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content-documents/ds8/ee/EFTA00037922.md ADDED
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00037922)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ eftaNumber: "EFTA00037922"
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+ ocrPages: 0
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+ parseTier: "internal"
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+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
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+ ---
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+
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+ | From |
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+ |----------------------------------------------------------------------------------------------------------------------------------------------------|
17
+ | |
18
+ | Subject: RE: Epstein Victims<br>Date: Tue, 30 Jun 2020 23:33:06 +0000 |
19
+ | Importance: Normal<br>Inline-Images: image001.png |
20
+ | Hey |
21
+ | No problem and no rush. Early next week is great. They are both on standby and with a day or so notice can make<br>anytime work. |
22
+ | EDWARDS<br>POTTINGER LLC<br>.r<br>1L-41.<br>Trial Attorney<br>425 North Andrews Avenue, Suite 2<br>Fort Lauderdale, Florida 33301<br>www.epllc.com |
23
+ | From:<br>Sent: Tuesday, June 30, 2020 7:22 PM<br>To:<br>Subject: RE: Epstein Victims |
24
+ | Hey |
25
+ | I apologize but I'm pretty swamped this week. Are your clients able to talk early next week? |
26
+ | |
27
+ | > wrote:<br>On Jun 27, 2020 1:53 PM,<br><<br>Hey |
28
+ | Just circling back on this. Are you available any day next week to speak with<br>and |
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+ | Also wanted to check in on the possibility of obtaining 302's or another form of verification that a victim has interviewed<br>with you. |
30
+ | Have a great weekend, |
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+
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+
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+
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+ ## Trial Attorney
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+
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+ 425 North Andrews Avenue. Suite 2 Fort Lauderdale. Florida 33301
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+
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+ www.epllc.com
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+
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+ | From: | |
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+ |--------------------------------------|--|
42
+ | Sent: Tuesday, June 23, 2020 7:05 PM | |
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+ | To: | |
44
+ | Cc: | |
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+ | Subject: RE: Epstein Victims | |
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+
47
+ Hi
48
+
49
+ I apologize for the delay in response but I wanted to check on scheduling. As of right now, I'm not going to be available on Monday. Is there another day that would be possible?
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+
51
+ Thanks,
52
+
53
+ Special Agent-FBI New York Field Office Child Exploitation/Human Trafficking
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+
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+ | From: | [mailto | |
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+ |--------------------------|--------------------------------------|--|
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+ | | Sent: Tuesday, June 23, 2020 5:45 AM | |
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+ | To: | | |
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+ | Cc: | | |
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+ | Subject: Epstein Victims | | |
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+
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+ Does Monday, June 29 work for you to speak with the following victims:
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+
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+ 1. 2.
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+
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+ If so, let me know what times work best for you.
67
+
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+ Thank you,
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+
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+
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+
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+ Trial Attorney 425 North Andrews Avenue. Suite 2 Fort Lauderdale. Florida 33301
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+
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+ | www.epllc.com
content-documents/ds8/ee/EFTA00037968.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00037968)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ eftaNumber: "EFTA00037968"
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+ ocrPages: 8
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+ ---
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+
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+ | From: "=1, |
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+ |----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
17
+ | ica<br>To:'<br>" |
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+ | Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your<br>review |
19
+ | Date: Tue, 15 Sep 2020 18:03:24 +0000 |
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+ | Importance: Normal |
21
+ | Absolutely will do. |
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+ | Special Agent<br>FBI New York Field Office<br>Child Exploitation/Human Trafficking |
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+ | From:<br>Sent: Tuesday, September 15, 2020 2:01 PM<br>To:<br>;<br>Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review |
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+ | Hello |
25
+ | Given the sensitivity, please treat with confidentiality. |
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+ | Thanks, |
27
+ | Unit Chief<br>Litigation Support Unit/RIDS |
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+ | From: 1M,<br>Sent: Tuesday, September 15, 2020 1:15 PM |
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+ | To:<br>Cc:<br>Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review |
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+ | This is the first I've seen this. I'll read through this and let you know. |
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+ | Thanks for sending, |
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+ | Special Agent<br>FBI New York Field Office |
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+
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+ | From:<br>Sent: Tuesday, September 15, 2020 5:12 AM<br>To:<br>Cc:<br>Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review<br>Importance: High |
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+ |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
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+ | I am going to follow up this email with 4 attachments of an upcoming OPR report re: 2006-08<br>Good Morning SA<br>Epstein Investigation. OPR forwarded to us for review to make sure our 7A stance is not impacted. |
37
+ | I am going to begin to review this today, but I wanted to forward for you, as well. If you have not reviewed this yet, please<br>let us know if anything within the report could impact any ongoing investigations. |
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+ | We have until this Friday to respond. |
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+ | Feel free to email or call with any questions. |
40
+ | Thanks, |
41
+ | From:<br>Sent: Monday, September 14, 2020 8:21 PM<br>To: |
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+
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+ Subject: Fw: [EXTERNAL EMAIL] - USD01 Office of Professional Responsibility Matter for your review
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+
45
+ Hey
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+
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+ Please take a look at the attached docs and let me know if release of info in this report will impact our 7A position.
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+
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+ Thanks,
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+
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+ | From: | |
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+ |----------------------------------------------------------------------------------------------------|--|
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+ | Sent: Thursday, September 10, 2020 1:55 PM | |
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+ | To: | |
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+ | Cc: | |
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+ | Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review | |
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+
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+ I just had a conversation with SC about this. We have until next Friday to respond. I'll look into it tomorrow, as I have a few other deadlines I'm dealing with today. Just keeping you posted.
59
+
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+ Thanks,
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+
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+ | Unit Chief |
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+ |------------------------------|
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+ | Litigation Support Unit/RIDS |
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+
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+ From: Sent: Thursday, September 10, 2020 9:18 AM
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+
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+ To:
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+
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+ Subject: FW: [EXTERNAL EMAIL) - USDOJ Office of Professional Responsibility Matter for your review
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+
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+ #4
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+
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+ | From: | |
75
+ |--------------------------------------------|--|
76
+ | Sent: Wednesday, September 9, 2020 2:55 PM | |
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+ | To: | |
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+
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+ Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
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+
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+ | From: |
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+ |----------------------------------------------------------------------------------------------------|
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+ | Sent: Thursday, September 3, 2020 5:43 PM |
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+ | To: |
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+ | Cc: |
86
+ | |
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+ | Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review |
88
+ | 4 of 4 |
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+ | Forwarded message |
90
+ | From: " |
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+ | Date: Sep 2, 2020 1:19 PM |
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+ | Subject: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review |
93
+ | To: ' |
94
+ | Cc: |
95
+ | |
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+ | Assistant Director and General Counsel |
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+ | Office of General Counsel |
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+ | FBI Headquarters |
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+ | Washington, D.C. |
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+ | Mr. |
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+
102
+ Attached is a letter from Department of Justice Office of Professional Responsibility (OPR) Director transmitting to you, for a sensitivity review, OPR's draft report in the Southern District of Florida's handling of the Jeffrey Epstein matter during 2006-2008. We've found that the draft report is too large to email, so will set it separately in two parts. We ask that it be treated with confidentiality. The letter is self-explanatory, but please do not hesitate to let us know if you have any questions.
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+
104
+ With regards,
105
+
106
+ ### Counsel
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+
108
+ Office of Professional Responsibility U.S. Department of Justice 950 Pennsylvania Avenue, N.W. — Room 3266 Washin ton, D.C. 20530
content-documents/ds8/ee/EFTA00038715.md ADDED
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00038715)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ eftaNumber: "EFTA00038715"
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+ ---
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+
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+ | From:<br>To: | | |
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+ |------------------------------------|--------------------------------------------|--------------------|
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+ | | Subject: FW: Voice Message Attached from ■ | - name unavailable |
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+ | | Date: Wed, 18 Aug 2021 18:07:28 +0000 | |
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+ | Importance: Normal<br>Attachments: | 20210811 120731.wav | |
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+
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+ | Original Message<br>From<br>Sent: Wednesday, August 11, 2021 12:56 PM |
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+ |-------------------------------------------------------------------------------------------------------------------------------------------------|
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+ | To:<br>- FW: Voice Message Attached from<br>- name unavailable<br>Subject: [EXTERNAL EMA |
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+ | Passing this along per our standard practice. |
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+ | Ori inal Messa e<br>From:<br>Sent: Wednesday, August 11, 2021 12:30 PM<br>To:<br>Subject: FW: Voice Message Attached froi<br>- name unavailable |
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+ | Re Maxwell. |
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+ | Ori inal Messa e<br>From:<br>Sent: Wednesda , Au ust 11, 2021 12:08 PM<br>To:<br>Subject: Voice Message Attached from<br>name unavailable |
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+ | Time: Aug 11, 2021 12:07:31 PM |
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+
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+ **Click attachment to listen to Voice Message**
content-documents/ds8/ee/EFTA00038968.md ADDED
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00038968)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ eftaNumber: "EFTA00038968"
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+ ---
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+
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+ | From: '<br>To:<br>' |
16
+ |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
17
+ | Subject: [EXTERNAL EMAIL] - RE: RE: question for award application |
18
+ | Date: Wed, 29 Jun 2022 15:02:04 +0000 |
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+ | Importance: Normal |
20
+ | Attachments: FBI,_Non-USAO_Supervisor_Concurrence_Fonn JEpsteins<br>_Maxwell).pdf |
21
+ | -- in the spirit of closure (!), any luck on the concurrence form? I have<br>from NYPD, so now that<br>Hey<br>sentencing is done I think the office will submit as soon as possible (it's due Friday, but I think because of the upcoming<br>holiday weekend they'd love to submit today or tomorrow). Thanks! |
22
+ | From:<br>(USANYS)<br>Sent: Friday, June 24, 2022 14:20 |
23
+ | To:<br>Subject: RE: RE: question for award application |
24
+ | And I got her info, so updated concurrence is attached. Progress : ) |
25
+ | From:<br>Sent: Friday, June 24, 2022 13:21<br>To:<br>(USANYS)<br>Subject: RE: RE: question for award application |
26
+ | Much appreciated. ThanksMI |
27
+ | From:<br>Sent: Friday, June 24, 2022 1:04 PM |
28
+ | To:<br>Subject: [EXTERNAL EMAIL] - FW: RE: question for award application<br>Importance: High |
29
+ | FYI, all good! As soon as I get her info, I'll send you the updated form and summary. |
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+ | From:<br>(USANYS)<br>Sent: Friday, June 24, 2022 13:03<br>To: |
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+ | Subject: RE: question for award application<br>Importance: High |
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+ | Dear |
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+
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+ Been a while, so I hope you're well these days! I wanted to send a quick email because our office is nominating the Epstein / Maxwell case for a Director's Award in the category of Superior Performance by a Litigation Team. Doing a nomination for that award in particular allows the office to include law enforcement partners as well, so we're thrilled to have the full team in the application, including in recognition of your extensive efforts with victims. I've reached out to and M, and so also wanted to ask you if you could please either email, or give me a quick call to tell me, your:
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+
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+ • DOB
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+
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+ - Last four of SSN
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+ - Your GS scale
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+ - Whether you've won any DOJ or other professional awards in the past three years
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+
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+ That's all! I'm reachable anytime at this email or by phone at . If it's possible to chat today, that would be great, or if not then whenever you're able.
43
+
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+ thanks again,
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+
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+ Assistant U.S. Attorney Southern District of New York
content-documents/ds8/ef/EFTA00009796.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00009796)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00009796"
8
+ ocrPages: 4
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+ parseTier: "internal"
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+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
13
+ ---
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+
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+ Code of Federal Regulations Title 5. Administrative Personnel Chapter XVI. Office of Government Ethics Subchapter B. Government Ethics Part 2635. Standards of Ethical Conduct for Employees of the Executive Branch (Refs & Annos) Subpart G. Misuse of Position
16
+
17
+ ## 5 C.F.R. § 2635.705
18
+
19
+ ## § 2635.705 Use of official time.
20
+
21
+ ## Currentness
22
+
23
+ (a) Use of an employee's own time. Unless authorized in accordance with law or regulations to use such time for other purposes. an employee shall use official time in an honest effort to perform official duties. An employee not under a leave system, including a Presidential appointee exempted under 5 U.S.C. 6301(2), has an obligation to expend an honest effort and a reasonable proportion of his time in the performance of official duties.
24
+
25
+ Example I: An employee of the Social Security Administration may use official time to engage in certain representational activities on behalf of the employee union of which she is a member. Under 5 U.S.C. 7131, this is a proper use of her official time even though it does not involve performance of her assigned duties as a disability claims examiner.
26
+
27
+ Example 2: A pharmacist employed by the Department of Veterans Affairs has been granted excused absence to participate as a speaker in a conference on drug abuse sponsored by the professional association to which he belongs. Although excused absence granted by an agency in accordance with guidance in chapter 630 of the Federal Personnel Manual allows an employee to be absent from his official duties without charge to his annual leave account, such absence is not on official time.
28
+
29
+ (b) Use of a subordinate's time. An employee shall not encourage, direct, coerce, or request a subordinate to use official time to perform activities other than those required in the performance of official duties or authorized in accordance with law or regulation.
30
+
31
+ Example 1: An employee of the Department of Housing and Urban Development may not ask his secretary to type his personal correspondence during duty hours. Further, directing or coercing a subordinate to perform such activities during nonduty hours constitutes an improper use of public office for private gain in violation of § 2635.702(a). Where the arrangement is entirely voluntary and appropriate compensation is paid, the secretary may type the correspondence at home on her own time. Where the compensation is not adequate, however, the arrangement would involve a gift to the superior in violation of the standards in subpart C of this part.
32
+
33
+ SOURCE: 57 FR 3504I, Aug. 7, 1992; 62 FR 48747, Sept. 17, 1997, unless otherwise noted.
34
+
35
+ AUTHORITY: 5 U.S.C. 7301, 7351, 7353; 5 U.S.C. App. (Ethics in Government Act of 1978); E.O. 12674, 54 FR 15159, 3 CFR, 1989 Comp., p. 215, as modified by E.O. 12731, 55 FR 42547, 3 CFR, 1990 Comp., p. 306.
36
+
37
+ ## Notes of Decisions ( 1)
38
+
39
+ Current through Nov. 14, 2022, 87 FR 68310. Some sections may be more current. See credits for details.
40
+
41
+ End of Document s.2022 Thomson Reuters. No chin, to original U.S. Government Works.
content-documents/ds8/ef/EFTA00009823.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00009823)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
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+ ---
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+
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+ | From: ' | |
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+ |--------------|---------------------------------------------------------------|
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+ | To: | ' |
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+ | Cc: " | |
19
+ | Subject: RE: | : Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's |
20
+ | | Friendship with Jeffrey Epstein in Prank Phone Call" |
21
+ | | Date: Wed, 11 Mar 2020 23:04:47 +0000 |
22
+
23
+ This had Prince Andrew, Prince Harry and Megan Markel in the same story.
24
+
25
+ | From:<br>Sent: Wednesday, March 11, 2020 7:03 PM<br>To:<br>Cc:<br>Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's Friendship with<br>Subject: Re:<br>Jeffrey Epstein in Prank Phone Call"<br>Nothing that I recall even comes close. For context, a really important WSJ or Times articles average about |
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+ |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
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+ | |
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+ | |
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+ | |
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+ | |
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+ | S250-500k. |
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+ | Sent from my iPhone |
33
+ | On Mar 11, 2020, at 6:48 PM,<br>> wrote: |
34
+ | Has any other article come close to that? An estimated 231,333,672 readers. |
35
+ | From: |
36
+ | Sent: Wednesday, March 11, 2020 6:25 PM |
37
+ | To: |
38
+ | Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's Friendship with<br>Subject: FW:<br>Jeffrey Epstein in Prank Phone Call" |
39
+ | This article is estimated to have over \$4M in publicity value. Insane. |
40
+ | |
41
+ | From: Critical Mention <alertpcriticalmention.com></alertpcriticalmention.com> |
42
+ | Sent: Wednesday, March 11, 2020 6:02 PM<br>To: |
43
+
44
+ Subject: Epstein in Prank Phone Call" : Yahoo Lifestyle - "Prince Harry Comments on Prince Andrew's Friendship with Jeffrey
content-documents/ds8/ef/EFTA00009952.md ADDED
@@ -0,0 +1,60 @@
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00009952)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00009952"
8
+ ocrPages: 0
9
+ ocrChars: 2810
10
+ ocrElapsed: 0.0
11
+ parseTier: "internal"
12
+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
13
+ ---
14
+
15
+ ## STATEMENT IN SUPPORT OF REGISTRATION OF A UNITED STATES CIVIL AIRCRAFT IN THE NAME OF A LIMITED LIABILITY COMPANY.
16
+
17
+ PLAN D, LLC -, a limited liability company of a United States Citizen and is eligible to register aircraft in its name. In this regard, we make to following representations:
18
+
19
+ | 1. | The full name of the Applicant LLC is: PLAN D, LLC | |
20
+ |----|----------------------------------------------------|--|
21
+ |----|----------------------------------------------------|--|
22
+
23
+ II. The state in which this LLC is lawfully organized is: U.S. VIRGIN ISLANDS
24
+
25
+ The effective date of the LLC is: OCTOBER 19,2012
26
+
27
+ - IV. The name of each of the members of the LLC and the type of entity of each member (i.e.: individual, corporation, partnership, etc.)
28
+
29
+ | Type of Entity | | U.S. Citizenship Verification | |
30
+ |------------------------------------------------|--------|-------------------------------|--|
31
+ | Individual | X<br>Y | | |
32
+ | | Y | N | |
33
+ | | Y | N | |
34
+ | | | | |
35
+ | Additional Members listed on additional pages: | | | |
36
+ | | | | |
37
+
38
+ V. This LLC is managed by Managers or Members (Circle One)
39
+
40
+ VI. The manager(s) or member(s) of this LLC may act independently: Y X N
41
+
42
+ - VII. The name of the Manager of this LLC LAWRENCE VISOSKI
43
+ The Manager is a(n)_X individual corporation partnership other
44
+
45
+ The undersigned certifies that he/she/it understands that an LLC is eligible to register aircraft in its name provided that:
46
+
47
+ - (I) at least 2/3rds of the managers or managing members are "U.S. Citizens" within the meaning of 49 U.S.C. Section 40102(2)(15)(C) and:
48
+ - (2) at least 75% of the voting interest or units is owned or controlled by persons who are "U.S.citizens" or citizens of one of its possessions; and specifically that AN LLC CANNOT REGISTER AS A NON-CITIZENS CORPORATION.
49
+
50
+ If any member of this LLC is not a United States Citizen as defined in 40102(a)(15)(C) an explanation appears below to support the certification that this LLC is a "U.S. Citizen" as required by 49 U.S.C. Section 40102(2)(15)(C).
51
+
52
+ The undersigned hereby also certifies that the information given herein is true and correct and meets all citizenship specifications as required by the Federal Aviation AdminiStlation.
53
+
54
+ PLAIN D, LLC e By:
55
+
56
+ L wrence Visoski Its: Manager
57
+
58
+ 09 9 A 29 MAR 2011 CITY 8:TAW:IA OKLAHOMA
59
+
60
+ FAA WITH FILED REGISTRATION AIRCRAFT DR
content-documents/ds8/ef/EFTA00010152.md ADDED
@@ -0,0 +1,23 @@
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00010152)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00010152"
8
+ ocrPages: 2
9
+ ocrChars: 262
10
+ ocrElapsed: 10.4
11
+ parseTier: "internal"
12
+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
13
+ ---
14
+
15
+
16
+
17
+ Chambers,
18
+
19
+ The parties respectfully submit the attached letter providing a list of names and places for voir dire.
20
+
21
+ Thank you.
22
+
23
+ Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 100.
content-documents/ds8/ef/EFTA00010587.md ADDED
@@ -0,0 +1,899 @@
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00010587)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00010587"
8
+ ocrPages: 50
9
+ ocrChars: 43511
10
+ ocrElapsed: 12.7
11
+ parseTier: "internal"
12
+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
13
+ ---
14
+
15
+ | From: Joe Nascimento | | | |
16
+ |----------------------|---------------------------------------|-----|--|
17
+ | To:" | "cl | | |
18
+ | Cc: | | k>, | |
19
+ | | | | |
20
+ | Subject: Re: | ) - Epstein | | |
21
+ | | Date: Thu, 19 Aug 2021 23:34:30 +0000 | | |
22
+
23
+ Will do. Thanks for the recommendation!
24
+
25
+ Sent from my iPhone
26
+
27
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC | |
28
+ |-----------------------------------------------------------------|--------|
29
+ | Lawyer's Plaza I 4th Floor | |
30
+ | 2250 S.W. 31±1Avenue | |
31
+ | Miami Florida 33129 | |
32
+ | t.<br>f. | |
33
+ | e. | |
34
+ | www.crimlawfirm.com | |
35
+ | | |
36
+ | On Aug 19, 2021, at 5:40 PM, | wrote: |
37
+
38
+ Thanks! Could you please both fill out the attached form? There's a mask mandate in federal buildings regardless of vaccination status (our team is vaccinated), so we'll all be wearing masks tomorrow. I should mention that the water fountains at our office don't work (a contamination issue), so you may want to bring water bottles.
39
+
40
+ For places near the office, I like a small coffee shop called Blue Spoon (76 Chambers Street), which has breakfast.
41
+
42
+ | From: Joe Nascimento | |
43
+ |-----------------------------------------|--|
44
+ | Sent: Thursday, August 19, 2021 5:26 PM | |
45
+ | I <<br>To:<br>> | |
46
+ | Cc:<br>(USANYS) | |
47
+ | ) - Epstein<br>Subject: Re: | |
48
+
49
+ Yes, we are both vaccinated. She has her card, I have a picture of mine. Any recommendations for breakfast in the morning near your office?
50
+
51
+ Sent from my iPhone
52
+
53
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3rdAvenue Miami Florida 33129
54
+
55
+
56
+
57
+ | On Aug 19, 2021, at 5:22 PM, | | > wrote: |
58
+ |------------------------------|--|----------|
59
+ |------------------------------|--|----------|
60
+
61
+ Hi Joe,
62
+
63
+ We're sorting out some logistics for tomorrow related to pandemic protocols. Could you please let me know whether you and your client are vaccinated?
64
+
65
+ Thanks,
66
+
67
+ | From: Joe Nascimento c | > |
68
+ |------------------------------------------|---|
69
+ | Sent: Monday, August 16,<br>202111:18 AM | |
70
+ | To: | |
71
+ | (USANYS)<br>Cc: | |
72
+ | - Epstein<br>Subject: Re: | |
73
+
74
+ Good morning,
75
+
76
+ We are set to be there this Friday. Please let me know what time you want to start and where we should go.
77
+
78
+ Thanks,
79
+
80
+ Joe
81
+
82
+ Sent from my iPhone
83
+
84
+
85
+
86
+ - Her full name as it appears on her government-issued ID
87
+ - Her date of birth
88
+ - Her home address, cellphone number, and email address
89
+
90
+ Once I have these details, I can pass them along to our witness coordinator, who can reach out to to make arrangements.
91
+
92
+ Thanks,
93
+
94
+ | From: Joe Nascimento | |
95
+ |----------------------------------------|--|
96
+ | Sent: Thursday, August 5, 2021 1:18 PM | |
97
+ | I <<br>To:<br>> | |
98
+ | Cc:<br>(USANYS) | |
99
+ | - Epstein<br>Subject: Re: | |
100
+
101
+ Great, thanks for working around our schedules. Let's reserve Friday 8/20. Hopefully you can fly up Thursday night and she can take a late night flight home Friday to give you all day with her.
102
+
103
+ Let me know what you need from us. If its easier, feel free to communicate directly with ) to make travel arrangements.
104
+
105
+ Thanks,
106
+
107
+ Joe
108
+
109
+ | Joseph E. Nascimento, Esq. |
110
+ |-----------------------------------|
111
+ | ROSS AMSEL RABEN NASCIMENTO, PLLC |
112
+ | Lawyer's Plaza I 4th Floor |
113
+ | 2250 S.W. 3rd<br>Avenue |
114
+ | Miami, FL 33129 |
115
+ | |
116
+ | f. |
117
+ | e. |
118
+ | www.crimlawfirm.com |
119
+
120
+ | From: " | |
121
+ |--------------------------------------------|---------|
122
+ | Date: Wednesday, Au ust 4 2021 at 10:11 PM | |
123
+ | To: Joe Nascimento | |
124
+ | Cc: '<br>SANYS)" | ,<br>II |
125
+ | | |
126
+ | - Epstein<br>Subject: Re: | |
127
+
128
+ Hi Joe,
129
+
130
+ I've confirmed with the agents, and either of those days would work for us. Do you have a preference on scheduling? Happy to work around whatever works best for your travel schedule.
131
+
132
+ Thanks,
133
+
134
+ | On Aug 3, 2021, at 7:47 PM, Joe Nascimento <<br>wrote: | |
135
+ |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
136
+ | HIM, | |
137
+ | and she hopes we can schedule the meeting for the 19th or 20th.<br>I spoke with | |
138
+ | Thanks, | |
139
+ | Joe | |
140
+ | Sent from my iPhone | |
141
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC<br>Lawyer's Plaza 14th Floor<br>2250 S.W. 3rd<br>Avenue<br>Miami Florida 33129<br>t.<br>f.<br>e.<br>www.crimlawfirm.com | |
142
+ | On Aug 3, 2021, at 10:03 AM, Joe Nascimento c<br>> wrote: | |
143
+ | Of course, what time works best for you?<br>Sent from my iPhone | |
144
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC<br>Lawyer's Plaza 14th Floor<br>2250 S.W. 3rd<br>Avenue<br>Miami Florida 33129<br>t.<br>f.<br>e.<br>www.crimlawfirm.com | |
145
+ | On Aug 3, 2021, at 10:02 AM,<br>> wrote:<br>Hi Joe,<br>Hope you're doing well. Are you available for a brief call this afternoon? | |
146
+
147
+ Thanks,
148
+
149
+ | From: Joe Nascimento ciM | ) |
150
+ |--------------------------------------|---|
151
+ | Sent: Monday, April 26, 2021 9:53 AM | |
152
+ | I<br>To:<br>><br>sc | |
153
+ | Cc:<br>(USANYS) | |
154
+ | | |
155
+ | - Epstein<br>Subject: Re: | |
156
+
157
+ Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a part a daily part of my life the past year, so we should be OK. See you all then, let me know if you need anything further from us in the meantime.
158
+
159
+ Sent from my iPhone
160
+
161
+
162
+
163
+ Hi Joe,
164
+
165
+ Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
166
+
167
+ Thanks,
168
+
169
+ I spoke with and she can make herself available the following dates:
170
+
171
+ May 3, 4 (before 2pm), 5, 6, 12, 13 or 14.
172
+
173
+ She is going to take the day off of work, so no need to do it after-hours (thank you for the offer). Let me know if you need additional availability.
174
+
175
+ Thanks,
176
+
177
+ Joe
178
+
179
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC |
180
+ |-----------------------------------------------------------------|
181
+ | Lawyer's Plaza I 4th Floor |
182
+ | 2250 S.W. 3rdAvenue |
183
+ | Miami Florida 33129 |
184
+ | t.<br>f. |
185
+ | e. |
186
+ | www.crimlawfinn.coin |
187
+ | <image001.jpg></image001.jpg> |
188
+ | |
189
+ | From: |
190
+ | Date: Friday, April 16 2021 at 1:31 PM |
191
+ | To: Joe Nascimento |
192
+ | Cc:<br>(IJSANYS) |
193
+ | |
194
+ | Subject: RE:<br>- Epstein |
195
+
196
+ Thanks very much — let's plan for 9:30 a.m. on Monday, if that works for you. Should I just call your desk line, or would you prefer a different number?
197
+
198
+ Thanks,
199
+
200
+ | From: Joe Nascimento | |
201
+ |--------------------------------------|--|
202
+ | Sent: Friday, April 16, 2021 1:00 PM | |
203
+ | To: | |
204
+ | Cc:<br>(USANYS) | |
205
+ | | |
206
+ | - Epstein<br>Subject: Re: | |
207
+
208
+ Hi Allison,
209
+
210
+ Yes, I'm free Monday morning between 9:30 and 12 or Tuesday between 11-3. If that doesn't work for you, I can try to move something around. Let me know.
211
+
212
+ Have a nice weekend,
213
+
214
+ Joe
215
+
216
+ Sent from my iPhone
217
+
218
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC |
219
+ |-----------------------------------------------------------------|
220
+ | Lawyer's Plaza I 4th Floor |
221
+ | 2250 S.W. 3rdAvenue |
222
+ | Miami Florida 33129 |
223
+ | t. |
224
+ | c. |
225
+ | www.crimlawfirm.com |
226
+ | |
227
+ | |
228
+ | |
229
+ | |
230
+ | |
231
+
232
+ On Apr 16, 2021, at 11:58 AM, ) < wrote:
233
+
234
+ Hi Joe,
235
+
236
+ Hope you're doing well. Are you available for a call sometime early next week? Nothing urgent, but we wanted to talk with you about potentially scheduling an interview (by video conference) with your client for sometime in early May.
237
+
238
+ Thanks,
239
+
240
+ | From: Joe Nascimento |
241
+ |-------------------------------------------|
242
+ | Sent: Monday, March 8, 20211:54 PM |
243
+ | I <<br>To:<br>> |
244
+ | Cc: |
245
+ | |
246
+ | - Epstein<br>Subject: Re: |
247
+ | Yes, 10:30 works for me. Thank youl |
248
+ | Joseph E. Nascimento, Esq. |
249
+ | ROSS AMSEL RABEN NASCIMENTO, PLLC |
250
+ | Lawyer's Plaza I 4th Floor |
251
+ | rdAvenue<br>2250 S.W. 3 |
252
+ | Miami Florida 33129 |
253
+ | t. |
254
+ | f. |
255
+ | e. |
256
+ | www.crimlawfirm.com |
257
+ | |
258
+ | From: |
259
+ | Date: Monday, March 8,<br>2021 at 1:32 PM |
260
+ | To: Joe Nascimento |
261
+ | Cc: |
262
+
263
+
264
+
265
+ Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
266
+
267
+ Thanks,
268
+
269
+ | From: Joe Nascimento | | | |
270
+ |-------------------------------------|-----------|--|--|
271
+ | Sent: Monday, March 8, 2021 1:24 PM | | | |
272
+ | To: | | | |
273
+ | Cc: | | | |
274
+ | 4 | | | |
275
+ | Subject: Re: | - Epstein | | |
276
+ | | | | |
277
+ | HIM, | | | |
278
+
279
+ I hope you are well. Please let me know if you have 5 min for a quick call.
280
+
281
+ Sent from my iPhone
282
+
283
+ | Joseph E. Nascimento, Esq. |
284
+ |----------------------------------------|
285
+ | ROSS AMSEL RABEN NASCIMENTO, PLLC |
286
+ | Lawyer's Plaza 14th Floor |
287
+ | 2250 S.W. 3rd<br>Avenue |
288
+ | Miami Florida 33129 |
289
+ | t.<br>f. |
290
+ | e. |
291
+ | www.crimlawfirm.com |
292
+ | |
293
+ | |
294
+ | |
295
+ | |
296
+ | |
297
+ | |
298
+ | On Jul 2, 2020, at 11:09 AM,<br>wrote: |
299
+ | Hi Joe, |
300
+
301
+ Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation with our investigation, and her status from our perspective has not changed. We'll be in touch going forwardj
302
+
303
+ ## All the best,
304
+
305
+ | From: Joe Nascimento | | | | |
306
+ |--------------------------------------|-------------|------|---|--|
307
+ | Sent: Thursday, July 2, 202011:07 AM | | | | |
308
+ | To: | | | | |
309
+ | Cc: | 'z | =11> | ) | |
310
+ | Subject: Re: | ) - Epstein | | | |
311
+
312
+ Good morning,
313
+
314
+ Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
315
+
316
+ you need anything from us, let us know.
317
+
318
+ -Joe
319
+
320
+ Sent from my iPhone
321
+
322
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza I 4th Floor 2250 S.W. 3rd Avenue Miami Florida 33129 t. f. e. www.crimlawfirm.com
323
+
324
+ On Feb 21, 2020, at 3:53 P
325
+
326
+ wrote:
327
+
328
+ Joe,
329
+
330
+ We very much appreciated that, and we just wanted to let you know that the lack of communication separate from that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch again when we're able.
331
+
332
+ If
333
+
334
+
335
+
336
+ | From: Joe Nascimento •c | | | |
337
+ |------------------------------------------|-----------|--|--|
338
+ | Sent: Wednesday, February 19, 2020 15:03 | | | |
339
+ | To: | | | |
340
+ | Cc: | | | |
341
+ | Subject: Re: | - Epstein | | |
342
+
343
+ We really appreciate this email. I was able to speak with a few weeks ago and gave the green light to share name and information provided with anyone necessary in your investigation. We will wait to hear from you if you need anything further.
344
+
345
+ Thanks,
346
+
347
+ Joe
348
+
349
+ | Joseph E. Nascimento, Esq. |
350
+ |-----------------------------------|
351
+ | ROSS AMSEL RABEN NASCIMENTO, PLLC |
352
+ | Lawyer's Plaza I 4th Floor |
353
+ | 2250 S.W. 3rd<br>Avenue |
354
+ | Miami, FL 33129 |
355
+ | |
356
+ | f. |
357
+ | e. |
358
+
359
+ www.crimlawfirm.com
360
+
361
+ | From: ' | | | |
362
+ |----------------------|--------------------|----|--|
363
+ | Date: Monday, Februa | 17 2020 at 3:40 PM | | |
364
+ | To: Joe Nascimento | | | |
365
+ | Cc: | | •• | |
366
+ | | | | |
367
+ | Subject: RE: | ) - Epstein | | |
368
+
369
+ Joe,
370
+
371
+ We just wanted to check in very briefly—we had been hopeful that we'd be able to circle back with you earlier, but our investigation is currently still ongoing, so at the very least we wanted to let you know that we continue to appreciate both your client's prior assistance and her willingness to assist in the future. Nothing in our investigation since we were last substantively in touch has changed our view of your client, and we hope to be able to be in touch with you in the coming weeks with an update. In the interim, we do continue to view her status as we've previously conveyed, and please let us know if any issues arise on your end.
372
+
373
+ thank you,
374
+
375
+
376
+
377
+ | From: | c<br>> | | |
378
+ |----------------------------------------------------------|-----------|---|---------------------------------|
379
+ | Sent: Saturday, November 30, 2019 14:42 | | | |
380
+ | To: Joe Nascimento | | | |
381
+ | Cc: | | ; | |
382
+ | | | | |
383
+ | Subject: Re: | - Epstein | | |
384
+ | Hi Joe, | | | |
385
+ | Thanks for checking in—<br>appreciate your following up. | | | so no issues on our end, but we |
386
+ | Thanks, | | | |
387
+ | | | | |
388
+ | Sent from my iPhone | | | |
389
+ | On Nov 30, 2019, at 8:54 AM, Joe Nascimento < | | | > wrote: |
390
+ | Good morning, | | | |
391
+ | Just wanted to check-in | | | |
392
+ | | | | |
393
+
394
+ Please let us know if you need anything from us.
395
+
396
+ Thanks,
397
+
398
+ Joe
399
+
400
+ Sent from my iPhone
401
+
402
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza I 4th Floor 2250 S.W. 3rd Avenue Miami Florida 33129 t. f. e. www.crimlawfirimeoin
403
+
404
+ On Sep 9, 2019, at 9:47 PM, Joe, wrote:
405
+
406
+ We will meet tomorrow at the same lace as last time— the Hilton in West Palm Beach, on Okeechobee Blvd. My cell is when ou arrive. My colleague, will be joining us, and he can be reached a
407
+
408
+ Thanks,
409
+
410
+ | Sent from my iPhone | |
411
+ |-----------------------------------------------|----------|
412
+ | On Sep 4, 2019, at 10:46 PM, Joe Nascimento < | > wrote: |
413
+ | Yes, we will be there. | |
414
+
415
+ Sent from my iPhone
416
+
417
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC<br>Lawyer's Plaza I 4th Floor |
418
+ |-----------------------------------------------------------------------------------------------|
419
+ | 2250 S.W. 3rd<br>Avenue |
420
+ | Miami Florida 33129 |
421
+ | t.<br>f.<br>e.<br>www.crimlawfirm.com |
422
+ | On Sep 4, 2019, at 5:32 PM,<br>wrote: |
423
+ | Hi Joe, |
424
+ | Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work? |
425
+
426
+ Thanks,
427
+
428
+ | From: Joe Nascimento | |
429
+ |---------------------------------------------|--|
430
+ | Sent: Wednesday, September 4, 2019 10:13 AM | |
431
+ | I aa<br>To: | |
432
+ | I<br>Cc: | |
433
+ | | |
434
+ | - Epstein<br>Subject: Re: | |
435
+
436
+ Good morning,
437
+
438
+ Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or 13th work best for me. Look forward to hearing from you.
439
+
440
+ -Joe
441
+
442
+ Sent from my iPhone
443
+
444
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC |
445
+ |-----------------------------------------------------------------|
446
+ | Lawyer's Plaza I 4th Floor |
447
+ | 2250 S.W. 3rd<br>Avenue |
448
+ | Miami Florida 33129 |
449
+ | t. |
450
+ | f. |
451
+ | e. |
452
+ | www.crimlawfirm.com |
453
+ | On Sep 4, 2019, at 10:04 AM,<br>> wrote: |
454
+
455
+ Hi Joe,
456
+
457
+ Hope the storm missed you this week, and that you and your client are doing okay.
458
+
459
+ Our team is working out some scheduling issues today, and we should know more by this afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
460
+
461
+ Thanks,
462
+
463
+ Sent from my iPhone
464
+
465
+ On Aug 30, 2019, at 9:52 AM, Joe Nascimento wrote:
466
+
467
+ Good morning,
468
+
469
+ Just wanted to check in to see if you still planned to travel south given the storm. Current estimates show a landing (somewhere) Tuesday with very bad weather on Wednesday. Airports might close (which will answer my question), but that's a guess.
470
+
471
+ Sent from my iPhone
472
+
473
+ | Joseph E. Nascimento, Esq.<br>ROSS AMSEL RABEN NASCIMENTO, PLLC |
474
+ |-----------------------------------------------------------------|
475
+ | Lawyer's Plaza 14th Floor |
476
+ | 2250 S.W. 3rd<br>Avenue |
477
+ | Miami Florida 33129 |
478
+ | t.<br>f. |
479
+ | C.<br>www.crimlavv lirm.com |
480
+ | On Aug 21, 2019, at 2:40 PM,<br>wrote: |
481
+
482
+ Hi Joe,
483
+
484
+ Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a hotel in West Palm Beach, and I'll let you know closer in time which location.
485
+
486
+ Thanks,
487
+
488
+ | From: Joe Nascimento | |
489
+ |---------------------------------------|--|
490
+ | Sent: Monday, August 19, 2019 6:37 PM | |
491
+ | To: | |
492
+ | Cc: | |
493
+ | | |
494
+ | ) - Epstein<br>Subject: Re: | |
495
+
496
+ Hi
497
+
498
+ Both the time and date work for us. Let me know the location when you have it confirmed.
499
+
500
+ Thanks,
501
+
502
+ Joe
503
+
504
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza I 4th Floor 2250 S.W. 3rd Avenue Miami Florida 33129 t. f. e. www.crimlawfirm.com On Aug 19, 2019, at 11:11 AM,
505
+
506
+ Joe,
507
+
508
+ wrote:
509
+
510
+ Following up on scheduling, we were wondering if your client is available for a proffer on September 4th. We're flexible on timing that day, but we would propose meeting at 12:30 p.m., if that works.
511
+
512
+ Thanks,
513
+
514
+ | From: Joe Nascimento | | |
515
+ |-----------------------------------------|-----------|--|
516
+ | Sent: Wednesday, August 7, 2019 4:53 PM | | |
517
+ | Icas<br>To: | | |
518
+ | Cc: | | |
519
+ | | | |
520
+ | Subject: Re: | - Epstein | |
521
+ | | | |
522
+ | HIM, | | |
523
+
524
+ I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon (anytime after 1)? I have proactive cooperation ongoing in another case involving multiple jurisdictions, and they are looking to meet the morning of 8/14. I understand if your schedule is already set, and will work around it.
525
+
526
+ Thanks,
527
+
528
+ Joe
529
+
530
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3rd Avenue Miami, FL 33129 f. e. www.erimlawfirm.com
531
+
532
+ | From: " | | | | |
533
+ |-----------------------------------------|-----------|--|--|--|
534
+ | Date: Friday, August 2, 2019 at 3:34 PM | | | | |
535
+ | To: Joe Nascimento | | | | |
536
+ | Cc: | | | | |
537
+ | | | | | |
538
+ | Subject: RE: | - Epstein | | | |
539
+
540
+ Joe,
541
+
542
+ Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and we'll follow up to firm up plans as we get closer. If there are any conflicts with that date, please let us know, we're happy to be flexible.
543
+
544
+ | Thanks, |
545
+ |------------------------------------------------------------------------------|
546
+ | |
547
+ | From:<br>Joe Nascimento<br>><br>gc<br>Sent: Thursday, August 1, 2019 8:10 PM |
548
+ | To: |
549
+ | Cc: |
550
+ | .c=<br>><br>- Epstein<br>Subject: Re: |
551
+ | ME, |
552
+
553
+ I do not have any travel plans during the month of August, nor does September is a busy month with two trials set, and I will be traveling out of the country from Sept 17-30, but I will do everything to be as flexible as possible.
554
+
555
+ Thanks,
556
+
557
+ Joe
558
+
559
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3rd Avenue Miami, FL 33129
560
+
561
+ f. e. wvvw.crimlawfirm.com
562
+
563
+ | From: ' | r | |
564
+ |-------------------------------------------|-------------|--|
565
+ | Date: Thursday, August 1. 2019 at 6:10 PM | | |
566
+ | To: Joe Nascimento | | |
567
+ | Cc: | | |
568
+ | | | |
569
+ | Subject: RE: | ) - Epstein | |
570
+
571
+ Joe,
572
+
573
+ As we start thinking about scheduling a next meeting with S we were wondering if you could please let us know if there are any particular weeks that would not work for you or your client for a meeting in Florida (in particular, we don't want to interfere with anyone's summer vacation plans).
574
+
575
+ We will of course be in touch to talk about a next meeting in more detail, but in the first instance it would be helpful to get a sense of your schedules, for planning purposes.
576
+
577
+
578
+
579
+ | From: Joe Nascimento |
580
+ |---------------------------------------------------------|
581
+ | Sent: Wednesday, July 17, 2019 6:25 PM |
582
+ | To: |
583
+ | I •<br>Cc: |
584
+ | - Epstein<br>Subject: Re: |
585
+ | Hi Allison, |
586
+ | That works for me. Please call me on my cell<br>Thanks. |
587
+ | Sent from my iPhone |
588
+
589
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza I 4th Floor 2250 S.W. 3rd Avenue Miami Florida 33129 t. f. e. www.crimlawfirm.com
590
+
591
+ On Jul 17, 2019, at 5:58 PM, wrote:
592
+
593
+ Hi Joe,
594
+
595
+ Following up, we were wondering if you were available for a call to discuss next steps. We're available on Friday at 2:30, if that works, but let us know if there are other times that would be more convenient for you.
596
+
597
+ Thanks,
598
+
599
+ | From: Joe Nascimento | |
600
+ |----------------------------------------|----|
601
+ | Sent: Saturday, July 13, 2019 12:39 PM | |
602
+ | I<br>To: | |
603
+ | Cc: | >; |
604
+ | | |
605
+ | Subject: Re:<br>- Epstein | |
606
+
607
+ Good afternoon,
608
+
609
+ It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
610
+
611
+
612
+
613
+ As always, feel free to contact me at any time if we can be of further assistance. Look forward to meeting again.
614
+
615
+ ## -Joe
616
+
617
+ ## Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3rd Avenue
618
+
619
+ Miami, FL 33129
620
+
621
+ 13 f. e. www.crimlawfirm.com
622
+
623
+
624
+
625
+ Hi Joe,
626
+
627
+ We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are here, and we will meet you in the lobby.
628
+
629
+ Thanks,
630
+
631
+ | From: Joe Nascimento | |
632
+ |---------------------------------------|---|
633
+ | Sent: Thursday, July 11, 2019 9:02 PM | |
634
+ | To:<br>) < | > |
635
+ | Cc:<br>< | |
636
+ | ><br>< | |
637
+ | - Epstein<br>Subject: Re: | |
638
+
639
+ Good evening,
640
+
641
+ Have you set a location for our meeting tomorrow?
642
+
643
+ Thanks,
644
+
645
+ Joe
646
+
647
+ Sent from my iPhone
648
+
649
+ | Joseph E. Nascimento, Esq. |
650
+ |------------------------------------|
651
+ | ROSS AMSEL RABEN NASCIMENTO, PLLC |
652
+ | Lawyer's Plaza 14th Floor |
653
+ | 2250 S.W. 3rd<br>Avenue |
654
+ | Miami Florida 33129 |
655
+ | t. |
656
+ | f. |
657
+ | e. |
658
+ | www.crimlawfirm.com |
659
+ | |
660
+ | k<br>On Jul 10, 2019, at 12:03 PM, |
661
+ | |
662
+
663
+ On Jul 10, 2019, at 12:03 PM, wrote:
664
+
665
+ Thank you, we will plan to see you then in West Palm Beach. We are still coordinating logistics, and we will let you know that morning the address where we should meet.
666
+
667
+ Since we will be travelin lease feel free to call my cell if you need to reach us for any reason:
668
+
669
+ Thanks,
670
+
671
+ Sent from my iPhone
672
+
673
+ | | | | On Jul 10, 2019, at 11:39 AM, Joe Nascimento |
674
+ |--|--|--|----------------------------------------------|
675
+ |--|--|--|----------------------------------------------|
676
+
677
+ <1 cmailto
678
+
679
+ wrote:
680
+
681
+ Of course
682
+
683
+ Sent from my iPhone
684
+
685
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor <x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<xapple-data-detectors://2/0><z-apple-data-detectors://2/0> Avenue<x-apple-datadetectors://2/0> <x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-datadetectors://2/0> t. le i f. M : :l el ft-' e. mailto www.crimlawfirm.com<http://www.crimlawfirtmcornt>
686
+
687
+ On Jul 10, 2019, at 11:34 AM,
688
+
689
+ >>
690
+
691
+ mailto: >> wrote:
692
+
693
+ Joe,
694
+
695
+ Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
696
+
697
+ Sent from my iPhone
698
+
699
+ | | On Jul 9. 2019. at 10:51 PM. Joe Nascimento | |
700
+ |--------------------------------------------------------------|---------------------------------------------|--|
701
+ | | mailto | |
702
+ | <mailto:< td=""><td>&gt;&gt; wrote:</td><td></td></mailto:<> | >> wrote: | |
703
+ | | | |
704
+
705
+ Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
706
+
707
+ Thanks,
708
+
709
+ Joe
710
+
711
+ Sent from my iPhone
712
+
713
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor <x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-cletectors://2/0>rd<xapple-data-detectors://2/0><z-apple-data-detectors://2/0> Avenue<x-apple-datadetectors://2/0>
714
+
715
+ <x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-datadetectors://2/0>
716
+
717
+ <mailt > wrote:
718
+
719
+ | t.<br><lel< th=""></lel<> |
720
+ |------------------------------------------------------------|
721
+ | <lel<br>f.</lel<br> |
722
+ | |
723
+ | mailto: |
724
+ | <mail< td=""></mail<> |
725
+ | wvvw.crimlawfirm.com <http: www.crimlawfinmcom=""></http:> |
726
+ | <http: www.crimlawfinn.com=""></http:> |
727
+ | |
728
+ | On Jul 9 2019 at 4:56 PM |
729
+ | mailto: |
730
+
731
+ Joe,
732
+
733
+ :
734
+
735
+ We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
736
+
737
+ thanks,
738
+
739
+ <mailto:
740
+
741
+ From: Joe Nascimento
742
+
743
+ mailto:
744
+
745
+ | Sent: Tuesda | Jul 09 2019 16:43 | | |
746
+ |--------------------------------------------------------|-------------------|------|--|
747
+ | To: | | | |
748
+ | | mailto: | | |
749
+ | <mailto< td=""><td></td><td></td><td></td></mailto<> | | | |
750
+ | Cc: | | mail | |
751
+ | <mailto< td=""><td></td><td></td><td></td></mailto<> | | | |
752
+ | | mails. | | |
753
+ | <mailto:< td=""><td></td><td></td><td></td></mailto:<> | | | |
754
+ | Subject: Re: | - Epstein | | |
755
+ | | | | |
756
+
757
+ Hi M,
758
+
759
+ I got done a little earlier today - do you want to bump up our call time? Sent from my iPhone
760
+
761
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0> Miami Florida 33129<x-a le-data-detectors://2/0> t. <tel: <mail wvvw.crimlawfirm.com<http://www.crimlawfirm.com> <http://www.crimlawfirm.coml>
762
+
763
+ ## On Jul 9 2019 at 10:02 AM Joe Nascimento
764
+
765
+ From: ' "
766
+
767
+ | | mailto |
768
+ |-------------------------------------------------|----------|
769
+ | <mailto:< th=""><th>&gt; wrote:</th></mailto:<> | > wrote: |
770
+ | HIM, | |
771
+
772
+ Are you still free for a call?
773
+
774
+ | Joseph E. Nascimento, Esq. |
775
+ |------------------------------------------------------------|
776
+ | ROSS AMSEL RABEN NASCIMENTO, PLLC |
777
+ | Lawyer's Plaza I 4th Floor |
778
+ | 2250 S.W. 3rd Avenue |
779
+ | Miami, FL 33129 |
780
+ | pi<br>f. |
781
+ | e. |
782
+ | mails : |
783
+ | <mailto:< td=""></mailto:<> |
784
+ | www.crimlawfirm.com <http: www.crimlawfirm.com=""></http:> |
785
+ | <http: www.crimlawfirm.com=""></http:> |
786
+ | |
787
+ | |
788
+ | |
789
+
790
+ mailto:
791
+
792
+ | <mailto:< th=""><th></th><th></th></mailto:<> | | |
793
+ |-----------------------------------------------|----------------------------------------|--|
794
+ | | Date: Sunday, July 7, 2019 at 10:19 PM | |
795
+ | To: Joe Nascimento | | |
796
+ | | | |
797
+ | | | |
798
+ | | | |
799
+ | | | |
800
+ | | | |
801
+ | | | |
802
+ | <mailt.:< td=""><td></td><td></td></mailt.:<> | | |
803
+ | Subject: RE: | I - Epstein | |
804
+
805
+ Joe,
806
+
807
+ Sure, thanks — and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on Tuesday — you can reach us at , or we can also call you then if that's easier, whatever you prefer.
808
+
809
+
810
+
811
+ | From: Joe Nascimento | | |
812
+ |-----------------------------------------------|-----------|--|
813
+ | | mailto | |
814
+ | <mailto:< td=""><td></td><td></td></mailto:<> | | |
815
+ | Sent: Sumin | | |
816
+ | To: | | |
817
+ | | | |
818
+ | | | |
819
+ | | | |
820
+ | | | |
821
+ | | | |
822
+ | <mailto:< td=""><td></td><td></td></mailto:<> | | |
823
+ | Subject: Re: | - Epstein | |
824
+
825
+ HIM,
826
+
827
+ No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday morning (the earlier the better for me). Let me know what works for you.
828
+
829
+ Thanks,
830
+
831
+ Joe Sent from my iPhone
832
+
833
+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0> Miami Florida 33129<x-apple-data-detectors://2/0>
834
+
835
+ | t.<br>tel: | | |
836
+ |------------------------------------------------------------|---------|--|
837
+ | tel:<br>f. | | |
838
+ | e. | | |
839
+ | | mailto: | |
840
+ | <mailt :<="" td=""><td></td><td></td></mailt> | | |
841
+ | www.crimlawfirm.com <http: www.crimlawfirm.com=""></http:> | | |
842
+ | <http: www.crimlawfirm.comt=""></http:> | | |
843
+ | | | |
844
+ | On Jul 7. 2019. at 4:04 PM, | | |
845
+ | | | |
846
+
847
+ | | mailto: | |
848
+ |----------------------------------------------------------|----------|--|
849
+ | <mailto:< th=""><th>&gt; wrote:</th><th></th></mailto:<> | > wrote: | |
850
+ | Joe, | | |
851
+
852
+ Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before you meet with , if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being in touch.
853
+
854
+ thank you,
855
+
856
+ Assistant U.S. Attorney Southern District of New York
857
+
858
+ From: Joe Nascimento
859
+
860
+ | | mailto | |
861
+ |-----------------------------------------------|---------------|--|
862
+ | <mailto:< td=""><td></td><td></td></mailto:<> | | |
863
+ | Sent: Saturda , Jul | 06 2019 22:55 | |
864
+ | To: | | |
865
+ | | | |
866
+ | <mailt :<="" td=""><td></td><td></td></mailt> | | |
867
+ | Subject: | - Epstein | |
868
+
869
+ Begin forwarded message:
870
+
871
+ | From: | | |
872
+ |-------------------------------------------------|----------------------------|--|
873
+ | | | |
874
+ | <mailto:)< th=""><th></th><th></th></mailto:)<> | | |
875
+ | Date: Jul | 6, 2019 at 10:51:09 PM EDT | |
876
+ | To: | mails : | |
877
+ | <mailto:< td=""><td></td><td></td></mailto:<> | | |
878
+ | | | |
879
+ | <mailto< td=""><td></td><td></td></mailto<> | | |
880
+ | | mailto: | |
881
+ | <mailto.< td=""><td></td><td></td></mailto.<> | | |
882
+ | Cc: | mailto | |
883
+ | <mailto.< td=""><td></td><td></td></mailto.<> | | |
884
+ | Sub'ect: | -E stein | |
885
+ | | | |
886
+
887
+ My former partner, Alan Ross, represented
888
+
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+ prior to his passing in 2018. Agent served with a grand jury subpoena earlier today, and as Alan's former partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting up to speed. Please let me know what day/time is best for you.
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+
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+ Look forward to speaking with you.
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+
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+ Best,
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+
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+ Joe
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+
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+ Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0> Miami Florida 33129<x-apple-data-detectors://2/0> t. f. tel e. mailto: <mailto: www.erimlawfirm.com<http://www.crimlawfirm.com> <http://www.crimlawfirm.cornt>
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+ <SDNY COVID-19 Visitor Screening Form 05 04 21.pdf>
content-documents/ds8/ef/EFTA00010956.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00010956)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00010956"
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+ ocrPages: 18
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+ ocrChars: 29723
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+ ocrElapsed: 10.2
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+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
13
+ ---
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+
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+
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+
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+ Date: Fri, 22 Feb 2019 22:20:56 +0000 Importance: Normal
18
+
19
+ ## Coast Guard Officer Ordered to Jail, Accused of Being 'Domestic Terrorist' [Fox News]
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+
21
+ - Lt. Christopher Paul Hasson will remain in jail without bail for at least two weeks, a judge ruled Thursday (02/21/2019).
22
+ - Federal agents recovered 15 guns and more than 1,000 rounds of ammunition from Hasson's Maryland apartment.
23
+ - Investigators say Hasson repeatedly studied a manifesto authored by Anders Behring Breivik, the Norwegian right-wing extremist who killed 77 people in a 2011 bomb-and-shooting rampage. Prosecutor Jennifer Sykes claimed Thursday that Hasson would also log onto his government computer during work and spend hours searching for information on such people as the Unabomber, the Virginia Tech gunman and anti-abortion bomber Eric Rudolph.
24
+ - Related Article: Prosecutors Haven't Proved 'Hit List' Coast Guardsman is a Terrorist: Judge [NY Post]
25
+
26
+ ## US Citizen Charged in Kidnapping of Journalist in Somalia [Fox News]
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+
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+ - According to a criminal complaint unsealed Thursday (02/21/2019) in New York, Abdi Yusuf Hassan was part of a conspiracy to kidnap a journalist in January 2012 in Galkayo, Somalia, and demand \$20 million in ransom.
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+ - While the journalist is not named in the complaint or in a superseding indictment, the dates of his capture and release, and several details outlined in the court documents, match the experiences of author Michael Scott Moore, a German-American. In November, Moore confirmed to the New York Times that another man indicted in the case, Mohamed Tahlil Mohamed, was one of his captors. Mohamed and Hassan are listed as co-defendants.
30
+ - According to court documents, Hassan, 51, was born in Mogadishu and is a naturalized U.S. citizen. He faces six counts, including kidnapping conspiracy, hostage-taking conspiracy and unlawful use of firearms. He was arrested in Minneapolis on Friday and will be returned to New York to face charges.
31
+ - [Analyst's note: Abdi Yusuf Hassan and Mohamed Tahlil Mohamed positive for FBI holdings.]
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+
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+ # Global Terrorism
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+
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+ # United States (Social Media)
36
+
37
+ - A U.S. citizen suspect was arrested in Minneapolis, Minnesota, and charged with participating in the kidnapping of afreelance journalist in Somalia, where he was held for nearly three years over a \$20 million ransom, media reported Thursday Twitter [Star Tribune]
38
+ - o The suspect was charged in federal court in New York with six felony counts ranging from kidnapping to hostage-taking to illegal use ((firearms
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+ - o According to the criminal complaint, the suspect and other heavily armed captors abducted the journalist on Jan. 21, 2012, firm a vehicle in the northern Somali city of Galkayo in the Mudug region
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+
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+ # 11 American Women Who Left the US to Become ISIS Brides and Fighters [Business Insider]
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+
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+ - The State Department announced on Wednesday (02/20/2019) that a US-born woman who left Alabama to join the Islamic State would not be welcomed home. Secretary of State Mike Pompeo said that Hoda Muthana "does not have any legal basis, no valid US passport, no right to a passport, nor any visa to travel to the United States."
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+ - According to a report from the George Washington University's Program on Extremism, 72 Americans have successfully traveled to Syria or Iraq and joined ISIS and other Jihadist groups since 2011. Just 12% of the travelers have been women.
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+
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+ # Trump Calls For More Biometric Scans, Data Sharing To Stop Terrorism [NextGov]
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+
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+ - President Donald Trump on Wednesday (02/20/2019) signed the National Strategy to Combat Terrorist Travel, a new policy document that calls for increased use of biometric technologies and sharing of the data being collected in order to prevent the travel of known or suspected terrorists.
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+ - "Vetting includes automated biographic and/or biometric matching against watchlists and threat information;' the strategy states. The process referenced in the strategy "does not include the physical screening or inspection of people or goods that may occur at the border, United States Secret Service venues, or transportation checkpoints."
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+
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+ # American Who Joined aI-Qaeda, then Turned InformantSpeaks in First TV Interview [CBS]
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+
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+ - Bryant Villas tells 60 Minutes about the time he spent with al-Qaeda before providing key information to U.S. intelligence.
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+ - The lure of fighting for oppressed Muslims in the Middle East pitched in online videos drove troubled American Muslim-convert Bryant Villas into the arms of al-Qaeda in Afghanistan, where he spent eight months training with al-Qaeda. After he was caught in Pakistan and shipped back to the U.S., Villas provided key information about his experience.
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+
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+ - Villas spent eight years talking to the FBI while he was locked up and provided what former FBI acting director Andrew McCabe termed "incredibly valuable" information including identities of terrorists and how he made his way from Long Island, New York, into al-Qaeda.
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+ # Canadian Who Tried to Join Terror Group in Syria Released from Prison Despite Being 'High Risk to Public Safety' [Global News]
58
+
59
+ - An Ontario man who travelled to Syria to join an al-Qaida faction is being released from prison less than two years after pleading guilty, even though the Parole Board of Canada is concerned he might continue to engage in terrorism.
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+ - The Parole Board said Kevin Omar Mohamed had not participated in any de-radicalization efforts and there was no evidence he was committed to changing his "extremist ideological beliefs."
61
+ - Although the former University of Waterloo student was sentenced to 4.5 years imprisonment as recently as October 2017, he is already eligible for statutory release, when the time he had served awaiting trial is taken into consideration.
62
+
63
+ # German Police Detain 2 in Alleged Islamic Extremist Plot [Star Tribune]
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+
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+ - A German-Moroccan couple was arrested Thursday in central Germany on charges they were planning an Islamic extremist attack. A series of raids included searches of the homes of 12 other suspects, Frankfurt prosecutors said.
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+ - The couple, both 26 and German-Moroccan dual nationals, tried to travel with their two young children to Syria in 2016 to join the Islamic State extremist group, but were captured in Turkey and deported back to Germany, Niesen said. They were arrested at their home in the Raunheim area, southwest of Frankfurt in the state of Hesse.
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+ - Overall, some 200 police officers raided 15 homes in Ruesselsheim, Biebesheim, and Raunheim in Hesse as well as one in Kerpen in North Rhine-Westphalia.
68
+
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+ # Germany
70
+
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+ - German authorities arrested two German-Moroccan suspects and charged a dozen others Thursday after a series of police raids near Frankfurt aimed at disrupting a planned terrorist attack Associated Press
72
+ - o Authorities believe the suspects were in the early stages of planning an attack in Germany, though officials said they were not aware of an attack target
73
+ - . The suspects, both 26 and German-Moroccan dual nationals, tried to travel to Syria in 2016 to join ISIS, but were captured in Turkey and deported back to Germany
74
+ - o Overall, some 200 police officers raided 15 homes in the Frankfurt area, resulting in charges against 12 suspects for accessory to planning an attack in Germany
75
+
76
+ # Fabien Clain, French Jihadist and 'Voice of Paris Attacks', Reported Killed [BBC]
77
+
78
+ - Security sources told French media an air strike on Wednesday killed Clain in Baghuz, the last pocket held by IS.
79
+ - The US-led coalition fighting IS said it was trying to verify the reports.
80
+ - Clain became known as the French voice of IS after the 2015 attacks that left 130 people dead.
81
+
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+ # Afghanistan: Members of a Prominent Terror Gang of Taliban Arrested in Kabul [India Blooms]
83
+
84
+ - Afghanistan security forces have arrested at least four members of a prominent terror gang of Taliban group during an operation in Kabul city, media reports said on Friday (02/22/2019).
85
+ - The Taliban group members who belonged to one of the most destructive networks of the group were arrested during an operation of the Special Forces of Afghan Intelligence which was conducted in the
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+
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+ vicinity of the 5th police district of Kabul city, the National Directorate of Security, the intelligence directorate of Afghanistan said in a statement, reported Khaama Press.
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+
89
+ - The arrested people were identified as Abdullah son of Gul Rasool who is the leader of the network, Humayoun son of Majnoon, Maiwand son of Sharbat, and Faridullah alias AhmadZia son of Redi Gul.
90
+ - The detained individuals have confessed that they were recruited in Taliban ranks by one of the Taliban group leaders Asadullah Nasrat in Paghman district of Kabul and were busy in bombings, armed robberies, assassinations, harassments, and lootings in Kabul city, according to the National Directorate of Security.
91
+
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+ # The U.S. Sent Its Most Advanced Fighter Jets to Blow Up Cheap Opium Labs. Now It's Canceling the Program [Time]
93
+
94
+ - After hundreds of airstrikes failed to curtail the Taliban's \$200 million-a-year opium trade, the U.S. military quietly ended a yearlong campaign that targeted drug labs and networks laced around the Afghan countryside.
95
+ - The U.S. military first began targeting Taliban narcotics facilities with airstrikes and Special Operations raids in November 2017 when opium production jumped to record highs in Afghanistan. At the time, U.S. commanders estimated the Taliban operated up to 500 drug labs, which helped fuel their nearly twodecade long insurgency.
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+ - The military's strategy became the latest high-priced failure to slow endemic poppy cultivation and drug trafficking in Afghanistan. The U.S. has spent \$8.9 billion in U.S. counter-narcotics efforts since 2001, yet the war-torn country has consistently produced about 85% of the world's illicit opium supply.
97
+
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+ # United Kingdom: Only One in 10 Jihadis Returning from Syria Prosecuted, Figures Reveal [Independent UK]
99
+
100
+ - Amid calls for the government to repatriate Shamima Begum for criminal investigation rather than remove her British citizenship, police have warned it is "no easy task" to evidence a suspect's activities abroad.
101
+ - Ben Wallace the security minister, said around 40 people "have been successfully prosecuted so far either because of direct action they have carried out in Syria or, subsequent to coming back, linked to that foreign fighting".
102
+ - But more than 400 people "of national security concern" are believed to have returned from conflicts in Syria and Iraq.
103
+
104
+ # Amid Loss of Leaders, Unknown Militant Rises in Philippines [Washington Post]
105
+
106
+ - Not much is known about Hatib Hajan Sawadjaan, but the attacks attributed to him heralding his rise are distinctly savage: A deadly bombing, which authorities say was a suicide attack by a foreign militant couple, blasted through a packed Roman Catholic cathedral in the middle of a Mass.
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+ - The Jan. 27 attack, which killed 23 people and wounded about 100 others on southern Jolo Island, and another suspected suicide bombing on nearby Basilan Island last July that officials said he masterminded, put Sawadjaan in the crosshairs of the U.S.-led global campaign against terrorism.
108
+ - A recent U.S. Department of Defense report to Congress said without elaborating that it believed Sawadjaan was the "acting emir," or leader, in the Philippines of the Islamic State group, also known by its acronym ISIS.
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+
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+ ### Venezuela's Ex-Spy Chief Rejects Maduro, Accusing Leader's Inner Circle of Corruption - By Ana Vanessa
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+
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+ Herrero and Nicholas Casey Feb. 21, 2019 CARACAS, Venezuela — A former intelligence chief in Venezuela who is one of the government's most prominent figures turned against President Nicolas Maduro on Thursday, calling him a dictator
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+
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+ with a corrupt inner circle that has engaged in drug trafficking and courted the militant group Hezbollah. In interviews with The New York Times, the former intelligence chief, Hugo Carvajal, 58, who is a congressman in the governing Socialist Party, urged the military to break with the president ahead of a showdown with the opposition on Saturday over Mr. Maduro's blockade of aid shipments on the country's borders. "It has been more than enough; Mr. Carvajal said in a statement, which was also released in a video online on Thursday and addressed to Mr. Maduro. "You have killed hundreds of young people in the streets for trying to claim the rights you stole. This without even counting the dead for lack of medicines and security." "To the generals," he added, "how is it that having the power to allow the entry of international humanitarian aid to our country to save lives, you would decide not to? Would you be so inhuman? So hypnotized?" The strong words come amid a wave of other defections by government officials, including a top air force official diplomats, military attaches and members of the national guard. This break with the regime, by a man who once guarded its secrets as intelligence chief, adds a dose of unexpected pressure on the president just three days before the confrontation over aid at the border with Colombia.
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+
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+ Mr. Carvajal's accusations also added a new twist to the unfolding drama: a willingness to provide evidence that could be used against Mr. Maduro's government should it fall. Mr. Carvajal — who in 2017 criticized Mr. Maduro for setting up a second legislature — now provided a valuable weapon to the opposition, which for years has contended that the president's inner circle has ties to drug runners and militants. President Trump warned Venezuelan military officials on Monday to abandon Mr. Maduro by the weekend or "lose everything." This was an escalation of American support for Juan Guaido, the leader of the opposition, who claims the presidency and has staked his bid on pushing shipments of humanitarian aid into Venezuela, against Mr. Maduro's wishes. Many of Mr. Guaides supporters said they are preparing to storm a border bridge to force open the blockade on Saturday. In his interview, Mr. Carvajal — who retired from the intelligence service in 2012, after having served almost 10 years — offered a rare account of the internal workings of a government in which he said drug trafficking and corruption were commonplace, managed by top figures such as Nestor Reverol, the interior minister; Tareck El Aissami. a minister who served as vice president; and Mr. Maduro himself. Those who were combating drugs "were the ones trafficking it, too," he said of Venezuelan officials who face indictments or sanctions in the United States. Mr. Carvajal is among those accused of drug trafficking by American investigators: He escaped extradition on drug charges in Aruba in 2014 and was sanctioned by the Treasury Department for having helped Colombian guerrilla groups smuggle cocaine. In the interviews, Mr. Carvajal admitted to dealings in both worlds. https://www.nytimes.com/2019/02/21/world/americas/hugo-carvajal-maduro-venezuela.html? action=click&module.RelatedCoverage&pgtype=Article&region.Footer
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+
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+ Venezuela's former chief of military intelligence declared his support for Guaid6, telling Maduro, "It's been more than enough." The Wall Street Journal's Ryan Dube and Kejal Vyas report: "Hugo Carvajal, a retired general and current congressman for the ruling Socialist Party, called for authorities to allow into Venezuela the humanitarian aid that the U.S. is stockpiling on the Colombian border.... Mr. Carvajal, who spent more than three decades in Venezuela's military, also had a sobering message for active troops, many of whom have been appearing in propaganda videos meant to rile up nationalist sentiment against what the Maduro regime says is an imminent U.S. invasion."
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+
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+ Sunni Jihad is Going Local - For decades, Sunni jihadism has been characterized by transnational terrorism, suicide bombing, and excommunication. These three pillars not only attracted the ire of American and European governments, but turned off many of the jihadists' target constituents, namely Sunnis living in the Muslim world. Yet there are signs that Sunni extremists are changing their ways, drifting away from the global agenda that reached its apotheosis in al-Qaeda's attack on the World Trade Center, and toward a hyperlocal one. The transformation is happening in various countries, including Afghanistan, Yemen, and Mali. Jabhat al-Nusra, al-Qaeda's offshoot in Syria, provides an illustrative example of how the jihadist threat is changing across the region. In 2016, Jabhat al-Nusra put together a lengthy training manual for its new recruits. In the roughly 200-page book, obtained by me, the group argues the merits of country-focused jihad over global jihad. It advises followers that al-Qaeda's stated strategy of going after the "far enemy" was not set in stone, and that, in the current moment, a focus on anything other than the local fight would be an "unacceptable distraction." (The Atlantic - 2/15)
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+
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+ Iran says Suicide Bomber who hit Revolutionary Guards was Pakistani - Iran said Tuesday that at least three Pakistani citizens were among the assailants responsible for killing 27 members of the Islamic Revolutionary Guards Corps on a bus last week, including the driver of the explosives-laden car that rammed the vehicle. The February 13 bombing in the
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+
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+ southeast region along the Pakistan border was one of the deadliest attacks in years to strike Iran. Iran has often criticized Pakistan for harboring Sunni Muslim militants from the province, Sistan and Baluchistan. The accusation, reported by Iran's Tasnim news agency, was made by a commander of the Revolutionary Guards, Brig. Gen. Mohammad Pakpur, at a ceremony held Tuesday to honor victims of the attack. (New York Times — 2/19)
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+
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+ ISIS Maintains Online Activity despite Significant Territorial Losses - According to a report from Dublin City University, ISIS continued to maintain an active online presence despite significant territorial losses and a decrease in attacks in the West. ISIS also continued to rely on the use of cryptocurrency and the dark web for the relative anonymity they both provide. ISIS continued to regularly disseminate press releases, claims of responsibility for attacks, infographics, and audio/video messages. These releases were most accessible through the messaging app Telegram. Since its loss of Raqqa, Syria, ISIS has not published a non-Arabic language magazine—once a key feature of the group's online media strategy. The last issue of ISIS's Rumiyah Magazine appeared in September 2017. Other violent extremist groups like Boko Haram have mimicked ISIS's online strategy, posting the same type of propaganda and even used similar branding and templates in their online claims. (VOX POL— 2/11)
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+
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+ Amazon Drive is hosting Terrorist Content - Terrorist groups usually find ways to exploit the ever expanding services offered by major online platforms and tech companies, and Amazon Drive is no exception. Designed for storing and sharing photos, videos, PDFs and other forms of content, it has been adopted by the Islamic State, al-Qaeda and other organizations as a stable and reliable platform for disseminating their content. They upload it and then share the links to it with followers and sympathizers, primarily using the encrypted messaging app Telegram — terrorists' "app of choice." Amazon Drive, established in 2011and previously known as Amazon Cloud Drive, can store subscribers' photos, videos and other files for access from mobile devices, desktops or Amazon Fire devices. According to the Amazon website, "All photos, videos and other files you upload to Amazon Drive are securely and privately stored in your Files and your Amazon Photos library." While Amazon has guidelines for its many platforms, including specific bans on terrorism, "bigotry, hatred, or illegal discrimination " or the use of its services by anyone who is "the subject of U.S. sanctions or of sanctions consistent with U.S. law imposed by the governments of the country where you are using Amazon Services," it has not been proactive in removing terrorist content. Terrorist activity and content on Amazon Drive is the subject of a new report by my organization, the Middle East Media Research Institute and its Cyber & Jihad Lab documenting how ISIS and other groups like it have been using this free service. The examples in the report include Amazon Drive links to content such as videos by ISIS, audio messages by its leaders, and official newsletters and other content created by the group, its secondary media organizations and its supporters. (USA Today — 2/20)
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+
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+ # Global Terrorism
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+
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+ # Saudi Arabia
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+
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+ - The U.S. Department of State issued a Level 2 Travel Advisory for Saudi Arabia on Thursday due to "terrorism and the threat of missile and drone attacks on civilian targets" U.S. Department of State
135
+ - o The advisory says to exercise increased caution and warns against travel within 50 miles of the border with Yemen due to terrorism and armed conflict, areas where the U.S. government has limited ability to provide assistance
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+ - Rebel groups operating in Yemen have fired missiles and rockets into Saudi Arabia, specifically targeting populated areas and civilian infrastructure, including: the cities of Riyadh and Jeddah, Riyadh's international airport, Saudi Aramco facilities, and vessels in Red Sea shipping lanes
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+ - These groups are also in possession of unmanned aerial systems, or drones, which they have used to target similar areas and facilities
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+
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+ Sons of El Chapo Ovidio and Joaquin unsealed indictment for arrest and extradition preparation — Borderland Beat View article... and NY Times https://www.nytimes.com/2019/02/21/nyregion el-chapo-sons-indictment.html? action=click&module=Latest&pgtype=Homepagg
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+
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+ #### "El Chapo" might be getting a new trial after Vice News reported that at least six jurors ignored the judge's orders of
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+
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+ avoiding social media and any discussion of the case. The drug kingpin's attorneys said they're already planning on filing
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+
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+ a motion requesting the judge question the jury. (Deanna Paull
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+
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+ Mexican Meth Fuels an American Crisis - The opioid crisis grabs the headlines, but what about the meth crisis? Methamphetamine, produced by Mexican cartels and smuggled over the southwestern border, killed 10,333 Americans in 2017, more than in any previous year. Worse, preliminary statistics show an increase to more than 12,000 in the year ending last July. President Trump says there's a "crisis" at the border, and he's right—its result is the meth-overdose epidemic. (Wall Street Journal — 2/20)
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+
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+ #### Prosecutors Broke Law in Agreement Not to Prosecute Jeffrey Epstein, Judge Rules -
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+
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+ https://www.nytimes.com/2019/02/21/usheffrey-epstein-judge-prosecution-agreement.html? action=click&module=Latest&pgtype=Homepage
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+
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+ Yahoo News, "The Soviets wanted to infiltrate the Reagan camp. So, the CIA recruited a businessman to bait them" by Zach Dorfman: "Beginning in 1975, a big black limousine with diplomatic plates would pull up once a month to the noparking zone outside John Greenagel's office in the handsome Merchants Exchange Building in downtown San Francisco. A man would exit the car, paper bag in hand, and ascend the stairs to Greenagel's public relations firm. The man would hand Greenagel, then in his mid-30s, the paper bag, which always contained stale Cuban cigars and a bottle of Stolichnaya without a tax stamp. 'Compliments of Mr. Pavlov,' the man would say, and walk out. Yuri Pavlov was a diplomat based at the Soviet Consulate in San Francisco and an undercover KGB officer ... after the Soviet bag man left, Greenagel would call his CIA handler, who would pop over to his office; and they'd laugh and drink the Stoly, smoke the old Cubans and talk about Greenagel's deepening friendship with Pavlov, which was entirely manufactured. ... Greenagel was acting as an 'access agent' — providing the CIA with key insights about Pavlov's psychological and personality profile."
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+
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+ #### West Point CTC Sentinel: February 2019 issue:
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+
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+ A HOLLOW VICTORY OVER THE ISLAMIC STATE IN SYRIA? THE HIGH RISK OF JIHADI REVIVAL IN DEIR EZ-ZOR'S EUPHRATES RIVER VALLEY Hassan Hassan A VIEW FROM THE CI FOXHOLE: SHAUN GREENOUGH CASE STRATEGY AND MENTOR SUPERVISOR THE UNITY INITIATIVE Paul Cruickshank PROFIT-MINDED SUPPLIERS: CONVERGENCE OF IED FACILITATION AND WMD PROLIFERATION NETWORKS FOR NON-STATE ACTORS Stephen Hummel, F. John Burpo, and James Bonner THE ELN'S ATTACK ON THE NATIONAL POLICE ACADEMY IN BOGOTA AND ITS IMPLICATIONS Ross Dayton
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+
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+ MTA Daily:
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+
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+ Significant Dates in History February 22, 2005 Washington, D.C. Man Charged in Alleged Plot to Kill President Bush Brief Description: (NY Times) — A Virginia man has been charged with plotting with Middle East terrorists to assassinate President Bush, either by shooting him on the street or by detonating a car bomb, the Justice Department said today.
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+
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+ The department said that the suspect, Ahmed Omar Abu Ali, had conspired with terrorists in Saudi Arabia, with whom he lived there from September 2002 to June 2003, and that he had obtained a religious blessing from a co-conspirator to carry out the killing.
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+ Mr. Ali, 23, described in recent news reports as a Houston-born American citizen and the valedictorian of his high school class in suburban Virginia, appeared in federal district court in Alexandria, Va., today. He did not enter a plea, but scores of his supporters laughed when the charges were read.
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+
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+ Mr. Ali's attorney, Ashraf Nubani, told Magistrate Liam O'Grady that his client was tortured while in Saudi custody, before he was returned to the United States, The A.P. said. "He has the evidence on his back," the lawyer said. "He was whipped. He was handcuffed for days at a time."
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+
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+ Magistrate O'Grady assured Mr. Nubani that his client would not be mistreated in American custody.
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+
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+ A federal indictment, setting forth charges that could lead to decades of imprisonment upon conviction, described the defendant as eager to be a partner in terrorism with Al Qaeda.
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+
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+ "It was defendant Abu Ali's intent to become a planner of terrorist operations like Mohamed Atta and Khalid Sheikh Mohammed," the document says, referring to the man who piloted the first airliner that struck the World Trade Center on Sept. 11, 2001, and to one of the masterminds of the plot. (Mr. Mohammed was captured in Pakistan in March 2003.)
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+
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+ Mr. Ali was arrested by Saudi authorities in Medina on June 9, 2003, on suspicion of being associated with bombings in Riyadh four weeks earlier that killed more than 30 people, including 9 Americans.
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+
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+ A week after his arrest, the indictment says, a search of Mr. Ali's home in Falls Church turned up documents praising the Sept. 11 attacks, audio tapes in Arabic promoting the killing of Jews and a battle by Muslims against Christians and Jews and other incendiary writings.
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+
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+ The indictment says that Mr. Ali traveled between Virginia and Saudi Arabia between 2000 and 2002, and that from September 2002 on he received lodging from Al Qaeda members who taught him such skills as using hand grenades and forging documents.
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+
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+ At some time between September 2002 and June 2003 Mr. Ali tried to travel to Afghanistan through Iran to attack American soldiers, the indictment says, but he could not get the necessary travel documents.
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+
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+ The accusation that Mr. Ali plotted to kill President Bush was included in a count charging him with conspiracy to provide material support and resources to foreign terrorists. Between September 2002 and June 2003, the indictment says, Mr. Ali and another conspirator discussed two possibilities: that Mr. Ali would get close enough to the president "to shoot him on the street," or that he would detonate a car bomb to kill the president.
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+
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+ Traffic is routinely blocked off when a president travels in an armored limousine with an armed escort. It has been decades since presidents strolled along city streets, and they are heavily protected by Secret Service agents wherever they go. But John W. Hinckley Jr. proved that a close-range shooting is not impossible, when he wounded President Ronald Reagan on March 30, 1981.
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+
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+ The defendant's lawyer, Mr. Nubani, represented some of the 11 Muslim men in the Washington area and Pennsylvania who were accused in 2003 of conspiring with foreign terrorists and training for terrorist missions at firearms ranges in Northern Virginia.
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+
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+ The men insisted they were engaging in harmless paintball games, not mock military missions. But three defendants were convicted of conspiracy in a non-jury trial last March and sentenced to long prison terms.
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+
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+ While Mr. Ali was imprisoned in Saudi Arabia, his case became a cause cell bre among Washington-area Muslims, who complained that he should not be held so long without being charged with a crime. About three weeks ago, the State Department asked Saudi Arabia to either indict Mr. Ali or allow the Justice Department to return him to the United States. Until Mr. Ali's appearance in court today the United States government had not disclosed that he had in fact left Saudi Arabia.
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+
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+ The Washington Post reported in 2003 that Mr. Ali was valedictorian of his 1999 high school class at the Islamic Saudi Academy in Alexandria, where school officials described him as "an exceptional student," with special talent in mathematics and science.
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+
195
+ Bending to the wishes of his parents, Omar and Faten Abu Ali, Mr. Ali entered the University of Maryland in the fall of 1999 to study engineering on a scholarship, The Post reported. But he was unhappy and left the next year to further his Islamic studies, first in Fairfax County, Va., and later in Medina.
196
+
197
+ Rega rds,
198
+
199
+ Senior Intelligence Specialist U.S. Attorney's Office-SONY Terrorism & International Narcotics Unit One St. Andrew's Plaza New York, NY 10007
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00013696)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
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+ ---
14
+
15
+ | From: | (USAFLS)" |
16
+ |--------------------|---------------------------------------|
17
+ | To: | (USAFLS)" |
18
+ | | Subject: RE: Follow up |
19
+ | | Date: Thu, 18 Oct 2007 21:29:07 +0000 |
20
+ | Importance: Normal | |
21
+
22
+ My understanding was that Jay would not be attending the change of plea, so his availability shouldn't have dictated the guilty plea date. Since we have agreed to the date change, can you please confirm with Jay that this will not effect the date when Epstein begins serving his sentence? Thank you.
23
+
24
+ From: (USAFLS) Sent: Thu 10/18/2007 4:39 PM To: Jay Lefkowitz Cc: Acosta, Alex (USAFLS) Subject: RE: Follow up
25
+
26
+ The change of plea will take place on November 20. Agreed.
27
+
28
+ | -----Original Message--- |
29
+ |------------------------------------------|
30
+ | From: Jay Leflcowitz [mailto: |
31
+ | Sent: Thursday, October 18, 2007 4:35 PM |
32
+ | To: Acosta, Alex (USAFLS) |
33
+ | Cc:<br>(USAFLS) |
34
+ | Subject: Re: Follow up |
35
+
36
+ Alex - Thanks.
37
+
38
+ M, are we all set?
39
+
40
+ Jay
41
+
42
+ | -- Original Message ---- |
43
+ |---------------------------------|
44
+ | From: "Acosta, Alex (USAFLS)" [ |
45
+ | Sent: 10/18/2007 12:15 PM AST |
46
+ | To: Jay Lefkowitz |
47
+ | Cc: "II<br>(USAFLS)" |
48
+ | Subject: RE: Follow up |
49
+
50
+ | | | | | | | Can you see any issues with this? If not, please confirm with | |
51
+ |------|--|--|--|--|--|---------------------------------------------------------------|--|
52
+ | Jay. | | | | | | | |
53
+
54
+ ----Original Message--- From: Jay Leflcowitz [mailto: Sent: Thursday, October 18, 2007 10:12 AM To: Acosta, Alex (USAFLS) Subject: Follow up
55
+
56
+ Alex - I wanted to thank you for making the time for breakfast Friday. It was great to catch up.
57
+
58
+ Following up on our conversation about the date for Mr. Epstein's plea, where you said that you didn't want to dictate a schedule to the state, as we discussed I have a case where I represent an individual who is now the lead witness for the government, and openings are set for next week. Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's attorney's office and the court will be available to have him enter his plea on November 20. So we will plan to proceed on one that date. Please confirm that this is ok.
59
+
60
+ ### Thanks, Jay
61
+
62
+ 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 Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 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 postmaster©kirkland.com, and destroy this communication and all copies thereof, including all attachments.
63
+
64
+ The infommtion 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 Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 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 postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments.
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00014384)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
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+ ---
14
+
15
+
16
+
17
+ Subject: transcript Date: Fri, 26 Jun 2020 16:22:39 +0000 Attachments: 2019-07-19,_Transcript.pdf; 2019-06-19,_Transcript.pdf
18
+
19
+ Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00014683)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
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+ ---
14
+
15
+ | From: Christian Everdell | |
16
+ |---------------------------------------|--------------------------|
17
+ | To:<br>' | |
18
+ | Cc: | |
19
+ | | obbi C. Sternheim, Esq." |
20
+ | Laura Menninger | Jeff Pagliuca |
21
+ | Subject: [EXTERNAL] RE: Stip | |
22
+ | Date: Sun, 21 Nov 2021 04:20:07 +0000 | |
23
+ | Attachments: Stipulatio | Trial Testimony.PDF |
24
+
25
+ Attached is a clean version of the stip. The only thing I changed from the version you last saw is that we now label the stip Defendant's Trial Exhibit A.
26
+
27
+ You can email me the signed version and hand deliver it to me at the conference on Tuesday, whichever works best for you.
28
+
29
+ Thanks,
30
+
31
+ Chris
32
+
33
+ | From: | | |
34
+ |-------------------------------------------|-----------------------------|----------------------|
35
+ | Sent: Saturday, November 20, 2021 2:37 PM | | |
36
+ | To: Christian Everdell<br>C | | |
37
+ | Cc | | |
38
+ | | • Bobbi C. Sternheim, Esq.< | II>; Laura Menninger |
39
+ | ;Jeff Pagliuca | | |
40
+ | Subject: RE: Stip | | |
41
+
42
+ Hey Chris,
43
+
44
+ This works for us. If you send me a clean version, I'll sign and return it to you, or I can just sign it at the conference Tuesday.
45
+
46
+ Thanks,
47
+
48
+ | From: Christian Everdell < | | |
49
+ |-----------------------------------------|--------------------------|-------------------|
50
+ | Sent: Friday, November 19, 2021 9:04 PM | | |
51
+ | To: | | |
52
+ | Cc | | |
53
+ | | Bobbi C. Sternheim, Esq. | ; Laura Menninger |
54
+ | >; Jeff Pagliuca | | |
55
+ | Subject: [EXTERNAL] RE: Stip | | |
56
+ | | | |
57
+
58
+ Following-up on our conversation today, is the revised stipulation acceptable to the government?
59
+
60
+ | From: I | | | |
61
+ |------------------------------------------|------------------|------------------------------|-------------------|
62
+ | Sent: Tuesday, November 16, 2021 7:03 PM | | | |
63
+ | To: Christian Everdell < | | | |
64
+ | Cc: | | | |
65
+ | | | ; Bobbi C. Sternheim, Esq. < | ; Laura Menninger |
66
+ | | >; Jeff Pagliuca | | |
67
+
68
+ Subject: Stip
69
+
70
+ Hey Chris,
71
+
72
+ Following up on our conversation today regarding the stip, would you agree to have the sentence say that the document is a "true and accurate copy of the transcript of one witness's trial testimony, but not the full trial transcript, given on February 26 . . . ."? If so, we are fine with the stip — and, of course, happy to consider other language that makes the same point.
73
+
74
+ Thanks,
75
+
76
+ Assistant United States Attorney Southern District of New York
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00014714)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
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7
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+ ---
14
+
15
+
16
+
17
+ Those are the addresses I have for him. I would try Stacey, his lawyer. She is usually very responsive. Thanks for handling this
18
+
19
+ | On Nov 23, 2021, at 11:50 AM, | (USANYS) < | > wrote: |
20
+ |-------------------------------|------------|----------|
21
+ | | | |
22
+
23
+ Hi Public Corruption Chiefs,
24
+
25
+ FYI, since the Times article came out today about Epstein's incarceration and death, BOP has been receiving multiple new requests for the records released in the FOIA matter (ABC, CNN, MuckRack). BOP plans to respond to those requests quickly and release the same records.
26
+
27
+ One minor wrinkle: the FOIA specialist at BOP has tried to contact Mark Epstein a couple times regarding his communications from about a month ago. But so far he has not responded to her. She has asked if we have contact info for him. What I have is this phone number and these emails Mark Epstein and STACEY RICHMAN . I am going to confirm BOP has these, but please let me know if there is some other way to contact him.
28
+
29
+ Thanks,
30
+
31
+ Assistant United States Attorney
32
+
33
+ White Plains, NY 10601 Telephone:
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00016968)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
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6
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+ ---
14
+
15
+ | From: ' | (USANYS)" ctl | |
16
+ |---------|---------------|--|
17
+ | To: | (USANYS)" | |
18
+
19
+ Subject: RE: Letter regarding jail conditions and court appearance Date: Fri, 21 Aug 2020 18:39:31 +0000
20
+
21
+ ## Thanks
22
+
23
+ | From:<br>(USANYS)<br>Sent: Friday, August 21, 2020 2:39 PM<br>To:<br>(USANYS)<br>Subject: Re: Letter regarding jail conditions and court appearance |
24
+ |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
25
+ | Left a vm |
26
+ | Co-Chief, Narcotics Unit |
27
+ | On Aug 21, 2020, at 14:36,<br>> wrote:<br>(USANYS) < |
28
+ | Have you tried calling her? I'm in victim interviews, but can try calling her when I free up. If you don't hear back by<br>3pm, I think we should email again and add |
29
+ | From:<br>(USANYS)<br>Sent: Friday, August 21, 2020 2:36 PM<br>To:<br>(USANYS)<br>Subject: Re: Letter regarding jail conditions and court appearance |
30
+ | Not holding my breath on a response |
31
+ | Co-Chief, Narcotics Unit |
32
+ | On Aug 21, 2020, at 14:23,<br>(USANYS)<br>wrote: |
33
+ | Thanks for getting this going. |
34
+ | From:<br>(USANYS)<br>Sent: Friday, August 21, 2020 1:25 PM<br>To:<br>Cc:<br>(USANYS) |
35
+
36
+ Subject: FW: Letter regarding jail conditions and court appearance
37
+
38
+ — Can we please jump on a call this afternoon to discuss? As you can see, we have only until Monday to respond.
39
+
40
+ Co-Chief, Narcotics Unit
41
+
42
+ From: Karas NYSD Chambers Sent: Friday, August 21, 2020 1:22 PM To: Bruce Barket Cc: Aida Leisenring >; Michael Bachrach John Diaz <, >; I(USANYS) >; (USANYS) < >; (USANYS) (USANYS) >;
43
+
44
+ Subject: Re: Letter regarding jail conditions and court appearance
45
+
46
+ All,
47
+
48
+ Attached please find a memo endorsement from Judge Karas.
49
+
50
+ -Chambers of Judge Karas
51
+
52
+ | From: Bruce Barket | |
53
+ |--------------------------------------------------------------------|--|
54
+ | Sent: Thursday, August 20, 2020 6:24 PM | |
55
+ | To: Karas NYSD Chambers | |
56
+ | Subject: FW: Letter regarding jail conditions and court appearance | |
57
+
58
+ Good afternoon,
59
+
60
+ I sent this to but wanted to forward here as well. Can you confirm that the judge will see it?
61
+
62
+ Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530
63
+
64
+ www.barketepstein.com
65
+
66
+ 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
67
+
68
+ | From: Bruce Barket | |
69
+ |------------------------------------------|----------------------------------------------------|
70
+ | Sent: Thursday, August 20, 2020 12:50 PM | |
71
+ | To: | |
72
+ | Cc: Aida Leisenring | tonyricco<br>>; |
73
+ | | >; Michael Bachrach<br>; Kenneth J. Montgomery Esq |
74
+
75
+
76
+
77
+ Subject: Letter regarding jail conditions and court appearance
78
+
79
+ I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the MCC and the prosecution team as well as firewall counsel. Thank you.
80
+
81
+ Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530
82
+
83
+ www.barketepstein.com
84
+
85
+ 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
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00017074)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
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7
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+ ---
14
+
15
+ #### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
16
+
17
+ Virginia L. Giuffre,
18
+
19
+ Plaintiff,
20
+
21
+ v.
22
+
23
+ Case No.: 15-cv-07433-RWS
24
+
25
+ Ghislaine Maxwell,
26
+
27
+ Defendant.
28
+
29
+ ## INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S RESPONSE TO MAXWELL'S OBJECTIONS TO UNSEALING
30
+
31
+ Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Attorneys for Intervenors Julie Brown and Miami Herald Media Company
32
+
33
+ ## casQac,./g%261'43g-ceg'FenbegrrieRFA004lieif36643026'act6@f218f 10
34
+
35
+ Pursuant to this Court's Order and protocol for Unsealing Decided Motions, Intervenors Julie Brown and Miami Herald Media Co. ("Miami Herald") respectfully submit this response to Ms. Maxwell's Memorandum Brief in Support of Her Objections to Unsealing Sealed Materials (Dkt. 1057) ("the Objections")}
36
+
37
+ #### ARGUMENT
38
+
39
+ Ms. Maxwell's objections to the unsealing of Dkt. Entries 143, 164, 172, 199, and 230 (and related submissions) are entirely without merit, and these documents should be unsealed in their entirety. The objections mischaracterize the governing law, including the Second Circuit's ruling in Brown v. Maxwell, 929 F.3d 41 (2d. Cir. 2019); rely upon general "alleged countervailing interests" against disclosure that are not supported by the extensive body of case law addressing whether a judicial document may be sealed by the Court; and assert unsubstantiated, generalized, and speculative harms based on the alleged countervailing interests that are insufficient to outweigh the presumption of access to these judicial documents.
40
+
41
+ As set forth in detail below, there is no basis identified in the Objections for the Court to continue sealing Dkt. Entries 143, 164, 172, 199, and 230 (and related docket entries identified by Ms. Maxwell).
42
+
43
+ ## I. Ms. Maxwell Mischaracterizes Brown v. Maxwell.
44
+
45
+ Ms. Maxwell's filing selectively quotes from the Second Circuit's ruling in Brown v. Maxwell in an attempt to minimize the right of access that attaches to all judicial documents. Maxwell's repeated assertion that these documents are entitled to "a minimal presumption of access" is directly contradicted by the Second Circuit's conclusion that "the presumption of access to "materials submitted in connection with, and relevant to, discovery motions, motions in limine,
46
+
47
+ <sup>&#</sup>x27; Counsel for Intervenors has not seen these documents and submits this response based on the list of Decided Motions prepared by counsel for the Parties and Ms. Maxwell's Objections.
48
+
49
+ ## casgemgW6143§tiumeneekt-OrgefifilVo4fheifigf23028v4ef31th 10
50
+
51
+ and other non-dispositive motions" is "substantial." Brown v. Maxwell, 929 F.3d at 53 (2d. Cir. 2019).
52
+
53
+ It is also well-established that the party requesting that documents remain sealed bears the heavy burden of demonstrating that there are compelling competing factors that outweigh the presumption of access that attaches to each of the judicial documents at issue here. See Delta Air Lines, Inc. v. Bombardier, Inc., No. 1:20-CV-3025-GHW, 2020 WL 2614704, at *4 (S.D.N.Y. May 22, 2020); Bernsten v. O'Reilly, 307 F. Supp. 3d 161, 168 (S.D.N.Y. 2018); Lytle v. JPMorgan Chase, 810 F. Supp. 2d 616, 621-22 (S.D.N.Y. 2011). Those factors and the harm of disclosure must be identified with specificity. Lytle, 810 F. Supp. 2d at 621-22. None of Ms. Maxwell's Objections meets this heavy burden.
54
+
55
+ ## II. Ms. Maxwell's General Objections Are Without Merit.
56
+
57
+ Ms. Maxwell asserts objections based on alleged "countervailing interests" that are not recognized in the extensive body of case law addressing whether a judicial document may be sealed by the Court.
58
+
59
+ #### A. Reliance on a Protective Order By a Party or Non-Party
60
+
61
+ Ms. Maxwell argues that, if a party or non-party relies on a protective order or sealing order and provides information in discovery, the information must remain sealed. This is incorrect.
62
+
63
+ First, courts in this Circuit have routinely ordered unsealing of documents in cases with protective orders or confidentiality provisions. See, e.g., Gambale v. Deutsche Bank AG, 377 F.3d 133, 143 (2d Cir. 2004) (unsealing judicial document despite party's claim that it had settled claim to "avoid public disclosure at trial of the temporarily sealed documents"); Bernsten v. O'Reilly, 307 F. Supp. 3d 161 (S.D.N.Y. 2018) (unsealing documents submitted in support of motion to compel arbitration despite parties' agreement to file them under seal); Wells Fargo Bank, N.A. v. Wales LLC, 993 F.Supp.2d 409, 414 (S.D.N.Y. 2014) (holding the fact that the agreement
64
+
65
+ # casgamgfic26143 Piton enbigniefiFili00446g2teagcsthefat 10
66
+
67
+ "contains a confidentiality clause is not binding here, given the public's right of access to `judicial documents'").2 Courts do so, recognizing that "[t]he presumption of public access would become virtually meaningless if it could be overcome by the mutual interest of the parties..." Wolinsky v. Scholastic Inc., 900 F.Supp.2d 332, 334 (S.D.N.Y. 2012).
68
+
69
+ And second, here, the plain terms of the Protective Order do not support Maxwell's reliance argument. The Protective Order at issue specifically provided that it would "have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial." Dkt. 39-1, at 6. Therefore, the Protective Order contemplated certain information becoming public at trial, and any party's reliance on the Protective Order to prevent all sensitive information from becoming public is unfounded.
70
+
71
+ #### B. Prevention of the Abuse of Court Records and Files
72
+
73
+ Ms. Maxwell again mischaracterizes Brown v. Maxwell in stating that the Court should use sealing orders to prevent abuse of court records and files. In Brown v. Maxwell, the Second Circuit's instruction that courts should manage their dockets to ensure that court filings are not abused was made in the context of providing alternatives to sealing, which the Court noted are "often preferable" to sealing, including "explaining on the record that the statements appear to lack credibility" and striking from the record materials that are "redundant, immaterial, impertinent, or
74
+
75
+ <sup>2</sup> The case relied on by Maxwell is not to the contrary. Instead, Martindell v. Int'l Tel. & TeL Corp., 594 F.2d 291, 297 (2d Cir. 1979), addresses only whether reliance on a valid protective order may be a considered as a countervailing interest to disclosure. But here, the Second Circuit has already held that the protective order was not valid, as implemented. See Brown v. Maxwell, 929 F.3d 41 (2d. Cir. 2019). Therefore, Martindell is not applicable. Further, in later cases, the Second Circuit limited Martindell's ruling to cases involving documents that were not "judicial documents" subject to a presumption of access. See United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995).
76
+
77
+ ## casQam§feZot4AceguneoUgnieAFP95?044leiPtit§f2V28aftbef51M 10
78
+
79
+ scandalous." Brown, 929 F.3d at 49 n.28, 51-52. Ms. Maxwell's argument, here, turns that reasoning on its head.
80
+
81
+ Ms. Maxwell also provides no basis for her conclusory statements that the documents at issue were "abusively filed" court records and files.
82
+
83
+ #### C. Annoyance, Embarrassment, Oppression, and Undue Burden
84
+
85
+ Rule 26 allows protective orders to issue that allow the sealing of materials upon a showing of good cause that they are likely to cause annoyance, embarrassment, oppression, or undue burden. See Fed. R. Civ. P. 26; Brown, 929 F.3d at 51.
86
+
87
+ Simply stating that questions were "intrusive" or "embarrassing," however, is insufficient to meet the good cause standard of Rule 26, especially when the allegations at issue in the litigation concern the sexual abuse of young girls at the hands of the wealthy and powerful. Framing allegations of sexual abuse as "private" protects perpetrators at the expense of victims. The Miami Herald's coverage of Mr. Epstein's and his associates' alleged crimes has nothing to do with consensual sexual preferences and everything to do with the abuse of young girls, whether that crime was justly prosecuted or, instead, whether it was quietly dispensed with by the legal system to protect the reputations of well-connected adults. This is not information that could be reasonably characterized as exposing Ms. Maxwell to "annoyance" or "embarrassment" in a way that could support continued sealing under the good cause standard of Rule 26.
88
+
89
+ #### D. Rights of Suspects Under Criminal Investigation
90
+
91
+ Ms. Maxwell also claims that the mere existence of criminal investigations into Mr. Epstein and his associates' conduct warrants the sealing of materials because it is "unclear who are witnesses or targets of any investigation." Dkt. 1057, at 6. The cases she relies on stand for the general proposition that documents may sometimes be sealed to protect the integrity of criminal
92
+
93
+ ## casceamgQAR6nag'49kcnenbt•NeffFiWo*lieZt3&@f2V2f?an§ef61•9f 10
94
+
95
+ investigations. See United States v. Longueuil, 567 F.App'x 13, 16 (2d Cir. 2014) (finding it was not an abuse of discretion to allow continued sealing of discovery materials that were not judicial documents and that reflected sensitive information about cooperating witnesses and the government's investigative methods and techniques); Hardy v. Equitable Life Assurance Soc'y of United States, 697 F. App'x 723, 725 (2d Cir. 2017) (noting generally that protection of ongoing investigations and safety of witnesses may be countervailing interests).
96
+
97
+ However, Ms. Maxwell's generalized assertion that there are ongoing criminal investigations is wholly insufficient to warrant sealing. See United States v. Huntley, 943 F. Supp. 2d 383, 387 (E.D.N.Y. 2013) (denying request to seal in high-profile case and noting "Where will be no surprises to the potentially accused by the revelations of their names. Interference with ongoing investigations will be of almost no significance."). Further, it is completely unreasonable to allow Ms. Maxwell — a potential target of investigations — to assert this as a "countervailing interest" under the circumstances. This would lead to an absurd result in which court documents that could shed light on how Mr. Epstein's alleged crimes were kept secret for so long would be sealed to protect the perpetrators at the expense of victims and the public.
98
+
99
+ #### E. Improper Submission of Documents
100
+
101
+ Ms. Maxwell contends that documents submitted for a "non-merits purpose" should remain sealed or redacted if there is any interest in sealing or redaction. The case she cites, SEC v. TheStreetcom, 273 F.3d 222 (2d Cir. 2001), does not support this argument, nor are Intervenors aware of any case supporting this position. This position is directly in conflict with Brown v. Maxwell.
102
+
103
+ # casgamgric26140-9swienbt-ilnlefiFili004belt3gfrateafthef718f 10
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+
105
+ All of the documents at issue appear to have been submitted to the Court for purposes of an adjudication call upon the court to exercise its Article III powers and are judicial documents.' Ms. Maxwell's arguments to the contrary are wholly unsupported.
106
+
107
+ #### F. Untrustworthy, Unreliable, and Incorrect Information
108
+
109
+ Ms. Maxwell contends that material submitted to the court should not be unsealed because it is untrustworthy, unreliable, and incorrect. Again, Ms. Maxwell offers little support for those conclusions, relying on hearsay requirements found in the Federal Rules of Evidence.4 This argument conflates the admissibility requirements and sealing requirements. See Burton v. Zwicker & Assocs., No. CV 10-227-WOB-JGW, 2012 WL 12925759, at *1 (E.D. Ky. Sept. 24, 2012) ("[D]efendant cites no authority—nor has the Court independently located any—which supports the sealing of documents based upon alleged evidentiary problems."); Krause v. Rhodes, 535 F. Supp. 338, 354 (N.D. Ohio 1979), aff'd, 671 F.2d 212 (6th Cir. 1982) ("It is not a ground for a protective order as suggested by deponents' counsel, that the depositions contain hearsay answers or answers whose relevancy or competency might be suspect. The test of the propriety of a discovery deposition question or answer is not admissibility at trial, nor is admissibility at trial the test for entry of the depositions into the public domain.").
110
+
111
+ <sup>3</sup> Additionally, Ms. Maxwell's reference to issues that were briefed in various undecided motions in limine put those motions at issue. Therefore, under the Court's January 13, 2020 Order, these motions should also be unsealed. See Dkt. 1018.
112
+
113
+ <sup>4</sup> While Ms. Maxwell is correct that the Amodeo II court allowed some portions of a report containing hearsay to be sealed, it did so on the basis of specific assertions regarding the material, rather than the generalized assertions Ms. Maxwell offers.
114
+
115
+ ### III. The Specific Objections for Each of the Documents at Issue Also Do Not Justify Sealing.
116
+
117
+ Notwithstanding the 17-page brief submitted by Maxwell, she has failed to identify with the required specificity any countervailing interest sufficient to overcome the substantial presumption of access. Instead, Maxwell repeatedly cites generalized concerns and asks the Court to broadly continue to seal entire documents based on those generalized concerns. These alleged "countervailing interests" are wholly insufficient to support the continued sealing of documents in this case. See New York v. Actavis, PLC, No. 14 CIV. 7473, 2014 WL 5353774, at *3 (S.D.N.Y. Oct. 21, 2014) (citing Lugosch, 435 F.3d at 124) (decisions to seal must be supported by "specific, on-the-record findings that sealing is necessary to preserve higher values and only if the sealing order is narrowly tailored to achieve that aim").
118
+
119
+ #### A. Dkt. 143 and Related Submissions
120
+
121
+ Ms. Maxwell contends that these pleadings all concern Plaintiff's attempt to compel Ms. Maxwell to answer intrusive questions about her sex life. However, the related exhibits and submissions appear to be much broader and include deposition transcripts, a "Flight Log Summary Chart" and flight logs, and police reports.
122
+
123
+ None of the reasons Ms. Maxwell identifies warrants sealing these materials:
124
+
125
+ - J. Does 1 and 2 have not asserted any objections with regard to these materials, despite receiving notice and an opportunity to be heard.
126
+ - Sexual content alone is insufficient to justify continued sealing of Ms. Maxwell's deposition transcript. This case concerns allegations of sexual assault and trafficking of minors. There is no recognized privacy interest in allegations of sex trafficking. Any privacy interest Ms. Maxwell may have is substantially outweighed by the public interest
127
+
128
+ # gitga\$ij@f916410
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+
130
+ in disclosure, which will shed light on the abuse of young girls and women—and the system that allowed the abuse to continue.
131
+
132
+ - There is no support for Ms. Maxwell's claims that the third-party depositions are unreliable. She simply claims that her counsel did not cross-examine the witnesses under oath. But this is the hearsay standard, not the sealing standard. See Section II.F.
133
+ - Whether Ms. Maxwell is identified as a "suspect, a perpetrator, or participant" in the police reports is irrelevant to whether the police reports should be unsealed. Additionally, the police reports are public records under Florida's Sunshine Act. See Fla. AG Advisory Opinion AGO 80-96 ("...crime and arrest reports are not exempt from the inspection provisions of the Public Records Law..."). This lends additional support to the release of these documents in full here.
134
+
135
+ #### B. Dkt. 153-1, Exhibits 4, 5, 6 and 7
136
+
137
+ Ms. Maxwell claims that the third-party depositions are unreliable and inadmissible. Again, this is not the correct standard for sealing. See Section II.F.
138
+
139
+ #### C. Dkt. 172 and Related Submissions
140
+
141
+ Ms. Maxwell contends that this request was filed for an improper purpose because it could "have been a straightforward request by Plaintiff to exceed the presumptive 10 deposition limit set by the Court." Dkt. 1057, at 8. What this filing could have been is irrelevant to the Court's analysis: The relevant inquiry turns on what it was.
142
+
143
+ Ms. Maxwell does not dispute that the Plaintiff made this request to the Court seeking judicial action and that the Court acted. The remaining arguments that Ms. Maxwell makes, including that these are not judicial documents, are all addressed above and/or are non-sequiturs.
144
+
145
+ #### D. Dkt. 199 and Related Submissions
146
+
147
+ ## casafr.i et43gitsimmenbgirrieAFil4404thelPilskfigawafrcifolilf 10
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+
149
+ For the reasons set forth above, there is no basis for continuing to seal these documents. See Sections II.A, B, C, D.
150
+
151
+ Further, Ms. Maxwell's claim that the Court's ruling on these documents is premature because they name other third parties who have not yet received notice is inconsistent with the Court's note in Dkt. 1053. There, the Court said that it was "amenable to unsealing portions of documents mentioning non-parties rather than waiting to unseal the entirety of a given document until all non-parties have provided input." Intervenors ask that the Court follow the approach set forth in Dkt. 1053.
152
+
153
+ #### E. Dkt. 164 and Related Submissions
154
+
155
+ It appears the Court has received no objections regarding these submissions, and they should be released (as to J. Does 1 and 2).
156
+
157
+ #### F. Dkt. 230 and Related Submissions
158
+
159
+ It appears the Court has received no objections regarding these submissions, and they should be released (as to J. Does 1 and 2).
160
+
161
+ #### CONCLUSION
162
+
163
+ For all of the foregoing reasons, Intervenors respectfully request that this Court unseal in their entirety Dkt. entries 143, 164, 172, 199, and 230 and their related submissions (as they pertain to J. Does 1 and 2).
164
+
165
+ Dated: New York, New York Respectfully submitted, June 24, 2020
166
+
167
+ Is/ Christine N. Walz Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Attorneys for Intervenors Julie Brown and Miami Herald Media Company
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+ source: "DOJ Epstein Files, Data Set 8"
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+
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+
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+
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+ Subject: SecureMail Encryption Response Date: Mon, 09 Sep 2019 21:41:29 +0000
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+
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+ Your message was successfully encrypted.
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+
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+ Message Details:
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+
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+ | From: | | | | | |
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+ |-------|--|--|--|--|--|
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+ | To: | | | | | |
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+ | | | | | | |
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+
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+ Subject: Epstein File - Redactions
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+ ---
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+
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+ | From: | |
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+ |--------------------|---------------------------------------|
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+ | To: | |
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+ | Subject: pic | |
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+ | | Date: Mon, 08 Jul 2019 18:57:59 +0000 |
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+ | Importance: Normal | |
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+
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+ https://www.washingtonexaminer.cominews/comeys-daughter-named-to-epstein-prosecution-team
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+
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+ U.S. Attorney's Office for the Southern District of New York
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+
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+ Website: nvw.justice.gov/usao-sdny Facebook: https://war.v.facehook.com/usaosdm Follow us on Twitter: @SDNYnews
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+ source: "DOJ Epstein Files, Data Set 8"
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+
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+ ## UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
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+
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+ )
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+
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+ )
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+
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+ )
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+
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+ )
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+
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+ )
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+
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+ UNITED STATES OF AMERICA, )
28
+
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+ v. )
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+
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+ JEFFREY EPSTEIN
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+
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+ Defendant-Appellant )
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+
35
+ IT IS HEREBY STIPULATED by counsel for Jeffery Epstein, Defendant-Appellant, and the United States of America, Appellee, that, pursuant to Federal Rule of Appellate Procedure 42, this appeal shall be dismissed with prejudice. The parties understand and agree that, once dismissed, the appeal may not be reinstated.
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+
37
+ IT IS FURTHER STIPULATED that neither party shall be entitled to recover costs, expenses or fees from the other party.
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+
39
+ EXECUTED on August 2019.
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+
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+ /s/ Reid Weingarten Reid Weingarten Martin G. Weinberg Counsel to Defendant- Appellant Jeffrey Epstein
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+
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+ Ale ossmiller Counsel to Appellee United States of America
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+
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+ Plaintiff-Appellee, ) Appeal No. 19-2221-cr
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+
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+ Property of - Not For Media Use n010470
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+
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+ SDNY_GM_02753421 CONFIDENTIAL
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+
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+
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+
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+ EFTA00020250
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+ ---
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+
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+
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+
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+ ## Thank you both for the updates on this.
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+
19
+ | From: | |
20
+ |-------------------------------------------|--|
21
+ | Sent: Tuesday, February 23, 2021 12:38 PM | |
22
+ | . (NY) (FBI) <<br>To:<br>>;<br>(USANYS) | |
23
+ | >;<br>Cc:<br>) < | |
24
+ | Subject: Re: Maxwell Follow Up | |
25
+
26
+ Victoria Secret has recently switched their systems and only can access records dating back approximately 2 years.
27
+
28
+ | Detective<br>NYPD / FBI | |
29
+ |-------------------------------------------------------------------------------|--|
30
+ | Child Exploitation Human Trafficking Task Force<br>Office:<br>Cell: | |
31
+ | Fax:<br>From:<br>(NY) (FBI) <<br>><br>Sent: Monday, February 22, 2021 5:36 PM | |
32
+ | O;<br>To:<br>(USANYS) <<br>Cc:<br>Subject: RE: Maxwell Follow Up | |
33
+
34
+ At this point we haven't come across images of her. I'll keep you posted if we find otherwise. I'll circle back with you on the UK information.
35
+
36
+ Special Agent-FBI New York Field Office Child Exploitation/Human Trafficking Desk:
37
+
38
+ | From: | | | |
39
+ |-------|-----------------------------------------|--------------|--|
40
+ | | Sent: Monday, February 22, 2021 4:45 PM | | |
41
+ | To: | (USANYS) < | (NY) (FBI) < | |
42
+ | Cc: | | | |
43
+ | | | | |
44
+
45
+ Subject: [EXTERNAL EMAIL] - Re: Maxwell Follow Up
46
+
47
+
48
+
49
+ Fedex only retains records for 1 to 5 years depending on which method they use (ground...freight etc.).
50
+
51
+ We are still waiting on an answer from Victoria Secret. Will let you know as soon as I know.
52
+
53
+ | Detective | |
54
+ |-------------------------------------------------|--|
55
+ | NYPD / FBI | |
56
+ | Child Exploitation Human Trafficking Task Force | |
57
+ | Office: | |
58
+ | Cell: | |
59
+ | Fax: | |
60
+ | From:<br>(USANYS) | |
61
+ | Sent: Wednesday, February 17, 2021 11:34 AM | |
62
+ | (NY) (FBI) <<br>>;<br>To: | |
63
+ | Cc:<br>► | |
64
+ | Subject: Maxwell Follow Up | |
65
+ | | |
66
+ | ,<br>Hi M | |
67
+
68
+ **I hope you both are well. We wanted to follow up on a few additional items:**
69
+
70
+ - **Contact Victoria Secret and FedEx regarding retention of documents/how far back they keep materials**
71
+ - **Review of images for photos of**
72
+ - **Follow up with ALAI regarding UK travel records for Maxwell and Epstein**
73
+
74
+ **Happy to discuss if you have any questions.**
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+
76
+ **Thanks very much,**
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+
78
+ **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:**
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00021662)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ ---
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+
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+
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+
17
+ Thanks
18
+
19
+ Could I burden you, your team to break out of the intended first discovery production and to email to Reid and myself as soon as you are able the search warrants and affidavits and if they are easily available the returns, thanks, Marty
20
+
21
+ Martin G. Weinberg, Esq.
22
+
23
+
24
+
25
+ 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.
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+
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+
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+
29
+ Marty,
30
+
31
+ Thank you. Regarding discovery, we expect to make an initial production no later than Tuesday, and we expect it will be electronic discovery in native format -- that is, PDFs, JPEGs, etc. (in other words, not .tiff and load files as is sometimes the case).
32
+
33
+
34
+
35
+ Subject: US v Epstein
36
+
37
+ Cc: Martin Weinberg
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+
39
+ I am in receipt of your earlier email about preservation/production and will have a responsive letter to you no later than Monday morning (hopefully today or over weekend).
40
+
41
+ - can you advise us as to when we will receive the initial discovery subject to the now issued Protective Order and to the extent it is an electronic production, its format so that we can have Steptoe IT prepare for its receipt.
42
+
43
+ Thanks
44
+
45
+ Marty
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+
47
+ Martin G. Weinberg, Esq.
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+
49
+
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+
51
+ ----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.
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00023122)"
3
+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ ---
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+
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+ | From: | |
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+ |----------------------------------------------|--|
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+ | To:<br>' | |
18
+ | Cc: | |
19
+ | Subject: Travel for trial witness | |
20
+ | Date: Thu, 28 Oct 2021 18:40:56 +0000 | |
21
+ | Attachments: Fact Witness_Travel_Requesadocx | |
22
+ | | |
23
+
24
+ ### Hi
25
+
26
+ See attached. We haven't set a firm time for our meeting on November 14, so let me know if you want to discuss any logistics. Please let me know if you need any other information.
27
+
28
+ Thanks so much!!
29
+
30
+ Assistant United States Attorney United States Attorney's Office York
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+
32
+ New York, New York 10007
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00023930)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
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+ ---
14
+
15
+
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+
17
+ ### Hi=,
18
+
19
+ The FBI is aware of 1 or 2 victims who indicated they could not come on short notice, but does not recall which victims they were. There were other victims who decided not to come but cited other reasons, such as scheduling issues or aversion to press exposure. USAO is not aware of victims who raised scheduling issues. Of course, that doesn't mean they didn't have them, just that no one recalls anyone affirmatively raising them beyond the 1 or 2.
20
+
21
+ I also now know that, including victims whose known counsel we contacted as opposed to directly, the number who were told about the hearing is at least 50, as opposed to 39. I am still working on whether this number of 50 includes all of the identified Florida victims.
22
+
23
+ 17 is the total number of victims who either spoke or provided written submissions.
24
+
25
+ | From:<br>(ODAG) | |
26
+ |-----------------------------------------------|--|
27
+ | Sent: Wednesday, October 30, 2019 11:33 PM | |
28
+ | To:<br>(USANYS)<br>:' | |
29
+ | Cc:<br>(ODAG) dc | |
30
+ | Subject: RE: Epstein Victim Impact Statements | |
31
+
32
+ Thank you for this information. It is very helpful but we need a little more clarity. Can you confirm with the VW coordinators (USAO and FBI), prosecutors, and agents whether any victims complained about not being able to participate in the SDNY hearing? Can you also confirm whether the 39 contacted victims include all of the identified Florida victims? In addition to the 17 victims that spoke directly or through counsel, did any victims submit letters to the court in their absence?
33
+
34
+ Petitioner's counsel has alleged that DOJ, specifically SDNY, possesses information that some of the Epstein victims were unable to attend the SDNY hearing because they did not have sufficient notice to travel to NY. They believe this information is material to the subjects currently being litigated in the 11th Circuit. We need to pin this information down so it can be addressed in the government's response which is due on 10/31.
35
+
36
+ Again, we apologize for the fire drill but this issue was just raised within the last 48 hours. If you can provide this information before noon tomorrow it will be greatly appreciated.
37
+
38
+ From: (USANYS) Sent: Wednesday, October 30, 2019 4:34 PM To: • (ODAG)ca
39
+
40
+ ### Cc: (0DAG) <
41
+
42
+ Subject: RE: Epstein Victim Impact Statements
43
+
44
+ ### Hi
45
+
46
+ We reached out to at least 39 victims, either directly or through attorneys. The number could be higher, but that is the best as I can confirm today.
47
+
48
+ At least 17 victims attended the hearing because that is the number that spoke, either directly or through counsel. We believe there may have been additional who were present but did not speak, based on what their attorneys said.
49
+
50
+ We are not aware of victims who complained about not having an opportunity, but I'd be hesitant to make a categorical statement about that, as its possible I am missing something or the Bureau heard any complaints.
51
+
52
+ | From: | (ODAG) | |
53
+ |-------|-----------------------------------------------|--|
54
+ | | Sent: Wednesday, October 30, 2019 2:04 PM | |
55
+ | To: | (USANYS) | |
56
+ | Cc: | (ODAG) | |
57
+ | | Subject: RE: Epstein Victim Impact Statements | |
58
+
59
+ Thanks, . If you know of any victims that complained about not having an opportunity to speak in court or to submit a written letter, that information would be helpful as well.
60
+
61
+ ### Thanks
62
+
63
+ | From: | (USANYS) | |
64
+ |-------------------------------------------|-----------------------------------------------|--|
65
+ | Sent: Wednesday, October 30, 2019 1:25 PM | | |
66
+ | To: | (ODAG) | |
67
+ | Cc: | (ODAG) | |
68
+ | | Subject: RE: Epstein Victim Impact Statements | |
69
+
70
+ Hi - I will try to figure out the rough numbers for you. (1) and (2) should be doable, but I am not sure about (3).
71
+
72
+ | From: | (ODAG) | | | | |
73
+ |-------------------------------------------|--------------------------------------------|--|--|--|--|
74
+ | | Sent: Wednesday, October 30, 2019 12:53 PM | | | | |
75
+ | To: | (USANYS) | | | | |
76
+ | Cc: | (ODAG) | | | | |
77
+ | Subject: Epstein Victim Impact Statements | | | | | |
78
+ | Importance: High | | | | | |
79
+
80
+ The Petitioner in the Epstein CVRA case has filed an appeal to the 11th Circuit. One of their issues is the District Court's refusal to hold a hearing allowing the Epstein victims to "have their day in court." The Court's ruling is, in part, on the basis that a hearing held in SDNY satisfied this request. The Petitioner has alleged that not all of the Epstein victims who wanted to speak were able to do so at the New York hearing because they did not have sufficient notice and were unable to travel to NY.
81
+
82
+ Can your office provide us some details about the following: 1) how many victims were contacted about making a victim impact statement; 2) how many victims were able to travel and make an in-person victim impact statement; and 3) how many victims indicated they wanted to make a victim impact statement but were unable to do so given the notice/timing of the hearing?
83
+
84
+ Please provide as much of this information as possible today. I'm very sorry for the quick turnaround but the Department's response to the mandamus petition is due tomorrow.
85
+
86
+ I really appreciate your assistance.
87
+
88
+ National Coordinator for Child Exploitation Prevention & Interdiction Office of the De tut Attorney General Direct:
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00024760)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00024760"
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+ ocrPages: 0
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+ parseTier: "internal"
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+ engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
13
+ ---
14
+
15
+ # Curriculum Vitae DAWN M. HUGHES, PH.D. ABPP 2020
16
+
17
+ ## PROFESSIONAL ADDRESS
18
+
19
+
20
+
21
+ ## EDUCATION
22
+
23
+ | 1996 | Doctor of Philosophy in Clinical Psychology<br>Nova Southeastern University, Fort Lauderdale, FL |
24
+ |------|--------------------------------------------------------------------------------------------------|
25
+ | 1992 | Master of Science in Clinical Psychology<br>Nova Southeastern University, Fort Lauderdale, FL |
26
+ | 1988 | Bachelor of Arts in Psychology<br>Hamilton College, Clinton, NY |
27
+
28
+ #### PROFESSIONAL TRAINING
29
+
30
+ | 9/96 - 9/97 | Postdoctoral Fe/law - Research Associate in Pgchiaby<br>Well Cornell Medical College - New York Presbyterian Hospital<br>Anxiety and Traumatic Stress Program - Payne Whimey Clinic<br>New York, NY | |
31
+ |-------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
32
+ | 6/94 - 6/95 | Predoctoral Intern | |
33
+
34
+ Yale University School of Medicine - Department of Psychiatry Substance Abuse Treatment Unit and West Haven Mental Health Clinic New Haven, CT
35
+
36
+ #### CURRENT POSITIONS
37
+
38
+ | 1998 - Present | Independent Practice in Clinical and Forensic Pgcbology<br>Specialization in Traumatic Stress, Interpersonal Violence and<br>Anxiety Disorders |
39
+ |----------------|------------------------------------------------------------------------------------------------------------------------------------------------|
40
+ | 2010 - Present | amkal Assistant Professor of Psychology in Pgchiatg<br>Well Cornell Medical College - New York Presbyterian Hospital<br>New York, NY |
41
+
42
+ ## LICENSURE & BOARD CERTIFICATION
43
+
44
+ - 1997 New York Licensed Psychologist
45
+ - 2005 Board Certification in Forensic Psychology American Board of Professional Psychology
46
+ - 2015 Connecticut Licensed Psychologist
47
+ - 2015 North Carolina Licensed Psychologist
48
+
49
+ #### PROFESSIONAL AFFILIATIONS
50
+
51
+ American Psychological Association (APA) American Psychology and Law Society Division of Trauma Psychology Psychologists in Independent Practice Society for the Psychology of Women New York State Psychological Association (NYSPA) American Board of Professional Psychology (ABPP) Fellow — American Academy of Forensic Psychology (AAFP) International Society for Traumatic Stress Studies (ISTSS) Anxiety Disorders Association of America (ADAA) Women's Mental Health Consortium (WIVIEIC) International Society for the Study of Trauma and Dissociation (ISSTD)
52
+
53
+ #### PROFESSIONAL ACTIVITIES
54
+
55
+ American Psychological Association (APA)
56
+
57
+ Colin& of Representatives — Division of Trauma Psychology — 2018-present Member-at-Large— Division of Trauma Psychology — 2013-2014 Leadership Institute for Women in Pgcbology— 2011-2012 Awards Chair- Division of Trauma Psychology — 2010-2012 Convention Program Co-Chair— Division of Trauma Psychology 2008-2010
58
+
59
+ Women's Mental I lealth Consortium President 2009-2017
60
+
61
+ Membership Chair 2007-2009
62
+
63
+ International Society for Traumatic Stress Studies (ISTSS) Program Committee 2001
64
+
65
+ ### CLINICAL EXPERIENCE
66
+
67
+ | 1/97 - 9/97 | Clitned Diagnostic Interviewer<br>Rockefeller University-Laboratory of Human Neurogenetics, NY, NY |
68
+ |--------------|----------------------------------------------------------------------------------------------------|
69
+ | 9/92 - 8/93 | Porbology Extern<br>Veterans' Administration Outpatient Clinic, Oakland Park, FL |
70
+ | 9/91 - 8/92 | Porhology Extern<br>Family Violence Program, Nova University, Fort Lauderdale, FL |
71
+ | 9/90 - 6/91 | Porhology Trainee<br>Nova University Community Mental Health Center, Lauderhill, FL |
72
+ | 5/91 - 11/91 | Calif Clinician<br>Nova University Crisis Services, Fort Lauderdale, FL |
73
+ | 5/89 - 7/90 | Legal Services Assistant<br>The Legal Aid Society - Federal Defenders Services Unit, New York, NY |
74
+
75
+ | 5/88 - 5/89 | Substance Abuse Counselor<br>Narco Freedom, Bronx, NY |
76
+ |--------------|-------------------------------------------------------|
77
+ | 10/87 - 5/88 | Field Study Intern |
78
+
79
+ | Central New York Psychiatric Center, Marcy, NY |
80
+ |------------------------------------------------|
81
+
82
+ #### TEACHING EXPERIENCE
83
+
84
+ | 2002 - 2010 | Clinical Mune& of Pgcbology in Psychiatry<br>Well Cornell Medical College, New York, NY<br>New York Presbyterian Hospital - Payne Whitney Clinic |
85
+ |------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------|
86
+ | 1998 - 2000 | Consultant: Professional Development, Education and Training<br>Victim Services, New York, NY |
87
+ | 9/92 - 12/92<br>9/93 - 12/93 | Teaching Assistant<br>Nova Southeastern University, Fort Lauderdale, FL<br>Courses:<br>Advanced Research Design and Intermediate Statistics |
88
+
89
+ ## RESEARCH EXPERIENCE
90
+
91
+ | 5/92 - 5/94 | Research Coordinator<br>Sexual Abuse Survivors Program |
92
+ |-------------|---------------------------------------------------------------------|
93
+ | | Nova University Community Mental Health Center, Fort Lauderdale, FL |
94
+ | 9/91 - 5/94 | Research and Statistical Consultant |
95
+ | | Nova University - Fort Lauderdale, FL |
96
+
97
+ #### PUBLICATIONS
98
+
99
+ Tardiff K. and Hughes, D.M. (2011). Structured and clinical assessment of risk of violence. In Drogin et al. (Eds.) Handbook of Forensic Assessment Prychiatric and Pychokical Pet-glee-fives, John Wiley & Sons, Inc., New Jersey
100
+
101
+ Hughes, D.M. & Cloitre, M. (1999). Rape and sexual assault among adult women. In K. Tardiff (Ed.). Medical Management of the Violent Patient, Marcel Dekker, Inc., New York
102
+
103
+ Gold, S.N., Hughes, D.M. & Swingle, J. (1999). Degrees of memory of childhood sexual abuse among women survivors in therapy. JoarialofFamily Violence, 14, 35-46.
104
+
105
+ Gold, S.N., Elhai, J., Lucenko, B.A., Swingle, J.M., & Hughes, D.M. (1998). Abuse characteristics among childhood sexual abuse survivors in therapy: A gender comparison. Child Abase and Neglect, 22, 1005-1012.
106
+
107
+ Hughes, D.M. (1996). Memory for childhood sexual abuse: Prevalence and relationship to abuse characteristics and psychological effects. Doctoral dissertation.
108
+
109
+ Gold, S.N., Hughes, D.M. & Swingle, J. (1996). Characteristics of childhood sexual abuse among female survivors in therapy. Child Abuse and Neglect, 20, 323-335.
110
+
111
+ Gold, S.N., Hughes, D.M. & l-Iohnecker, L. (1994). Degrees of repression of sexual abuse memories. American Pgcbologist, 49, 441-442.
112
+
113
+ ## PROFESSIONAL PRESENTATIONS
114
+
115
+ Hughes, D.M. and Rocchio, L.M. (August 2014). Essentials of Forensic Assessment of Trauma in Criminal and Civil Mailers. Presentation at the 122'd Annual Convention of the American Psychological Association, Washington, D.C.
116
+
117
+ Hughes, D.M. (November 2013). It Matters: The Developmental Liftman of the Trauma Therapist. Symposium presentation at the 30th Annual Meeting of the International Society for the Study of Trauma and Dissociation, Baltimore, MD
118
+
119
+ Hughes, D.M. (November 2011). Conceptualization of Complex Trauma and PTSD in Forensic Matters. Panel presentation at the 27th Annual Meeting of the International Society of Traumatic Stress Studies, Baltimore, MD
120
+
121
+ Hughes, D.M. (August 2011). Assessment of Complex "Trauma in a Forensic Setting. Presentation at the 119th Annual Convention of the American Psychological Association, Washington, D.C.
122
+
123
+ Hughes, D.M. (June 2011). What Emery Pgcbologist Needs to Know About Trauma. Workshop presentation at the New York State Psychological Association Annual Conference, New York, NY
124
+
125
+ Hughes, D.M. (March 2011). Vicarious Traumatization in Forensic Practice: Does It Matter? Presentation at the American Psychology and Law Annual Conference, Miami, FL
126
+
127
+ Hughes, D.M. and Rocchio, L.M. (November 2010). Forensic Assessment of Psychological Trauma and MD. Workshop presented at the 26th Annual Meeting of the International Society of Traumatic Stress Studies, Montreal, Canada
128
+
129
+ Hughes, D.M. (August 2010). Ethical Dilemmas and Professional Considerations for Working with the Adult Survivor of Sexual Abuse: Forensic Pgchology. Presentation at the 118th Annual Convention of the American Psychological Association, San Diego, CA
130
+
131
+ Hughes, D.M., Courtois, C., Walker, LE., and Vasquez, M. (August 2009). Trauma treatment in independent practice: Principles and resources. Workshop presented at the 117th Annual Convention of the American Psychological Association, Toronto, Canada
132
+
133
+ Hughes, D.M. (August 2008). Difficulties and dilemmas when dissociation is present in forensic cases. Presentation at the 116th Annual Convention of the American Psychological Association, Boston, MA
134
+
135
+ Hughes, D.M. (November 2007). Forensic issues in the assessment of trauma. International Society for Trauma and Dissociation 24i° Annual Conference, Philadelphia, PA
136
+
137
+ Hughes, D.M. (November 2000). Multi-method approach to assessment in forensic evaluations. In A. Pratt (Chair) Forensic assessment and testimoty: Psychological trauma. A workshop presentation at the 16th Annual Meeting of the International Society for Traumatic Stress Studies, San Antonio, TX.
138
+
139
+ Hughes, D.M. (August 1999). 'Training in interpersonal violence: The next generation. Presentation at the American Psychological Association Annual Convention, Boston, MA.
140
+
141
+ Gold, S.N., Hughes, D.M. & Swingle, J. (November 2000). Memory for chiklhood sexual abuse: A matter of semantics. Panel presentation at thel6" Annual Meeting of the International Society for Traumatic Stress Studies, San Antonio, TX.
142
+
143
+ Hughes, D.M. & Gold, S.N. (November 1997). Memory for childhood sexual abuse and adult Dimptomaialogy. Poster session presented at the 13th Annual Meeting of the International Society for Traumatic Stress Studies, Montreal, Canada.
144
+
145
+ Hughes, D.M., Cloitre, M., Hand, R., Klein, C., Henvitz, J., Bleiberg, K. & Pessier, J. (November 1997). Role functioning impairment in CM-related PTSD. In D.M. Hughes (Chair), Role functioning impairment among women with childhood sexual abuse related PTSD. \$ymposium presentation at the 13th Annual Meeting of the International Society for Traumatic Stress Studies, Montreal, Canada.
146
+
147
+ Cloitre, M., Hughes, D.M. & Hand, R. (November 1997). A two-phase treatment for CSA-related PTSD: Rationale and preliminary results. In D.M. Hughes (Chair), Role functioning impairment among women with chihibood sexual abuse related PTSD. Symposium presentation at the 13th Annual Meeting of the International Society for Traumatic Stress Studies, Montreal, Canada.
148
+
149
+ Klein, C., Hughes, D.M. & Cloitre, M. Etbnocoural considerations in the assessment of YEW in survivors of sexual assault. (November 1997). Poster presentation at the Annual Meeting of the Association for the Advancement of Behavioral Therapy, Miami, FL.
150
+
151
+ Gold, S.N., Hughes, D.M. & Swingle, J. (July 1995). Degrees of memory of childhood sexual abuse among female survivors in therapy. Paper presented at the 4th International Family Violence Research Conference, Durham, NH.
152
+
153
+ Stear, C.A., Gold, S.N., & Hughes, D.M. (November 1994). Pam* of origin atmosphere ofsexual abuse survivors, distressed, and non-clinical families. Paper presented at the Illinois Psychological Association Annual Convention, Chicago, IL.
154
+
155
+ Gold, S.N., Williamson, C. & Hughes, D.M. (March 1994). Male sexual abuse survivors: Integrating empirical and clinical findings Paper presented at the Mid-Winter Convention of APA Divisions 29, 42, & 43.
156
+
157
+ Hughes, D.M., Branson, J., Galper, L., Gelpi, H., Rubenstein, F & Dutton, M.A. (June 1992). 'Training in the context of relationships: A model for the fami/y violence clinician. Paper presented at the First World Congress of the International Society for Traumatic Stress Studies, Amsterdam, The Netherlands.
158
+
159
+ #### INVITED ADDRESSES
160
+
161
+ Hughes, D.M. (September 17, 2019). Mental Health Issues width 'Workplace. In CLE program, The Interplay of Mental Health Disabilities and Workplace Accommodations. New York City Bar Association, New York, NY
162
+
163
+ Hughes, D.M. (April 3, 2019). Pgchological Issues in the Workplace 2019. Practicing Law Institute, New York, NY
164
+
165
+ Hughes D.M. (June 8, 2018). -Trauma and the Courtroom. Alumni College Speaker. Hamilton College, Clinton, NY
166
+
167
+ Hughes, D.M. (February 2, 2018). Domestic Violence 2018: Survivors as Defendants, Respondents, and Parole or Ckmeng Applicants. Practicing Law Institute, New York, NY
168
+
169
+ Hughes, D.M., & Rocchio, L.M. (August 6, 2016). Forensic work with trauma populations. APA Division 56 — Trauma Psychology suite presentation at the American Psychological Association Annual Convention. Denver, CO
170
+
171
+ Hughes, D.M., Courtois, C., & Brown, L. (August 5, 2016). Establishing a clinical prattle in trauma pgcholog. APA Division 56 — Trauma Psychology suite presentation at the American Psychological Association Annual Convention. Denver, CO
172
+
173
+ Hughes, D.M. (September 16, 2015 and October 7, 2015). Interpersonal Violence, Trauma, and the Courtroom in Understanding the Ties that Bind. Judicial Responses to Domestic and Sexual Violence. Judicial Training -New York Unified Court System - Domestic Violence Task Force. White Plains and Rochester, New York.
174
+
175
+ Dutton, M.A. and Hughes, D.M. (April 13, 2015). Expert IG'itneir Testimoty in Cases Involving Domestic Violence. Webinar conducted for the National Clearinghouse for the Defense of Battered Women.
176
+
177
+ Hughes, D.M. (September 2012). The Relationship Matters: IVIaximiting Success. Presentation to attorneys at Outten and Golden, LLP. New York, NY
178
+
179
+ Hughes, D.M. (June and August 2012). Promoting Health) Relationships: Living Without Violence and Abuse. Professional training presented to the United States Army National Guard. Fort Hamilton, NY
180
+
181
+ Hughes, D.M. (July 2011). Remaining Civil with the Uncivil. College of Labor and Employment Layers. EEOC. New York, NY
182
+
183
+ Hughes, D.M. (March 2011). The Victim of Interpersonal Violence and the Courtroom. Judicial Commission on Women in the Courts invited Continuing Legal Education seminar. Brooklyn, NY
184
+
185
+ Hughes, D.M. (November 2010). The Use tprPgchological Experts in Cases of Domestic Violence. Invited Continuing Legal Education seminar presented at the Kings County Criminal Bar Association, Brooklyn, NY
186
+
187
+ Hughes, D.M. (July 2010). Ethics and Risk Management in the Practice of Pgchotherapy. Invited presentation at the Women's Mental Health Consortium Quarterly Meeting, New York, NY
188
+
189
+ Hughes, D.M. (January 21 and 22, 2010). Understanding Domestic Violence. Professional training in Advocating for Children in Cases of Domestic Violence by the New York Appellate Divisions and the New York State Office of Court Administration. New York City and White Plains.
190
+
191
+ Hughes, D.M. (2009). The victim of interpersonal violence and the courtroom: Strategies for understanding. Manhattan Integrated Domestic Violence Courts Continuing Legal Education Seminar (February 2009); Appellate Division Fundamental Training Series (May 2009 and January 2010); Queens County Family Court Continuing Legal Education Seminar (June 2009).
192
+
193
+ Hughes, D.M. (March 2008). Collision course of children's wishes, best interests, and domestic violence. Invited presentation and the Twelfth Annual Conference on Domestic Violence. Fordham Law School, New York, NY
194
+
195
+ Hughes, D.M. (March 2007). The inconvenient truths of domestic violence. Invited address at the Eleventh Annual Conference on Domestic Violence. Fordham Law School, New York, NY
196
+
197
+ Hughes, D.M. (June 2006). Issues and dilemmas in interpersonal violence. Invited presentation at STEPS to End Family Violence. New York, NY.
198
+
199
+ Hughes, D.M. (December 2001). Relevance of domestic violence in the courtroom: Expert testimony in a duress case. Chairperson of a mock trial continuing education seminar at the 17th Annual Meeting of the International Society of Traumatic Stress Studies, New Orleans, LA.
200
+
201
+ Hughes, D.M. (September 2001). Pathological assessment in the aftermath Vibe World Trade Center disaster. Emergency meeting of the New York Chapter of the International Society of Traumatic Stress Studies. New York, NY.
202
+
203
+ Hughes, D.M. (April 2001). Moving beyond domestic violence 101: Challenges and solutions. Invited presentation in J. Pearl and S. Herman (Chairs), Violence and the Fam*: Current legal and mental health perspectives. Association of the Bar of the City of New York, New York, NY.
204
+
205
+ Hughes, D.M. (June 2000). Psychological testing in forensic evaluations. Invited presentation in symposium, M. Dowd (Chair) Pathological evidence in pleas negotiations and sentencing. Association of the Bar of the City of New York, New York, NY.
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00025402)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
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+ ---
14
+
15
+ 90A-NY-3151227 Serial 32
16
+
17
+ FD-I087 (Rev. 5-8-I0)
18
+
19
+ UNCLASSIFIED
20
+
21
+ ## FEDERAL BUREAU OF INVESTIGATION
22
+
23
+ Collected Item Log
24
+
25
+ Event Title: (U) Submission of CART Derivative Date: 08/16/2019 Evidence NYC027705
26
+
27
+ Approved By: SSA
28
+
29
+ Drafted By:
30
+
31
+ Case ID #: 90A-NY-3151227 (U) UNSUB(S);
32
+
33
+ JEFFREY EPSTEIN - VICTIM; DEATH INVESTIGATION
34
+
35
+ Collected From: (U) CART-NY
36
+
37
+ Receipt Given?: No
38
+
39
+ Holding Office: NEW YORK
40
+
41
+ ## Details:
42
+
43
+ Submission of CART Derivative Evidence NYC027705: One (1) Seagate Desktop 1TB hard drive, model ST1000DM003, S/N Z4YDHX5M, containing the Clone Copy of 1B6 hard drive (Seagate Barracuda 500GB HDD, ST3500320NS, S/N 9OM8EC75), collected via Tableau TD-3 -B S/N 01D3B07E-1331. Request ID 112048. Derivative Copy.
44
+
45
+ | Item Type | Description |
46
+ |------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
47
+ | 1B Digital | (U) NYC027705: One (1) Seagate Desktop 1TB hard drive,<br>model ST1000DM003, S/N Z4YDHX5M, containing the Clone<br>Copy of 1B6 hard drive (Seagate Barracuda 500GB HDD,<br>ST3500320NS, S/N 9QM8EC75), collected via Tableau TD-3 |
48
+ | | -B S/N 01D3B07E-1331. Request ID 112048. Derivative<br>Copy. |
49
+ | | Collected On: 08/12/2019 07:00 PM EDT |
50
+ | | Seizing Individual: |
51
+ | | Collected By: |
52
+ | | Device Type:<br>Hard Drive |
53
+ | | Designation:<br>Derivative |
54
+
55
+ ## UNCLASSIFIED
56
+
57
+ This document contains neither recommendations nor conclusions of the FBI. Ins the property of the FBI and is loaned to your agency; it and its contents arc not to be distributed outside your agency.
58
+
59
+ ## UNCLASSIFIED
60
+
61
+ Title: (U) Submission of CART Derivative Evidence NYCO27705 Re: 90A-NY-3151227, 08/16/2019
62
+
63
+ Number of Devices Collected: 1
64
+
65
+
66
+
67
+ UNCLASSIFIED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00026569)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ ---
14
+
15
+ ### U.S. Department of Justice
16
+
17
+ United States Attorney Southern District of New York
18
+
19
+ 86 Chambers Street New York. New York 10007
20
+
21
+ June 5, 2020
22
+
23
+ By Electronic Mail
24
+
25
+ Robert Glassman, Esq. Panish Shea & Boyle LLP 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025
26
+
27
+ ### Re: Request for Information Relating to Jeffrey Epstein
28
+
29
+ Dear Mr. Glassman:
30
+
31
+ I am the Assistant U.S. Attorney ("AUSA") who will be handling the request you discussed with AUSA for certain information relating to Jeffrey Epstein. Because your request seeks information from Department of Justice (the "Department") employees acquired during and as part of their performance of their official duties, your request is governed by certain Department regulations—commonly referred to as Touhy regulations which, inter alia, prohibit any Department employee from disclosing such information "without prior approval of the proper Department official in accordance with §§ 16.24 and 16.25 of this part." 28 C.F.R. § 16.22(a); see also United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southern District of New York. The Touhy regulations provide a set of procedures for the United States Attorney to follow when considering such requests. See 28 C.F.R. §§ 16.22(b), 16.24.
32
+
33
+ A party seeking to obtain records or employee testimony from the Department must first submit a written demand. See 28 C.F.R. § 16.22. To assist the United States Attorney in evaluating your request, we ask that this demand provide a detailed statement of the information sought; 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. See id. § 16.22(d).
34
+
35
+ The U.S. Attorney will reach a determination regarding your request in light of the considerations codified at 28 C.F.R. §§ 16.24, 16.25, and 16.26. Such considerations include, inter alia, "[w]hether such disclosure is appropriate under the rules of procedure governing the case or matter in which the demand arose," 28 C.F.R. § 16.26(a)(1), and "[w]hether disclosure is appropriate under the relevant substantive law concerning privilege," including law enforcement privilege. 28 C.F.R. § 16.26(a)(2). Disclosure will not be made when, inter alia, "[d]isclosure would violate a statute ... or a rule of procedure, such as the grand jury secrecy rule," 28 U.S.C. § 16.26(b)(1), "[d]isclosure would reveal a confidential source or informant," 28 U.S.C. § 16.26(b)(4), or "[d]isclosure would reveal investigative records compiled for law enforcement purposes, and would interfere with enforcement proceedings or disclose investigative techniques," 28 U.S.C. § 16.26(b)(5). Applying these considerations, the Department will make appropriate disclosures when warranted. See 28 C.F.R. § 16.26(c).
36
+
37
+
38
+
39
+ My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. If you choose to submit a written request, please send it directly to me. We will act upon an application made pursuant to the Department's regulations.
40
+
41
+ Please contact me once you have had a chance to review this letter if you would like to discuss the issues herein further.
42
+
43
+ Sincerely,
44
+
45
+ GEOFFREY S. BERMAN United States Attorney for the Southern District of New York
46
+
47
+ | By: | | | |
48
+ |-----|----------------------------------|--|--|
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+ | | Assistant United States Attorney | | |
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+ | | | | |
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+ | | | | |
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+ | | | | |
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+ Date: Thu, 11 Jul 2019 01:17:26 +0000 Attachments: HOTLINE_TRACICER_9PM_7.10.2019.xlsx
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+
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+ FBI New York
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+ Assistant United States Attorney United States Attorney's Office Southern District of New York Tel:
18
+
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+ Fax:
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+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00027307)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ ---
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+
15
+ | UNITED STATES DISTRICT COURT<br>SOUTHERN DISTRICT OF NEW YORK | |
16
+ |---------------------------------------------------------------|-----------------|
17
+ | | x |
18
+ | UNITED STATES OF AMERICA | |
19
+ | | 19 Cr. 830 (AT) |
20
+ | TOVA NOEL and MICHAEL THOMAS, | : |
21
+ | Defendants. | |
22
+ | | x |
23
+
24
+ # MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL
25
+
26
+ GEOFFREY S. BERMAN United States Attorney Southern District of New York
27
+
28
+
29
+
30
+ Assistant United States Attorneys - Of Counsel -
31
+
32
+ # TABLE OF CONTENTS
33
+
34
+ | | | PRELIMINARY STATEMENT<br>1 |
35
+ |------------|----|---------------------------------------------------------------------------------------------------------------------------------------------|
36
+ | | | STATEMENT OF FACTS<br>2 |
37
+ | I. | | The Indictment<br>2 |
38
+ | II. | | Pretrial Discovery and the Defendant's Request for Additional Materials<br>3 |
39
+ | | A. | The Government's Discovery Production<br>3 |
40
+ | | B. | 4<br>Defense Requests for Additional Discovery Materials |
41
+ | ARGUMENT | | 7 |
42
+ | I. | | 7<br>Applicable Law |
43
+ | | A. | Brady & Giglio<br>7 |
44
+ | | B. | Rule 16<br>8 |
45
+ | II. | | 8<br>Thomas is Not Entitled to Additional Materials |
46
+ | | A. | 8<br>The Government Has Satisfied its Discovery and Disclosure Obligations |
47
+ | | B. | The Requested Records Are Not "Material" to Preparing a Defense and Are<br>Sought for the Impermissible Purpose of Jury Nullification<br>10 |
48
+ | | | I.Applicable Law<br>10 |
49
+ | | | 2.Discussion<br>12 |
50
+ | | C. | The Government is Not Required to Collect Materials From Agencies Who<br>Were Not Part of the Prosecution Team<br>15 |
51
+ | | | I.Applicable Law<br>16 |
52
+ | | | 19<br>2.Discussion |
53
+ | | D. | Any Draft Inspector General Report is Not Subject to Disclosure<br>21 |
54
+ | | E. | Thomas Has Not Carried His Burden With Respect to Discovery of Material in<br>Support of a Selective Prosecution Claim<br>24 |
55
+ | | | I.Applicable Law<br>24 |
56
+ | | | 2.Discussion<br>26 |
57
+ | CONCLUSION | | 29 |
58
+
59
+ # TABLE OF AUTHORITIES
60
+
61
+ ### Cases
62
+
63
+ | Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010)<br>27 | |
64
+ |-------------------------------------------------------------------------------------------------------|---|
65
+ | Brady v. Maryland, 373 U.S. 83 (1963)<br>passim | |
66
+ | Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447<br>(S.D.N.Y. 2018)<br>27 | |
67
+ | Dept of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. 1 (2001)<br>26, 27 | |
68
+ | Giglio v. United States, 405 U.S. 150 (1972)<br>passim | |
69
+ | In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997)<br>26 | |
70
+ | In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008)<br>15 | |
71
+ | Kyles v. Whitley, 514 U.S. 419 (1995)<br>19 | |
72
+ | N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975)<br>26 | |
73
+ | Nat'l Res. Del Council v. United States Ening. Prot. Agency, 954 F.3d 150 (2d Cir.<br>2020)<br>26 | |
74
+ | Standefer v. United States, 447 U.S. 10 (1980)<br>13 | |
75
+ | United States v. Alameh, 341 F.3d 167 (2d Cir. 2003)<br>29, 30, 31 | |
76
+ | United States v. Armstrong, 517 U.S. 456, (1996)<br>passim | |
77
+ | United States v. Avellino, 136 F.3d 249 (2d Cir. 1998)<br>19, 25 | |
78
+ | United States v. Bagley, 473 U.S. 667 (1985) | 7 |
79
+ | United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015)<br>19 | |
80
+ | United States v. Bass, 536 U.S. 862 (2002)<br>30, 33 | |
81
+ | United States v. Berrios, 501 F.2d 1207 (2d Cir. 1974)<br>30, 31 | |
82
+ | United States v. Blaszczak, 308 F. Supp. 3d 736 (S.D.N.Y. 2018)<br>20 | |
83
+ | United States v. Bryan, 868 F.2d 1032 (9th Cir. 1989)<br>24 | |
84
+ | United States v. Carr, 424 F.3d 213 (2d Cir. 2005)<br>12 | |
85
+ | United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019)<br>20 | |
86
+
87
+ # Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 4 of 34
88
+
89
+ | United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) | 7, 8 |
90
+ |--------------------------------------------------------------------------------------------------------|------------|
91
+ | United States v. Defritas, No. 07 Cr. 543 (DLI), 2011 WL 317964, at *10 (E.D.N.Y.<br>Jan. 31, 2011) | 12, 17 |
92
+ | United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y.<br>May 12, 2015) | 16 |
93
+ | United States v. Edwards, 101 F.3d 17 (2d Cir. 1996) | 13 |
94
+ | United States v. Fares, 978 F.2d 52 (2d Cir. 1992) | 30, 31, 33 |
95
+ | United States v. Fernandez, 231 F.3d 1240 (9th Cir. 2000) | 26 |
96
+ | United States v. Finnerty, 411 F. Supp. 2d 428 (S.D.N.Y. 2006) | 20 |
97
+ | United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y.<br>July 7, 1999) | 16 |
98
+ | United States v. Frank, 8 F. Supp. 2d 253 (S.D.N.Y. 1998) | 26 |
99
+ | United States v. George, 786 F. Supp. 56 (D.D.C. 1992) | 15 |
100
+ | United States v. Ghailani, 687 F. Supp. 2d 365 (S.D.N.Y. 2010) | 21 |
101
+ | United States v. Gibbons, 602 F.2d 1044 (2d Cir. 1979) | 16 |
102
+ | United States v. Gonzalez, No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5<br>(S.D.N.Y. Apr. 9, 2020) | 10 |
103
+ | United States v. LeRoy, 687 F.2d 610 (2d Cir. 1982) | 7 |
104
+ | United States v. Levin, No. 15 Cr. 101 (KBF), 2016 WL 2990831, at *12 (S.D.N.Y.<br>Jan. 25, 2016) | 13, 16 |
105
+ | United States v. Lewis, 35 F.3d 148 (4th Cir. 1994) | 28 |
106
+ | United States v. Lewis, 517 F.3d 20 (1st Cir. 2008) | 32 |
107
+ | United States v. Libby, 429 F. Supp. 2d 1 (D.D.C. 2006) | 24 |
108
+ | United States v. Manzano, 945 F.3d 616 (2d Cir. 2019) | 13, 17 |
109
+ | United States v. McGuinness, 764 F. Supp. 888 (S.D.N.Y. 1991) | 11 |
110
+ | United States v. Middendotf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5<br>(S.D.N.Y. Aug. 17, 2018) | 20, 22 |
111
+ | United States v. Moon, 718 F.2d 1210 (2d Cir. 1983) | 30, 33 |
112
+
113
+ # Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 5 of 34
114
+
115
+ | 8<br>United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) |
116
+ |-----------------------------------------------------------------------------------------------------------|
117
+ | United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005)<br>21 |
118
+ | United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996)<br>10 |
119
+ | 8<br>United States v. Persico, 645 F.3d 85 (2d Cir. 2011) |
120
+ | United States v. Reese, 933 F. Supp. 2d 579 (S.D.N.Y. 2013)<br>13, 16 |
121
+ | United States v. Rigas, 258 F. Supp. 2d 299 (S.D.N.Y. 2003)<br>11, 12 |
122
+ | United States v. Rigas, 583 F.3d 108 (2d Cir. 2009)<br>20 |
123
+ | United States v. Rosado, 728 F.2d 89 (2d Cir. 1984)<br>17 |
124
+ | United States v. Rosenfield, 469 F.2d 598 (3d Cir. 1972)<br>15 |
125
+ | United States v. Ruggiero, 472 F.2d 599 (2d Cir. 1973)<br>7 |
126
+ | United States v. Sanders, 17 F. Supp. 2d 141 (E.D.N.Y. 1998)<br>29 |
127
+ | United States v. Southland Corp., 760 F.2d 1366 (2d Cir. 1985)<br>15 |
128
+ | United States v. Stein, 424 F. Supp. 2d 720 (S.D.N.Y. 2006)<br>21 |
129
+ | United States v. Stevens, 985 F.2d 1175 (2d Cir. 1993)<br>9, 12 |
130
+ | United States v. Thomas, 116 F.3d 606 (2d Cir. 1997)<br>12 |
131
+ | United States v. Undenvood, No. 04 Cr. 424 (RWS), 2005 WL 927012, at *I<br>(S.D.N.Y. Apr. 21, 2005)<br>10 |
132
+ | United States v. Upton, 856 F. Supp. 727 (E.D.N.Y. 1994)<br>21 |
133
+ | United States v. Volpe, 42 F. Supp. 2d 204 (E.D.N.Y. 1999)<br>24 |
134
+ | United States v. Washington, 705 F.2d 489 (D.C. Cir. 1983)<br>14, 15 |
135
+ | United States v. White, 972 F.2d 16 (2d Cir. 1992)<br>33 |
136
+ | United States v. Yousef, 327 F.3d 56 (2d Cir. 2003)<br>19 |
137
+
138
+ ### PRELIMINARY STATEMENT
139
+
140
+ The Government respectfully submits this memorandum of law in opposition to defendant Michael Thomas's motion to compel discovery. (Dkt. No. 33) ("Mot."). Thomas seeks an order compelling the Government to collect materials that are not in its possession, not discoverable under any legal basis, and not related to any legally cognizable defense. Thomas's motion is entirely without merit and should be denied.'
141
+
142
+ Thomas concedes that the Government has produced a "multitude" of discovery directly relevant to the charges against him. (Mot. 6). Nonetheless, he seeks an order compelling the Government to collect and produce additional materials that he believes would support his purported defenses, namely, that he committed the offenses because of staffing issues and supervisory lapses, and that he was singled out for prosecution. Specifically, Thomas seeks: (i) a copy of a report being prepared by the Department of Justice, Office of the Inspector General ("DOJ-OIG"), which does not yet exist and would principally be based on the same primary materials that the Government produced to Thomas in December 2019 (Mot. 5, 8-9); (ii) reports and documents prepared by the Bureau of Prisons ("BOP") and other agencies who were not and are not members of the prosecution team (Mot. 6-7); (iii) reports and documents related to "any and all [Metropolitan Correctional Center ("MCC")] employees" who have engaged in "the same or similar conduct," including an incident in "2005 or 2006" where officers failed to conduct counts or rounds and an inmate committed suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP
143
+
144
+ Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the deadline for making a Rule 12(b)(3) motion, the motion is untimely. But a court may consider the defense, objection, or request if the party shows good cause.").
145
+
146
+ #### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 7 of 34
147
+
148
+ policies which relate to the "much larger context" at the BOP (Mot. 6, 7, 9, 10).
149
+
150
+ As an initial matter, the Government has satisfied its Rule 16, Brady, and Giglio obligations and is not in possession of the additional materials that Thomas seeks. More importantly, Thomas is not entitled to compel the Government to collect the additional records for at least four separate reasons. First, the records are not "material" to preparing a defense because they are wholly irrelevant to the false statement charges against Thomas and are intended to prompt jurors to nullify the charges against him. Second, the BOP records Thomas seeks are not in the "possession" of the prosecution team, and there is no legal basis for compelling the Government to collect materials from other agencies or components of the Department of Justice who are not and were not part of the criminal investigation that led to the charges against Thomas. Third, there is no legal basis to require the Government to produce a draft of the report being prepared by the DOJ-OIG, which is subject to the deliberative process privilege. Fourth, Thomas is not entitled to discovery relating to what happened to other MCC employees when they "falsiflied] the same documents," (Mot. 6), because he has utterly failed to identify evidence that the decision to prosecute him had a discriminatory effect and was motivated by a discriminatory purpose. Thomas's motion should be denied in all respects.
151
+
152
+ ## STATEMENT OF FACTS
153
+
154
+ ### 1. The Indictment
155
+
156
+ Indictment 19 Cr. 830 (AT) (the "Indictment") was filed on November 19, 2019, charging defendants Tova Noel and Michael Thomas in six counts: (i) conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371 (Count One); and (ii) five counts of making or using a false writing or document, in violation of Title 18, United States Code, Sections 1001(a)(3) and 3 (Counts Two through Six).
157
+
158
+ #### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 8 of 34
159
+
160
+ Both defendants are charged in Counts One, Four, Five, and Six; defendant Noel only is charged in Counts Two and Three. The charges in the Indictment stem from a fourteen-hour time period, from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019, when the defendants were working as correctional officers at the MCC. As charged in the Indictment, during that time period, the defendants failed to perform mandated counts of prisoners housed in MCC's Special Housing Unit ("SHU"), but nevertheless signed false certifications attesting to having conducted those counts, when, in fact, no counts or rounds of the SHU were conducted from approximately 10:30 p.m. on August 9 to 6:30 a.m. on August 10.
161
+
162
+ # II. Pretrial Discovery and the Defendants' Request for Additional Materials
163
+
164
+ ### A. The Government's Discovery Production
165
+
166
+ At the initial pretrial conference on November 25, 2019, the Court set a discovery deadline of December 31, 2019. On that date, pursuant to a protective order entered by the Court, the Government made a substantial discovery production to both defendants, consisting in part of the following: surveillance video for the common area of the SHU; analysis of the computers used by Noel and Thomas from August 9 to 10, 2019; count slips and thirty-minute round reports; MCC phone records; personnel records and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG who were participating in the investigation.2
167
+
168
+ Subsequently, the Government made three additional discovery productions, much more limited in scope. On January 23, 2020, the Government produced additional interview reports and
169
+
170
+ <sup>2</sup> The Government does not concede that production of all of the materials was required under Rule 16, but nonetheless produced the materials in its possession out of an abundance of caution.
171
+
172
+ notes. On January 30, 2020,3 the Government reproduced video surveillance footage with timestamps, and on March 16, 2020, the Government produced forensic reports for three electronic devices and a photograph of a text message.
173
+
174
+ # B. Defense Requests for Additional Discovery Materials
175
+
176
+ The defendants have made a number of requests for additional discovery materials, in response to which the Government has provided information in its possession as consistent with Rule 16 and its other disclosure obligations, as described below.
177
+
178
+ At the initial pretrial conference on November 11, 2019, Thomas, through counsel, raised the issue of an "ongoing . . . report" by the Office of the Inspector General and requested the "status" of the report and when it would be completed.4 (Conf. Tr., Nov. 25, 2019, at 3-4, 7-9). In response, the Government explained that "to the extent counsel's asking for a summary of the results of the criminal investigation, obviously we'll be turning over in discovery all of the underlying results of the criminal investigation. . . I don't have a time frame on the Mnspector [G]eneral report, but the [G]ovemment will produce to the defense all of the relevant discovery materials in this matter, which includes the Rule 16 materials relevant to the criminal charges that have been brought against the defendants." (Id. at 7-8). As there was no pending issue to resolve, the Court declined to rule at that time.
179
+
180
+ On January 29, 2020, Thomas and Noel each submitted discovery requests to the Government. Thomas's letter reiterated his prior request for "any and all reports, memorandums,
181
+
182
+ <sup>3</sup>The January 30, 2020 production was made to Noel's counsel on January 24, 2020, while the Government was still waiting for an additional hard drive from Thomas's counsel.
183
+
184
+ <sup>4</sup> Based on conversations with attorneys at DOJ-OIG tasked with preparing this report, the Government understands that the report will likely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures.
185
+
186
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 10 of 34
187
+
188
+ written statements, photos, videos, and incident reports created, manufactured or possessed by the United States Inspector General." Noel's January 29 letter sought materials related to the MCC video surveillance system and additional surveillance video, as well as assistance locating particular information in the surveillance video footage that the Government had previously produced in discovery.
189
+
190
+ At the pretrial conference the following day, Thomas, through counsel, renewed his request for "whatever investigation was done and whatever information there is that is discoverable with respect to the Inspector General's report." (Conf. Tr., Jan. 30, 2020, at 6, 9). The Court directed Thomas to file a motion formalizing his request. (Id. at 9).5
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+
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+ The Government responded to the defendants' discovery requests by letter dated March 14, 2020. As for Thomas's request for materials related to any forthcoming Inspector General's report, the Government referred Thomas to its prior response as stated at the November 25, 2019 pretrial conference. With respect to Noel's requests for additional materials related to the MCC video surveillance system, the Government explained that to the extent such materials were in the Government's possession and currently subject to disclosure, they had already been produced. In addition, the Government provided additional information answering certain of Noel's questions, including video timestamps to assist with review of the surveillance footage.
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+
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+ On March 27, 2020, Thomas submitted another discovery request to the Government, seeking, among other things, information from the BOP regarding other correctional officers and information about the Government's charging decisions. The Government responded by letter
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+
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+ <sup>5</sup> Thomas, through counsel, previewed that he would also likely file a motion to dismiss the indictment based on "selective prosecution." (Conf. Tr., Jan. 30, 2020 at 6). The deadline for filing motions, which was extended at counsel's request, has passed, and Thomas has failed to timely file a motion to dismiss.
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+
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+ # Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 11 of 34
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+
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+ dated April I, 2020, explaining that any responsive information in the Government's possession and subject to disclosure had already been produced. The letter further explained that to the extent the requests called for items not in the Government's possession or not subject to disclosure, Thomas had not identified any legal basis or authority for his requests and the Government was not aware of any authority requiring the Government to obtain or produce the requested information.
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+
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+ On April 9, 2020, Thomas filed the instant motion seeking an order from the Court compelling the Government to produce the following:
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+
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+ - The Inspector General's report investigating the death of Jeffrey Epstein and BOP policies and procedures (referred to herein as the "Inspector General's Report"), as well as all supporting memoranda and other documents, (Mot. 4-5);
205
+ - Any and all "reports generated by investigators within the [BOP] regarding the August 10, 2019 incident" as well as "documents, reports, witness statements and disciplinary records of any and all MCC employees who have engaged in the same or similar conduct," including "results of any disciplinary proceedings and documents maintained by the BOP regarding the discipline or administrative adjudication of any other employees who have failed to conduct rounds or inmate counts," (Mot. 4, 6);
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+ - Any previously undisclosed reports, witness statements, and documents created by "any other federal agencies that investigated the circumstances surrounding the death of Jeffrey Epstein," (Mot. 4, 7).
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+
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+ For the reasons that follow, Thomas is not entitled to the materials he seeks, and his motion
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+
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+ should be denied.
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+
212
+ ### ARGUMENT
213
+
214
+ ## I. Applicable Law
215
+
216
+ ### A. Brady & Giglio
217
+
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+ The Government has an obligation under the Due Process Clause to make a timely disclosure of any exculpatory or impeaching evidence that is material and in its possession. See Brady v. Maryland, 373 U.S. 83 (1963); Giglio v. United States, 405 U.S. 150 (1972); see also United States v. Coppa, 267 F.3d 132, 139-40 (2d Cir. 2001). Evidence is "material" in this sense only if "its suppression undermines confidence in the outcome of a trial." United States v. Bagley, 473 U.S. 667, 678 (1985). "The rationale underlying Brady is not to supply a defendant with all the evidence in the Government's possession which might conceivably assist the preparation of his defense, but to assure that the defendant will not be denied access to exculpatory evidence only known to the Government." United States v. LeRoy, 687 F.2d 610, 619 (2d Cir. 1982) (citing United States v. Ruggiero, 472 F.2d 599, 604 (2d Cir. 1973)).
219
+
220
+ Impeachment evidence is material only "where the witness at issue supplied the only evidence linking the defendant(s) to the crime, or where the likely impact on the witness's credibility would have undermined a critical element of the prosecution's case." United States v. Payne, 63 F.3d 1200, 1210 (2d Cir. 1995) (internal quotation marks and citations omitted). Similarly, "where the undisclosed evidence merely furnishes an additional basis on which to challenge a witness whose credibility has already been shown to be questionable or is subject to extensive attack by reason of other evidence, the undisclosed evidence may properly be viewed as cumulative, and hence not material." United States v. Persico, 645 F.3d 85, 111 (2d Cir. 2011) (citing cases). With regard to the timing of disclosing material under Giglio, the Second Circuit, in Coppa, rejected the argument that such material should be disclosed when defendants make a
221
+
222
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 13 of 34
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+
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+ demand for it. 267 F.3d at 146. The court held that as a general rule, Brady and its progeny do not require immediate disclosure of all impeachment material upon a defendant's request. Id. It found that the time required for its effective use would depend on the materiality of the evidence as well as the particular circumstances of the case, and suggested that district courts may order disclosure of material it deems material as a matter of case management. Id. As described above, the Government disclosed reports and notes of witness statements as part of its discovery productions, such that the defendants will have possessed substantial material that may serve as potential impeachment evidence for one year in advance of trial.
225
+
226
+ ### B. Rule 16
227
+
228
+ Rule 16 of the Federal Rules of Criminal Procedure requires the Government to permit the defendants to inspect and copy documents and objects within the Government's possession, custody, or control if the items are material to preparing the defense, if the Government intends to use them in its case-in-chief at trial, or if the items were obtained from or belong to the defendant. Fed. R. Crim. P. 16(a)(1)(E). An item is "material to preparing the defense" under Rule 16 "if it could be used to counter the Government's case or bolster a defense." United States v. Stevens, 985 F.2d 1175, 1180-81 (2d Cir. 1993).
229
+
230
+ # II. Thomas is Not Entitled to Additional Materials
231
+
232
+ ## A. The Government Has Satisfied its Discovery and Disclosure Obligations
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+
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+ As an initial matter, the Government is aware of, has satisfied, and will continue to satisfy its discovery and disclosure obligations.
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+
236
+ The Government has met its Rule 16 discovery and disclosure obligations. As set forth above, the Government has produced an expansive amount of discovery, which includes among other things, hundreds of hours of video surveillance going back to July 5, 2019 (despite the fact
237
+
238
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 14 of 34
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+
240
+ that the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written Bureau of Prison policies and regulations, among other documents and materials. In addition and while not required by Rule 16, the Government produced months in advance of trial (and now, approximately a year in advance of trial) statements for all of the witnesses interviewed during the investigation. While the Government is not aware of any other information that warrants disclosure, it will produce any such materials to the extent it becomes aware of them.
241
+
242
+ The Government is likewise aware of, and has complied with, its Brady and Giglio obligations. The Government has already produced any evidence in its possession that is arguably exculpatory or impeaching. To the extent Giglio material exists in notes of witness statements or attorney proffers made on behalf of witnesses that have not already been produced, the Government intends to comply with its obligations and will make such disclosures sufficiently in advance of trial to be effectively used. Based on that representation alone, the defendant's motion should be denied. See United States v. Gonzalez, No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5 (S.D.N.Y. Apr. 9, 2020) (denying a motion to compel because the government "represented that it had complied with and would continue to comply with its Brady and Rule 16 obligations); United States v. Undenvood, No. 04 Cr. 424 (RWS), 2005 WL 927012, at *1 (S.D.N.Y. Apr. 21, 2005) ("The courts of this Circuit repeatedly have denied pretrial requests for discovery orders pursuant to Brady where the government has made such good faith representations."); United States v. Perez, 940 F. Supp. 540, 553 (S.D.N.Y. 1996) (denying defendant's motion to compel production of Brady based on Government's representation that it was aware of and had complied with Brady).
243
+
244
+ # B. The Requested Records Are Not "Material" to Preparing a Defense and Are Sought for the Impermissible Purpose of Jury Nullification
245
+
246
+ All of the records Thomas seeks in his motion are not "material to preparing a defense" under Rule 16, and are not exculpatory under Brady, because they are irrelevant to countering the Government's false statements case or advancing a legitimate defense. Instead, Thomas seeks evidence of staffing shortages, working conditions, the implementation of BOP policies, supervisory lapses, and instances in which other BOP employees were not prosecuted so that he can engage in attempted jury nullification by arguing that those conditions "led" to the criminal conduct that he is charged with and are a reason to acquit him. (Mot. 5, 7, 9, 14). Thomas is not entitled to records—and certainly would not be entitled to introduce any such evidence at trial that would aid in that nullification effort because Rule 16 only entitles a defendant to discovery for purposes of bolstering a defense to the Government's case in chief, not the merits of the decision to prosecute.
247
+
248
+ # 1. Applicable Law
249
+
250
+ An item or record that the Government does not intend to use in its case-in-chief at trial is discoverable under Rule 16(a)(1)(E) only if it "is material to preparing the defense." Fed. R. Crim. P. 16(a)(1)(E). "It is [a defendant's] burden to make a prima facie showing that documents sought under Rule 16(a)(1)(E)(i) are material to preparing the defense." United States v. Rigas, 258 F. Supp. 2d 299, 307 (S.D.N.Y. 2003) (citing United States v. McGuinness, 764 F. Supp. 888, 894 (S.D.N.Y. 1991)). As noted above, an item is "material to preparing the defense" under Rule 16 "if it could be used to counter the Government's case or bolster a defense." Stevens, 985 F.2d at 1180-81. The defendant must "offer more than the conclusory allegation that the requested evidence is material." Rigas, 258 F. Supp. 2d at 307 (internal citation omitted).
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+
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+ As the Supreme Court held in United States v. Armstrong, while Rule 16 authorizes
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+
254
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 16 of 34
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+
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+ defendants to examine records "material to the preparation of their defense against the Government's case in chief," it does not authorize discovery for defenses that do not rebut the "merits to the criminal charge itself." 517 U.S. 456, 462-63 (1996) (holding that Rule 16 does not authorize discovery relating to a selective prosecution claim). For that reason, because evidence that would be impermissibly used to encourage jury nullification does not relate to the merits of the criminal charges, it is not discoverable under Rule 16. Id.; see also United States v. Defreitas, No. 07 Cr. 543 (DLI), 2011 WL 317964, at *10 (E.D.N.Y. Jan. 31, 2011) (rejecting discovery request related to something that is "not a defense" and has "nothing to do with the issues of whether defendants . . . committed the ... crimes charged"). Since jury nullification is "a practice whereby a juror votes in purposeful disregard of the evidence," United States v. Thomas, 116 F.3d 606, 614 (2d Cir. 1997), or "out of compassion or compromise," Standefer v. United States, 447 U.S. 10, 22 (1980) (internal citation omitted), it is not error for a court to preclude evidence that is "not a valid defense" aimed at nullification, United States v. Edwards, 101 F.3d 17, 19-20 (2d Cir. 1996). See also United States v. Reese, 933 F. Supp. 2d 579, 583-84 (S.D.N.Y. 2013) (precluding defense arguments or evidence related to "possible consequences for the defendant of conviction, jury nullification, and the Government's motive and conduct in prosecuting [defendant]"); United States v. Levin, No. 15 Cr. 101 (KBF), 2016 WL 299031, at *12 (S.D.N.Y. Jan. 25, 2016) (barring evidence "intended to elicit sympathy" and attempts to "use jury nullification as a defense" as "plainly improper"). Indeed, "trial courts have the duty to forestall or prevent jury nullification" even where the defendant or the court may "strongly disagree[] with the government's charging decisions and the attendant sentencing consequences." United States v. Manzano, 945 F.3d 616, 626-27 (2d Cir. 2019) (citations & quotation marks omitted).
257
+
258
+ ### 2. Discussion
259
+
260
+ Thomas's motion makes clear that he intends for his principal defense at trial to be that irrespective of his guilt or innocence of the false statements charges—he should be acquitted because the MCC was understaffed, Thomas was overworked, his supervisors did not catch his crime in the moment, and falsification of count slips is rampant within the BOP. (See Mot. 3 ("staffing issues, staffing shortages, supervisory lapses and the enforcement/interpretation of BOP procedures go to the heart of his defense to the government's criminal allegations"); 9 ("Mr. Thomas will assert that the rampant staffing shortages present at the MCC in August of 2019 led to the conduct for which Mr. Thomas is now criminally charged.")). Thomas has failed to meet his burden in establishing the materiality of discovery about these topics to preparing a valid defense because the materials he seeks do not rebut the merits of the criminal charges and instead would be impermissibly used to encourage jury nullification.
261
+
262
+ The purported reasons for Thomas's decision to falsify count slips—being tired, overworked, or understaffed—are not a valid legal defense, and therefore evidence related to those issues is not relevant. Put simply, were the jury to find beyond a reasonable doubt that Thomas intentionally made materially false statements and also that did so while tired or overworked, it would still be required to convict him. See United States v. Carr, 424 F.3d 213,221 (2d Cir. 2005) (holding that "it was proper for the district court to instruct the jury that it had a duty to find [the defendant] guilty if the government proved beyond a reasonable doubt every element of the offense with which he was charged" (internal citation omitted)).
263
+
264
+ None of Thomas's proffered excuses relate to proving or rebutting the elements of a violation of 18 U.S.C. § 100I(a)(3) as they do not concern whether a writing or entry was false, whether it was material to a matter within the jurisdiction of the BOP, or whether he knowingly
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+
266
+ #### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 18 of 34
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+
268
+ and willfully made a false statement. Nor are those excuses relevant to whether Thomas had a criminal agreement with his co-defendant. Indeed, evidence as to a defendant's purportedly innocent motive in a false statement case is irrelevant to the question of intent. See United States v. Washington, 705 F.2d 489, 493-94 (D.C. Cir. 1983) (holding that proof of a good or innocent motive is not probative of intent where the mens rea is "knowingly and willfully"); In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93, 154 n.49 (2d Cir. 2008) (citing Washington, 705 F.2d at 493, for "the irrelevance of a motive to the question of whether conduct is intentional"); United States v. George, 786 F. Supp. 56, 64 (D.D.C. 1992) (rejecting the defendant's "context argument" for why materials could be relevant to the crime charged).
269
+
270
+ For the same reasons, "other people were doing it" is not a defense to a false statements or conspiracy charge because the conduct of other BOP employees is irrelevant to each of the foregoing elements. Thomas argues that because he was aware of incidents where BOP employees falsified records and "their conduct did not lead to their indictment or incarceration," evidence of what other BOP employees have done is relevant to his intent. (Mot. 6.) Not so. Whether Thomas believed falsifying records was illegal or was subject to criminal penalties is not relevant to the charges against him. See United States v. Southland Corp., 760 F.2d 1366, 1372 (2d Cir. 1985) ("Ignorance of the law is no defense to a charge of purposeful and intentional action."); United States v. Rosenfield, 469 F.2d 598, 601 n.2 (3d Cir. 1972) ("As long as the inexcusable intent is present, it is not necessary that the defendant know that his conduct is subject to criminal penalties."). And in any event, it would be fundamentally inappropriate, and extremely prejudicial, for the jury to consider other individuals not on trial or otherwise relevant to the conduct charged here, in evaluating the guilt or innocence of the defendant. See United States v. Gibbons, 602 F.2d 1044, 1048 (2d Cir. 1979) (approving instruction that jury was not to consider individuals who
271
+
272
+ were not on trial).
273
+
274
+ Thomas's efforts to garner sympathy, put the Government on trial, and deflect blame for his own criminal actions plainly sound in nullification. See Reese, 933 F. Supp. 2d at 583-84; Levi,:, 2016 WL 2990831, at *12. Evidence on those points does not relate to whether the defendant committed the crimes charged, but rather is intended to elicit sympathy, compassion, or compromise from the jury. The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462- 63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective prosecution claim); United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. May 12, 2015) (rejecting defendant's "demands for general information and statistics relating to the Government's use of sting operations"); United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y. July 7, 1999) (rejecting discovery request for "background data, records and investigative reports" of the New York City Police Department ("NYPD") as well as information about NYPD officers' conduct in other cases); Defreitas, 2011 WL 317964, at *10 (rejecting discovery demands related to a "factual impossibility" defense to a conspiracy charge). It is the Court's "duty to forestall or prevent" jury nullification. Manzano, 945 F.3d at 627 (holding that "District courts have a duty to forestall or prevent [jury nullification arguments] and the district court in this case abdicated its duty by ruling that defense counsel could argue jury nullification."); see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) (criticizing trial court for inviting nullification by permitting the defendants to mount a "political defense" and stating that it was an "erroneous assumption that good motive for committing a crime is inconsistent with criminal intent").
275
+
276
+ In sum, much of the additional discovery Thomas seeks in his motion relates to legally
277
+
278
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 20 of 34
279
+
280
+ irrelevant matters, such as what "led" him to the criminal conduct or the broader "context" in which he committed specific criminal acts. There is no basis to compel production of evidence related to those matters under Rule 16, Brady, or Giglio because they are not material and because the evidence sought is in furtherance of a transparent attempt at nullification. Thomas's motion should be denied on this basis alone.
281
+
282
+ # C. The Government is Not Required to Collect Materials From Agencies Who Were Not Part of the Prosecution Team
283
+
284
+ Thomas asks the Court to compel the Government to produce "any reports, witness statements, memorandum, and documents from any separate investigation conducted by the BOP," "documents, reports, witness statements and disciplinary records of any and all MCC employees who have engaged in the same or similar conduct," and any previously undisclosed reports, witness statements, and documents created by "any other federal agencies that investigated the circumstances surrounding the death of Jeffrey Epstein." (Mot. 4, 7 (emphasis added)). Even if Thomas had satisfied the materiality requirement under Rule 16 or Brady with respect to these items—and he has not—Thomas's motion would still fail because the materials he seeks are not in the prosecution team's possession.
285
+
286
+ The BOP is not, and never has been, part of the prosecution team. Nor did the BOP conduct an investigation jointly or in coordination with the prosecution team.6 To require the Government to obtain and produce any records from the BOP from a separate investigation, as well as evidence that would support Thomas's purported (and improper, for the reasons discussed in Part II.B,
287
+
288
+ <sup>6</sup> The defendant claims, based on a CNN article, that the U.S. Marshal Service ("USMS") conducted an investigation. The Government is unaware of such an investigation, and in any event, any such inquiry by the USMS was not conducted jointly or in coordination with the prosecution team.
289
+
290
+ # Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 21 of 34
291
+
292
+ supra) defenses, is not legally required and would impose a nearly insurmountable obligation on the Government of marshaling and reviewing information and data in the possession of an entirely separate entity.
293
+
294
+ # 1. Applicable Law
295
+
296
+ As described above, Rule 16, Brady, and Giglio apply to materials in the Government's "possession." As a general matter, while "[lin individual prosecutor is presumed . . . to have knowledge of all information gathered in connection with his office's investigation of the case, . . . knowledge on the part of persons employed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the prosecutor's office on the case in question would inappropriately require us to adopt a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis." Id. (citation & quotation marks omitted); see also Kyles v. Whitley, 514 U.S. 419, 437 (1995) (Government's discovery and disclosure obligations extend only to information in the custody of the prosecutor or "others acting on the government's behalf in the case"). Thus, discovery and disclosure obligations only extend "information known to persons who are a part of the `prosecution team' ... who perform investigative duties or make strategic decisions about the prosecution of the case," including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (citation omitted). Brady is not a basis to compel the Government to gather information in the possession of third parties on behalf of the defense. See United States v. Yousef, 327 F.3d
297
+
298
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 22 of 34
299
+
300
+ 56, 112 (2d Cir. 2003) (defendants were not deprived of due process by any alleged failure of U.S. government to help them obtain cooperation from foreign authorities).
301
+
302
+ In considering whether Rule 16 and Brady apply to records in the possession of another government agency, a prosecutor's duty extends to reviewing such evidence only where the Government conducts a "joint investigation" with that agency or branch of government. See United States v. Rigas, 583 F.3d 108 (2d Cir. 2009) (affirming district court opinion holding that there was "no joint investigation with the [Securities and Exchange Commission ("SEC")]" and therefore the Government did not need to produce documents in the custody of the SEC); United States v. Blaszczak, 308 F. Supp. 3d 736, 742-43 (S.D.N.Y. 2018) (holding that the Government was not obligated to review SEC material for Brady where SEC was not involved in grand jury presentation, did not attend every interview, did not review documents gathered only by prosecution, and did not develop prosecutorial strategy); United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.Y. Aug. 17, 2018) (holding that the Government was not required to conduct a search because the [Public Company Accounting Oversight Board ("PCAOB")] was not involved in witness interviews or developing prosecutorial strategy, and the SEC was not involved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-42 (S.D.N.Y. 2019) (no joint investigation between Government and SEC); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (Chin, J.) (no joint investigation between Government and New York Stock Exchange ("NYSE")); United States v. Upton, 856 F. Supp. 727, 749-50 (E.D.N.Y. 1994) (holding that USAO and Federal Aviation Administration ("FAA") did not conduct a "joint investigation" even though the FAA provided two inspectors to assist the criminal investigation).
303
+
304
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 23 of 34
305
+
306
+ Moreover, even where agents from a component of an agency are involved in an investigation, that does not render the entirety of an agency part of the prosecution team. See, e.g., United States v. Stein, 424 F. Supp. 2d 720, 723 (S.D.N.Y. 2006) ("While the prosecution's [Rule 16] disclosure obligation in some circumstances may extend to materials beyond the knowledge of the individual prosecutors assigned to a case, it does not extend to the collective knowledge of the entire United States government or even to the entire government agency concerned."); United States v. Pelullo, 399 F.3d 197, 218 (3d Cir. 2005) ("[T]hat other agents in the ([Department of Labor ("DOL")] participated in this investigation does not mean that the entire DOL is properly considered part of the prosecution team."); see also United States v. Locascio, 6 F.3d 924, 949 (2d Cir.1993) (refusing, for Brady purposes, to impute to AUSAs prosecuting that action with the assistance of certain FBI agents knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); but see United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who were involved in making decisions about timing and progress of the case were part of the "government" for Rule 16 purposes).
307
+
308
+ Thus, as the foregoing precedents recognize, the factors relevant in determining whether an agency or a component of an agency are part of the prosecution team, and therefore their records are in the "possession" of the Government include whether the agency or component: "(1) participated in the prosecution's witness interviews, (2) was involved in presenting the case to the grand jury, (3) reviewed documents gathered by or shared documents with the prosecution, (4) played a role in the development of prosecutorial strategy, or (5) accompanied the prosecution to court proceedings." Middendwf, 2018 WL 3956494, at *4.
309
+
310
+ ### 2. Discussion
311
+
312
+ As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the United States Attorney's Office or the case teams at the FBI and DOJ-OIG who worked on this criminal investigation.
313
+
314
+ Thomas seeks a variety of records from the BOP. The BOP was not a member of the prosecution team, and no employee of the BOP performed investigative duties or made strategic decisions about the prosecution of the case. Indeed, the Government obtained records from the MCC (a component of the BOP) pursuant to a grand jury subpoena to the institution and written requests to the MCC's legal department. Likewise, the Government was not involved in any internal BOP investigation into the circumstances surrounding Epstein's suicide. Notwithstanding those facts, the defendant asserts that the BOP is "allied with the prosecution" and therefore the Government's discovery and disclosure obligations extend to materials exclusively in the possession of the BOP. That argument is not only belied by the facts, but it is settled law in this Circuit that a prosecutor's duty extends to reviewing the materials in the possession, custody, or control of another agency for Brady evidence only where the Government conducts a "joint investigation" with that agency. None of the indicia of a "joint" or "allied" prosecution, as discussed in the foregoing case law, is present here. A straightforward application of those factors considered by courts in this Circuit reveals that the investigation was in no way joint: the BOP did not participate in the prosecution's witness interviews; it was not involved in presenting the case to the grand jury; no BOP employees aided in the review of documents gathered by the
315
+
316
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 25 of 34
317
+
318
+ Government; the BOP was not involved in the strategic decisions; and no BOP personnel accompanied the prosecution to court proceedings.
319
+
320
+ Moreover, even if the BOP had conducted a joint investigation with the Government into the events of August 9 and 10, 2019 (which they did not), Thomas has offered no reason to believe that most if not all of the records that he seeks-such as records of other instances of BOP employees failing to conduct rounds and counts—would be part of the BOP's investigation. There is simply no basis to seek an order compelling the Government to search for records in the possession of the BOP, without any temporal limitation or factual nexus to the charged case, regarding staffing shortages at the MCC, other instances where BOP employees failed to conduct required rounds and counts, and disciplinary records for other BOP employees who have at other times also allegedly falsified records.
321
+
322
+ The cases Thomas cites do not support a contrary result. In United States v. Biyan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out of a single, nationwide IRS investigation. 868 F.2d 1032, 1035-37 (9th Cir. 1989). In reaching that holding, the Circuit explained that "a federal prosecutor need not comb the files of every federal agency which might have documents regarding the defendant" and that Rule 16's disclosure requirements are cabined to anything in the possession "of any federal agency participating in the same investigation of the defendant." Id. at 1036 (emphasis added). Similarly, in United States v. Volpe, 42 F. Supp. 2d 204, 221 (E.D.N.Y. 1999), the court explained, in denying the defendant's discovery motion, that "[c]ourts have construed the term `government' . . . narrowly to mean the prosecutors in the particular case or the governmental agencies jointly involved in the prosecution of the defendant, and not the 'government' in general." And while the court in United States v. Libby, 429 F. Supp.
323
+
324
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 26 of 34
325
+
326
+ 2d I, 9 (D.D.C. 2006), required the prosecutors to obtain records from the Office of the Vice President and the Central Intelligence Agency, even though those parts of government did not participate in the grand jury investigation, that holding was an outlier, which has never been cited by another court, and the decision itself has never been cited in this Circuit.
327
+
328
+ Finally, even if such materials had any conceivable relevance to the charges at hand (which, as discussed above, they do not), asking the Government to conduct a broad canvassing of the BOP's records—including searching databases located out of state, reviewing large quantities of documents, attempting to pull archived records going back as far as 2005, and parsing through attorney work product—would be inordinately time consuming and burdensome for attorneys for the Government, which does not have custody of the files, is not familiar with the files, and knows of no effective way to search them. It would, as the Circuit warned against in Avellino, "condemn the prosecution of criminal cases to a state of paralysis." 136 F.3d at 255. Such a result is not legally required by Rule 16, Brady, or Giglio, and therefore Thomas's motion should be denied.
329
+
330
+ ### D. Any Draft Inspector General Report is Not Subject to Disclosure
331
+
332
+ Thomas argues that any report by the Inspector General and related materials must be produced because he speculates that such a report will address systemic issues at the BOP, including purported staffing shortages at the MCC. (Mot. 5,9-10). For the reasons set forth above, any draft Inspector General Report is not discoverable because the issues Thomas believes it will discuss are not material to the preparation of a valid defense, see Part II.B, and the draft reports, to the extent they exist, are protected from disclosure by the deliberative process privilege. While the prosecution team has had no involvement in writing the Inspector General Report, the Government understands that those attorneys from DOJ-OIG responsible for writing the Report have not yet completed a draft, and do not anticipate completing the Report in the near term. As
333
+
334
+ # Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 27 of 34
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+
336
+ such, there are no drafts of the Report to disclose, and Thomas's motion can be denied on that reason alone. Moreover, Thomas's request for draft versions of the Report—which do not yet exist-fails for two additional reasons.
337
+
338
+ First, drafts of the Inspector General's Report, which has not been completed and will likely make recommendations about reforms at the BOP, are protected from disclosure under the deliberative process privilege, which "covers 'documents reflecting advisory opinions, recommendations and deliberations comprising part of a process by which governmental decisions and policies are formulated.'" Dep't of Interior v. Klamath Water Users Protective Ass 'n, 532 U.S. 1, 8 (2001) (quoting N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132, 150 (1975)). The privilege is applicable in criminal and civil cases involving the government. See, e.g., United States v. Fernandez, 231 F.3d 1240, 1246-47 (9th Cir. 2000) (government's death penalty evaluation form and prosecution memoranda were shielded from discovery under the deliberative process privilege); In re Sealed Case, 121 F.3d 729, 737-40 (D.C. Cir. 1997) (indicating that the privilege applies to grand jury subpoenas); United States v. Frank, 8 F. Supp. 2d 253, 284 (S.D.N.Y. 1998) (internal memoranda covered by privilege). "In order for the privilege to apply, the agency record at issue must be (1) an inter-agency or intra-agency memorandum or letter; (2) pre-decisional; and (3) deliberative." Nat'l Res. Def. Council v. U.S. Envtl. Prot. Agency, 954 F.3d 150, 155 (2d Cir. 2020). "It is well-settled that draft documents, by their very nature, are typically pre-decisional and deliberative [because] Whey 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." Color of Change v. U.S. Dep't of Homeland Sec., 325 F. Supp. 3d 447, 453 (S.D.N.Y. 2018) (quoting Amnesty Intl USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010)).
339
+
340
+ The Inspector General's Report is both pre-decisional and deliberative. A full draft has not
341
+
342
+ #### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 28 of 34
343
+
344
+ been completed, let alone reached a point where the final version will be disclosed to the public. It is also deliberative in that it will likely make recommendations about the BOP, and those recommendations will be under discussion within the Office of the Inspector General prior to being finalized and publicly announced. Internal deliberations are an important tool for agencies in reaching decisions, including recommendations in DOJ-OIG reports. The ability to have these discussions is important in identifying a broad range of policy and legal issues. Here, disclosure of any draft report or other work product related to the preparation of the Report will undermine the DOJ-OIG's ability to engage in meaningful discussions of the issues at the BOP relating to inmate security and staffing, among other topics, and will potentially stifle rigorous discourse on the issues. Accordingly, Thomas's motion should be denied for the reason that the materials sought are protected by the deliberative process privilege. Klamath, 532 U.S. at 9.
345
+
346
+ Second, Thomas has offered no support for his contention that drafts of the Inspector General's Report itself (and any related work product)—as opposed to the underlying materials upon which the Report is based—are subject to disclosure. To the extent that the forthcoming Inspector General's Report relies on information gathered during the instant investigation and prosecution, those underlying materials—which focus primarily on the events of August 9 and 10, 2019, the incarceration of Jeffrey Epstein, and related MCC records—have already been disclosed to the defendants. Thomas contends that those tasked with preparing the Report may "possibl[y]" have generated additional witness statements and "other information" that has not been produced by the Government to date. (Mot. 5). Thomas provides no support for such assertions besides mere speculation. The prosecution has inquired of the Washington D.C.-based attorneys who are preparing the Inspector General's Report. Based on those conversations, it is the prosecution's understanding that those attorneys have not conducted any additional interviews or otherwise
347
+
348
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 29 of 34
349
+
350
+ discovered any potential Brady material. As such, given that the prosecution has already produced in discovery all of the materials it provided to the DOJ-OIG attorneys preparing the Report, the underlying materials for the Report would be merely cumulative of information in the defendants' possession. Any analysis of those materials by the attorneys preparing the Inspector General's Report is not subject to disclosure pursuant to Rule 16 and cannot constitute Brady material. See United States v. Lewis, 35 F.3d 148, 150 (4th Cir. 1994) (noting generally that "nothing contained in [an] OIG report would ordinarily have been discoverable").
351
+
352
+ At bottom, Thomas has not cited a single authority requiring the production of a draft, unpublished report by an inspector general or related work product, and such production is not required by Rule 16, Brady, Giglio, or any other disclosure obligation.
353
+
354
+ ## E. Thomas Has Not Carried His Burden With Respect to Discovery of Material in Support of a Selective Prosecution Claim
355
+
356
+ Thomas seeks "information and statistics that show the conduct in which the defendant is being charged with a crime were . . . rampant throughout the BOP" and that the application of criminal laws to him is "possibl[y] discriminatory." (Mot. 7.) This request, which is effectively a demand for discovery in furtherance of a selective prosecution claim, should be denied not only for the reasons set forth in Section II.B, but also because Thomas has not made the requisite showing that is necessary to obtain discovery for a selective prosecution claim. Indeed, Thomas has failed to put forth any evidence that his prosecution was the result of discriminatory effect or discriminatory purpose.
357
+
358
+ # 1. Applicable Law
359
+
360
+ "A selective-prosecution claim is not a defense on the merits to the criminal charge itself, but an independent assertion that the prosecutor has brought the charge for reasons forbidden by the Constitution." Armstrong, 517 U.S. at 468. The standard to prove this defense is "a demanding
361
+
362
+ #### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 30 of 34
363
+
364
+ one," id., as the defendant must "overcome the strong presumption of regularity on the part of federal prosecutors, and 'in the absence of clear evidence to the contrary, courts presume that they have properly discharged their official duties."' United States v. Sanders, 17 F. Supp. 2d 141, 144 (E.D.N.Y. 1998) (quoting Armstrong, 517 U.S. at 464), aff'd, 211 F.3d 711 (2d Cir. 2000).
365
+
366
+ A defendant claiming selective prosecution must present "clear evidence" that the decision to prosecute not only (1) "had a discriminatory effect" but was also (2) "motivated by a discriminatory purpose." Armstrong, 517 U.S. at 465; United States v. Alameh, 341 F.3d 167, 173 (2d Cir. 2003); United States v. Fares, 978 F.2d 52, 59 (2d Cir. 1992); United States v. Moon, 718 F.2d 1210, 1229 (2d Cir. 1983). "The discriminatory effect prong requires a showing that `similarly situated individuals of a different [classification] were not prosecuted.'" Alameh, 341 F.3d at 173 (quoting Armstrong, 517 U.S. at 465). In other words, the defendant must show that he has been "singled out" as a member of a protected class. Fares, 978 F.2d at 59 (quoting Moon, 718 F.2d at 1229). To establish discriminatory purpose, the defendant must show that the Government's discriminatory "selection of the defendant for prosecution has been invidious or in bad faith, i.e., based upon such impermissible considerations as race, religion, or the desire to prevent his exercise of constitutional rights." Id. (internal quotation marks omitted; alteration incorporated). Where a defendant "has not shown that the Government prosecuted him because of his protected status or conduct, his claim fails. Id.
367
+
368
+ In order to obtain discovery on a selective prosecution claim, the defendant must offer "some evidence tending to show the existence of the essential elements of the defense." Armstrong, 517 U.S. at 468 (quoting United States v. Berrios, 501 F.2d 1207, 1211 (2d Cir. 1974)); United States v. Bass, 536 U.S. 862, 863 (2002) (per curiam) (to obtain discovery, a defendant accordingly first "must show some evidence of both discriminatory effect and discriminatory
369
+
370
+ # Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 31 of 34
371
+
372
+ intent"); Fares, 978 F.2d at 59 (same). "[T]he showing necessary to obtain discovery should itself be a significant barrier to the litigation of insubstantial claims." Armstrong, 517 U.S. at 464. "Mere assertions and generalized proffers on information and belief are insufficient" to meet this burden. Fares, 978 F.2d at 59; see, e.g., Armstrong, 517 U.S. at 470 (affidavits "recount[ing] hearsay and report[ing] personal conclusions based upon anecdotal evidence" are not sufficient to justify discovery); Berrios, 501 F.2d at 1211 (affidavit from defendant and attorney that they "believe[d]" there was improper motive and that "hundreds" of similarly situated individuals went unprosecuted was insufficient); Alameh, 341 F.3d at 174 (defendant's statistical analysis was insufficient to merit discovery on selective prosecution claim).
373
+
374
+ ### 2. Discussion
375
+
376
+ Thomas is not entitled to discovery that would relate to a selective procession or "discriminatory application" claim. He has not carried his burden through a showing of any evidence that his prosecution for the charges in the Indictment is discriminatory.
377
+
378
+ As to the first required prong (discriminatory effect), Thomas has failed to put forth any evidence that "others similarly situated have not generally been proceeded against because of conduct of the type forming the basis of the charge against [him]." Fares, 978 F.2d at 59 (internal quotation marks omitted). "A similarly situated offender is one outside the protected class who has committed roughly the same crime under roughly the same circumstances but against whom the law has not been enforced." United States v. Lewis, 517 F.3d 20, 27 (1st Cir. 2008). Thomas alleges that there was an "almost identical incident in 2005 or 2006 wherein officers failed to conduct institutional counts or rounds and an inmate committed suicide," and one of the four officers involved was given a suspension. (Mot. 6). But Thomas is not charged with failing to conduct counts, he is charged with making false statements about those counts. Even assuming
379
+
380
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 32 of 34
381
+
382
+ those officers "in 2005 or 2006" did falsify count slips, Thomas has still not put forth any evidence that those officers were "outside of the protected class," meaning of a different race, gender, nationality, or other protected class than Thomas. In any event, even were the conduct similar, that Thomas can point to but a single other instance in which officers were not criminally prosecuted for that type of conduct hardly rings of selectiveness.
383
+
384
+ Similarly, Thomas points to the fact that "Officer-1" and "Officer-2" in the Indictment, who falsified count slips along with Tova Noel for the 4 p.m. and 10 p.m. institutional counts on August 9, 2019, respectively, were not prosecuted. (Mot. 10; Ind. ¶¶ 15, 17, 19). Even assuming arguendo that Officer-1 and Officer-2 were similarly situated to Thomas in that they each falsified one count slip—while Thomas falsified three—Thomas has failed to put forth any evidence that either Officer-1 or Officer-2 were outside of a "protected class" to which Thomas belongs.' Nor could he: Officer-1 and Officer-2 are the same race, gender, and nationality as Thomas. Thomas also questions why his supervisors or other MCC personnel who received and reviewed Thomas's false count slips were not also prosecuted with making false statements, but those supervisors or personnel are not similarly situated to Thomas because they did not actually make the false statements—Thomas did. In addition, Courts have repeatedly held that the "suspicion [and] surmise" contained in Thomas's motion simply do not constitute "objective evidence" warranting discovery. See United States v. White, 972 F.2d 16, 19 (2d Cir. 1992) (conclusory allegations as to timing of indictment, Government's failure to follow internal guidelines, and improprieties of
385
+
386
+ <sup>7</sup> In so noting, the Government does not intend to comment on its deliberative process or the exercise of its prosecutorial discretion. It notes these facts simply in response to Thomas's claim that the lack of charges against Officer-1, Officer-2, or Thomas's supervisors is in and of itself sufficient to meet the defendant's burden of establishing evidence of a similarly situated defendant who was not charged.
387
+
388
+ ### Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 33 of 34
389
+
390
+ prosecutors not "objective evidence" warranting discovery); Moon, 718 F.2d at 1230 ("to engage in a collateral inquiry respecting prosecutorial motive, there must be more than mere suspicion or surmise"). Thomas's failure to make an evidentiary showing in support of the first required prong means that his motion for discovery on his selective prosecution claim must be denied. See, e.g., Bass, 536 U.S. at 863.
391
+
392
+ As to the second required prong, Thomas has failed to even allege, let alone establish, that the decision to prosecute him was motivated by a discriminatory purpose. To make such a showing, a defendant must establish that the Government's "selection of the defendant for prosecution has been invidious or in bad faith, i.e., based upon such impermissible considerations as race, religion, or the desire to prevent his exercise of constitutional rights." Fares, 978 F.2d at 59 (internal quotation marks omitted; alteration incorporated). Thomas has not put forth any evidence whatsoever that the Government's decision to prosecute Thomas was based on anything other than his guilt. Instead, Thomas challenges the Government's decision to prosecute him at all, based on his wholly unsupported claim that the criminal conduct with which he is charged is "rampant" within the BOP. (Mot. 7). But the mere fact that other people were not prosecuted for committing the crime that Thomas committed does not mean that the Government harbored discriminatory intent in prosecuting Thomas's
393
+
394
+ <sup>8</sup> Even if Thomas had not failed to carry his burden on his discovery motion (and he has failed), he would still not be entitled to put such evidence or argument regarding selective prosecution before a jury because the "selective prosecution defense is an issue for the court rather than the jury." Regan, 103 F.3d at 1082. The Second Circuit's directive makes sense. A claim of improper prosecutorial motive, whatever its ground or grounds, "is not a defense on the merits to the criminal charge itself, but an independent assertion that the prosecutor has brought the charge for reasons forbidden by the Constitution." Armstrong, 517 U.S. at 463. Instead, it is selfevidently "unrelated to factual innocence of the crime charged," which is the sole issue to be decided by the jury, and, as a result, the Court alone must resolve a claim of selective prosecution. Regan, 103 F.3d at 1082; see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) (criticizing admission of evidence about the propriety of a prosecution "for turning the trial away
395
+
396
+ Having failed to meet the "rigorous standard" required to obtain discovery on a selective prosecution defense, Thomas's requests for discovery of any materials related to other incidents in which officers were not prosecuted for falsifying count slips should be denied. Armstrong, 517 U.S. at 464.
397
+
398
+ ### CONCLUSION
399
+
400
+ For the foregoing reasons, the defendant's motion to compel should be denied.
401
+
402
+ Dated: New York, New York April 24, 2020
403
+
404
+ Respectfully submitted,
405
+
406
+ GEOFFREY S. BERMAN United States Attorney
407
+
408
+
409
+
410
+ from a determination of whether the elements of the offense charged had been proved beyond a reasonable doubt into a wide-ranging inquiry into matters far beyond the scope of legitimate issues in a criminal trial"). Accordingly, courts routinely and correctly preclude defendants from raising these arguments at trial. See Regan, 103 F.3d at 1082 ("[W]e agree with the district court's decision to resolve for itself whether the government's conduct was lawful and to prevent Regan from presenting evidence on that subject."); United States v. Raniere, No. 18 Cr. 204 (NGG), Dkt. 622 (precluding argument regarding propriety of Government's prosecution), United States v. Stewart, Cr. No. 03-717 (MGC), 2004 WL 113506, at *1 (S.D.N.Y. Jan. 26, 2004) (granting motion to preclude the defendant from "presenting arguments or evidence that would invite the jury to question the Government's motives in investigating and indicting" the defendant); United States v. Larkin, No. 12-CR-319, 2017 WL 928915, at *3 (D. Nev. Mar. 8, 2017) ("Defendant will be precluded from presenting evidence regarding the government's motive for prosecution in the instant case as such evidence is not relevant."); United States v. Starks, No. 10-CR-0160, 2012 WL 12878587, at *1 (N.D. Miss. July 20, 2012) (same).
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+ source: "DOJ Epstein Files, Data Set 8"
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+ | From: | MIE><br>(USANYS) [Contractor]" < |
16
+ |---------------------------------------------|----------------------------------|
17
+ | To: | " <a< th=""></a<> |
18
+ | Subject: Accepted: Call with PAE re Epstein | |
19
+ | Date: Thu, 25 Mar 2021 19:42:20 +0000 | |
20
+ | Importance: Normal | |
21
+ | Attachments: unnamed | |
22
+ | | |
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+ | Start Date: 2019-11-19 21:30:00 +0000 |
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+ |------------------------------------------|
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+ | End Date: 2019-11-19 22:00:00 +0000 |
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+ | Location: Es office |
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+ | Class: X-PERSONAL |
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+ | Comment: |
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+ | Date Created: 2019-11-19 23:51:15 +0000 |
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+ | Date Modified: 2019-11-19 23:51:15 +0000 |
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+ | Priority: 5 |
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+ | DTSTAMP: 2019-11-19 20:17:10 +0000 |
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+ | |
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+
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+ Attendee: (USANYS) <I
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00030190)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+
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+ From: ' (USANYS)"
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+
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+ To: (CRM)" < Subject: RE: U.S. Department of Justice investigation
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+
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+ Date: Tue, 16 Jun 2020 15:33:14 +0000
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+
21
+ Thanks, although given that Bloxsome has clearly been sharing his own communications with the Home Office, I think we would be comfortable sharing his.
22
+
23
+ In any event, I have conferred on this end, and we are prepared to accept your advice and allow you to communicate on our behalf with the Home Office in lieu of writing our own letter at this time. I'll await your draft.
24
+
25
+ Thanks very much,
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+
27
+ Fmar RM) c a Sent: Tuesday, June 16, 2020 11:11 AM To: (USANYS) Subject: RE: U.S. Department of Justice investigation
28
+
29
+ M- This is very helpful. It does not look like we can share the Feb email with the Home Office without checking with Bloxsome first. If we share it, he will cite it as just one more reason the US cannot be trusted.
30
+
31
+ Also, I think this process started before Jan 2020. I have my notes at the Embassy, but I think I started working with in the late fall, and the DCM put in one or more calls on this in either Nov or Dec. I'll dig out my notes when I am back in the office later this week.
32
+
33
+ Let me draft an email to and her team and then send it for your consideration. I think it would be better in the first instance to deal with this diplomatically and then escalate if unsuccessful.
34
+
35
+ From: (USANYS) < Sent: Tuesday, June 16, 2020 3:40 PM To: CRM) Subject: FW: U.S. Department of Justice investigation
36
+
37
+ =— You should also be aware of the correspondence below which is what precedes the Valentine's Day email (the highlighting is mine). Obviously, as with the other one, please keep just to yourself for now, pending further discussions about next steps, but this gives you some of the context I was referring to. Many thanks,MI
38
+
39
+ | Begin forwarded message: | | | | |
40
+ |----------------------------------------|--------------|----|------------|----------|
41
+ | From: Gary Bloxsome | | | | |
42
+ | Date: February 5, 2020 at 12:39:15 EST | | | | |
43
+ | To: ' | (USANYS)" | | | |
44
+ | Cc: ' | (USANYS)" 'c | =s | (USANYS)". | > Daniel |
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+
46
+ Cundy , Jennifer Richardson •
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+
48
+ Subject: Re: U.S. Department of Justice investigation
49
+
50
+ Dear
51
+
52
+ Thank you for your email.
53
+
54
+ We will reflect on the position of DOJ and provide you with a considered response shortly.
55
+
56
+ Best.
57
+
58
+ Gary
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+
60
+ # Gary Bloxsome I Partner
61
+
62
+ | | I London I EC4M 7EF<br>I www.blackfords.com | |
63
+ |----------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
64
+ | address. | 8lackfords LLP is a limited liability partnership registered in England & Wales with registered number<br>0025398 at Hill House, 1 Mint Walk, Croydon, CRO lEA. A list of members' names is available at this | |
65
+ | | ODOR: details of how we handle personal data can be found in our privacy Statement | |
66
+ | | Authonsed and regulated by the Solicitors Regulation Authority under number 462078. | |
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+
68
+ | On 4 Feb 2020, at 18:23, | (USANYS) | wrote: |
69
+ |--------------------------|----------|--------|
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+ |--------------------------|----------|--------|
71
+
72
+ ## ( .sternal email: is it safe to open attachments and links•?
73
+
74
+ ### Gary,
75
+
76
+ You are aware of our position, and we do not believe any further rehashing of our prior conversations is productive at this point. That said, we can confirm that it is our standard practice to refrain from publicly commenting on the substance of any witness interview, and we intend to abide by that practice in this case. Beyond that, we can make no commitments. Please advise as to whether Prince Andrew will agree to be interviewed and, if so, when such interview will take place.
77
+
78
+ AIM
79
+
80
+ Regards,
81
+
82
+ Assistant U.S. Attorney Southern District of New York
83
+
84
+ | From: Gary Bloxsome | | |
85
+ |-------------------------------------------------------|----------|-----------------|
86
+ | Sent: Monday, February 03, 2020 10:46 | | |
87
+ | (USANYS) •c•Ma<br>To: | | |
88
+ | Cc:<br>(USANYS)<br>>: | (USANYS) | >; Daniel Cundy |
89
+ | Jennifer Richardson | | |
90
+ | Subject: Re: U.S. Department of Justice investigation | | |
91
+
92
+ Thank you for your email of 30 January 2020.
93
+
94
+ On 10 January 2020 you personally assured me that any contact between the Duke of York and the DOJ was confidential and would remain confidential within the investigation team in the DOJ and FBI. You said: "We don't intend to share either the contents or the existence of the conversation beyond our chain of command in the DOJ. As well as our partners at the FBI. It is confidential within the investigation team and our supervisors." The note I made of what you said about the confidentiality of the interview process is as follows: "We do not publicise the content or existence of any of our interviews. We can't guarantee that anyone might not share it with some other person or it might be shared with other individuals who might come to have knowledge of its existence, but our office does not advise the press of the interview and doesn't advise other interviewees of the fact the interview has taken place or the contents of those discussions. For example, it was reported widely that our office was attempting to interview your client months ago which was inaccurate. We have been working on this request for several weeks now and it has not hit the press. That is consistent with our processes. We take confidentiality very seriously."
95
+
96
+ At no point did you suggest that, because of a press statement made on behalf of the Duke in November 2019, you or your colleagues in the investigation team would feel able to provide a public commentary on the DOJ's views on the degree of cooperation provided by the Duke. DOJ's first contact of any kind with the Duke was in early January 2020, and the first mention of any request for consideration of an interview came solely from you.
97
+
98
+ I object to your wholly inaccurate statement that the Duke has created a public misimpression. The Duke has made it clear that he has a strong desire to cooperate fully with the ongoing investigation by the DOJ. The communications between us were intended to enable him to provide that co-operation. In order for this process to continue, I need to emphasise that we regard the confidential treatment of all contacts between the DOJ and the Duke as essential. We do not wish to have any public pronouncements on what we regard as a voluntary and confidential process. Please confirm that any further communications in connection with the requested voluntary interview will be treated as wholly confidential and the DOJ will offer no further commentary on the Duke's cooperation.
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+
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+ Best
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+
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+ Gary Bloxsome
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+
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+ Gary Bloxsome I Partner
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+
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+ <image001.jrz≥ <image002.jpg≥
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+
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+
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+
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+ Blackfords LLP I London I EC4M 7EF www.blackfords.com
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+
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+ **Slackfords LLP is a limited liability partnership registered in England & Wales with registered number O[325398 at Croydon, CR0 lEA. A list of members' names is available at this address.**
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+
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+ **GDPR: details of how we handle personal data can be found in our Privacy Statement**
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+
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+ **Authorised and regulated by the Solicitors Regulation Authority under number 462078.**
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+
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+ #### External email: is it sale to open attachments and links?
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+
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+ ### Gary,
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+
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+ 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.
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+
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+ 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?"
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+
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+ 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 I 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."
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+
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+ Mr. Berman's statement corrected a public misimpression — created by the Prince himself — that the Prince is cooperating with our investigation.
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+
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+ 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.
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+
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+ Regards,
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+
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+ Assistant U.S. Attorney Southern District of New York
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+
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+ | From: Gary Bloxsome | |
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+ |----------------------------------------------------|-----------------|
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+ | Sent: Tuesday, January 28, 2020 11:59 | |
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+ | (USANYS) <l<br>To:</l<br> | |
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+ | Cc:<br>(USANYS) | >; Daniel Cundy |
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+ | ; Jennifer Richardson | |
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+ | Su ect: e: U.S. Department o Justice investigation | |
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+
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+ # Dear,
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+
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+ Thank you for your email response claiming that US Attorney Berman's statements were factually accurate and did not create a misleading impression.
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+
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+ We only have access to edited video and newspaper reporting of what the US Attorney said. Those reports suggest the US Attorney described the position of the Duke of York and his advisors in misleading, condemnatory and prejudicial terms. US Attorney Berman is quoted as having stated there has been "zero cooperation". This is not an accurate statement of the position. The following are also false statements ascribed to Mr Berman and to the Dal/FBI: "F.B.I. agents and federal prosecutors in New York ... reached out to his lawyers
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+
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+ and asked to interview him. There was no response at all, according to three people familiar with the investigation." (New York Times 27.01.20) and "Geoffrey Berman, a US attorney, said federal prosecutors and the FBI hod asked to interview Prince Andrew about the late paedophile billionaire, but had been met with a wall of silence"(The Telegraph 28.01.20).
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+
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+ Please provide us with an accurate record of the statements made by The US Attorney and/or the DOJ/FBI including a transcript of any relevant questions and answers.
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+
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+ We note from your email that you have not provided any response to our request that you confirm that the DOJ will not be making any further public statements about the Duke of York. We had understood from our conversations with you and from the rules governing media relations that DOJ personnel and the US Attorney would not comment on the nature or progress of any grand jury investigation and in particular would not comment on the willingness of any Subject to make a voluntary statement to the Dal. We ask you to confirm that there will be no further public comment on any contact between the Duke of York and the DO1.
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+
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+ Kind regards
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+
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+ Gary
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+
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+ | Gary Bloxsome I Partner |
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+ |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
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+ | <iimagdiajpg? th="" ≤imagtal)2jpg≥<=""></iimagdiajpg?> |
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+ | I London I EC4M 7EF<br>Blackfords LLP<br>www.blackfords.com |
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+ | Blackfords LLP is a limited liability partnership registered in England & Wales with registered number 0C325398 at<br>Croydon, CRO lEA. A list of members names is available at this address. |
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+ | GDPR: details of how we handle personal data can be found in our privacy Statement |
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+ | Authorised and regulated by the Solicitors Regulation Authority under number 462078. |
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+ | wrote:<br>On 27 Jan 2020, at 22:59,<br>(USANYS) |
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+ | External entail: is it safe to open attachments and links? |
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+ | Gary, |
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+
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+ Our understanding is that U.S. Attorney Berman made a factual statement in response to a specific question that suggested the Duke of York either would or was cooperating, and he responded that to date he has not in fact provided cooperation with our investigation. That is, he corrected the record generally in a factually accurate statement; I don't believe this would create a misleading impression. cooperate, and we look forward to hearing from you when he has made a determination as to whether he is in fact willing to speak with us. I appreciate that you have advised us that your client has a desire to
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+
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+ Regards,
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+
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+ | From: Gary Bloxsome | | |
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+ |--------------------------------------|------------|-----------------|
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+ | Sent: Monday, January 27, 2020 13:44 | | |
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+ | To:<br>(USANYS) < | | |
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+ | Cc:<br>(USANYS) | (USANYS) < | ?; Daniel Cundy |
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+
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+ # ; Jennifer Richardson
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+
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+ ### Subject: Re: U.S. Department of Justice investigation
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+
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+ The press are reporting that Geoffrey S. Berman, the United States Attorney for the Southern District of New York has disclosed what we understood were confidential communications between us and and
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+
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+ It has also been suggested that Geoffrey S. Berman has stated that the Duke of York has not co-operated with the Southern District. As you know we have made it very clear that the Duke of York has a strong desire to cooperate with the ongoing investigation by the DOJ and we are trying to reach a position where we are able to advise him to do so.
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+
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+ We are concerned about the misleading impression that has been created and the effect this has on our ability to advise the Duke to proceed with any voluntary co-operation. Please confirm that the DOJ will not be making any further public statements on this topic.
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+
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+ Thank you.
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+
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+ Gary Bloxsome
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+
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+ # Gary Bloxsome I Partner
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+
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+ | Blackfords LLP I | I London I EC4M 7EF |
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+ |------------------|----------------------|
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+ | | I www.blackfords.com |
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+ | | |
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+
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+ Blackfords LLP is a limited liability partnership registered in England & Wales with registered number 0C325398 at Croydon. CR0 LEA. A list of members names is available at this address.
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+
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+ GDPR: details of how we handle personal data can be found in our Privacy Statement
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+
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+ Authorised and regulated by the Solicitors Regulation Authonty under number 462078.
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+
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+ On 22 Jan 2020, at 17:34, (USANYS) wrote:
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+
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+ External emad: is It sate to open attachments and links!
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+
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+ Gary,
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+
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+ We've received your response. We look forward to hearing whether the Duke of York is willing to speak with us.
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+
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+ thank you,
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+
218
+ From: Gary Bloxsome
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+
220
+ Sent: Wednesday, January 22, 2020 11:35
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+
222
+ To: (USANYS) <
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+
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+
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+
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+ Subject: Re: U.S. Department o Justice investigation
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+
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+ We are very grateful for your offer of assistance. At present we do not believe you can help us but we would welcome a real-time conversation once we have achieved some of the more immediate preliminary tasks, including the need to
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+
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+ gather information from the Royal Household and others. Best
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+
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+ # Gary Bloxsome I Partner Ellackfords LLP London EC4M 7EF www.blackfords.com Blackfords LIP is a limited liability partnership registered in England & Wales with registered number 0C325398 at Croydon, CR0 1E/4. A list of members' names is available at this address. GOPR: 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 20 Jan 2020, at 18:52, (USANYS) wrote:
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+
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+ External entail: is it safe to open attachments and links?
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+
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+ Gary,
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+
238
+ Thank you for your response. It would be useful for us if you were able to help us understand the nature of the issues and procedures with which you are dealing, particularly as it sounds like it will take at least a couple additional weeks to address even minor preliminary issues, which suggests likely additional subsequent time to handle further processes—and without a response to the question of whether he is willing to speak with us, separate from a general desire to cooperate. Our investigation is moving forward expeditiously and so we would be grateful for some understanding of the relevant issues (especially, though not exclusively, to the extent we may be able to assist in their resolution) and would be happy to speak via phone if a real-time conversation would be more conducive to that discussion.
239
+
240
+ thank you,
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+
242
+ | From: Gary Bloxsome <gary hinxsnmepblackfords.com=""></gary> | | | |
243
+ |--------------------------------------------------------------|-----------------------|--------|--------|
244
+ | Sent: Monday, January 20, 2020 11:23 | | | |
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+ | (USANYS) <<br>To: | | | |
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+ | Cc:<br>(USANYS) < | >; | USANYS | Daniel |
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+ | Cundy | ; Jennifer Richardson | | |
248
+ | : epar men o us is investigation<br>Subject: | | | |
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+
250
+ Thank you for your email. The Duke of York has made it clear to us that he has a strong desire to cooperate fully with the ongoing investigation by the DOJ.
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+
252
+ It is our responsibility to deal with the various issues and procedures that arise here that will need to be addressed to enable him to do so. We should be able to deal with at least some of the minor preliminary issues in the next two weeks and we will update you on our progress once we have done so.
253
+
254
+ Regards,
255
+
256
+ Gary
257
+
258
+ ### Gary Bloxsome I Partner
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+
260
+ | <image001 jpg=""> <image002.jpg></image002.jpg></image001> |
261
+ |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
262
+ | I London I EC4M 7EF<br>Blackfords LLP<br>www.blackfords.com |
263
+ | 8lackfords LIP is a limited liability partnership registered in England & Wales with registered number OC325398 a<br>Croydon, CR0 AA. A list of members names is available at this address. |
264
+ | GDPR: details of how we handle personal data can be found in our &say<br>Statement |
265
+ | Authonsed and regulated by the Solicitors Regulation Authority under number 462078. |
266
+ | On 18 Jan 2020, at 01:06,<br>wrote:<br>(USANYS) |
267
+ | External email: is it safe to open attachments and links? |
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+
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+ We write to follow up on our phone conversation of a week ago. Could you please advise regarding status, in particular the initial question, separate from any logistics, of whether you expect your client will be willing to speak with us? And of course please let us know if any additional information would be useful to you.
270
+
271
+ thank you,
272
+
273
+ Gary,
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+
275
+ | From: Gary Bloxsome | | | |
276
+ |-------------------------------------------------------|-----------------------|------------|-----------|
277
+ | Sent: Wednesday, January 08, 2020 07:38 | | | |
278
+ | (USANYS) <<br>To: | > | | |
279
+ | Cc: Male; | | (USANYS) < | >; Daniel |
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+ | Cundy | ; Jennifer Richardson | | |
281
+ | Subject: Re: U.S. Department of Justice investigation | | | |
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+
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+ Thank you for your email.
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+
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+ Friday 10th January at 1400(LDN) time is fine.
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+
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+ Please forward dial in details.
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+
289
+ Kind regards
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+
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+ Gary
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+
293
+ ### Gary Bloxsome Partner
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+
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+ | =a. |
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+ |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
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+ | Blackfords LLP I<br>I London I EC4M 7EF |
298
+ | I www.blackfords.com |
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+ | Blacktur;:s LL,' a a limited<br>partnership registered in England & Wales with registered number<br>OC325398 at<br>Croydon, CR0 lEA. A list of members names is available at this<br>address. |
300
+ | GDPR: details of how we handle personal data can be found in our £uyxLy Statmetli, |
301
+ | Authorised and regulated by the Solicitors Regulation Authority under number 462078. |
302
+ | (USANYS) ca<br>On 7 Jan 2020, at 18:56,<br>wrote: |
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+
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+ External email: is it sale to open attachments and links?
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+
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+ ### Gary,
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+
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+ We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available at 9:00 local time for us (which I believe would be 14:00 your time►. **If that works, we can plan to call you at your office line unless you'd prefer we use another number or a conference line.**
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+
310
+ ### **thank you,**
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+
312
+ | From: Gary Bloxsome | | |
313
+ |---------------------------------------|-------------------------------------------------------|-----------|
314
+ | Sent: Tuesday, January 07, 2020 11:20 | | |
315
+ | To: | (USANYS) •c:M | |
316
+ | Cc:<br>(USANYS) | | >; Daniel |
317
+ | CundY "E | IM<br>• Jennifer Richardson | |
318
+ | | Subject: Re: U.S. Department of Justice investigation | |
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+
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+ **Thank you for your email.**
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+
322
+ **Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.**
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+
324
+ **Kind regards.**
325
+
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+ **Gary**
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+
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+ **Ga Bloxsome Partner**
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+
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+ **Blackfords LLP I I London I EC4M 7EF**
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+
332
+ # www.blackfords.com
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+
334
+ Blackfords LIP is a limited liability partnership registered in England & Wales with registered number O[325398 at Croydon. CR0 lEA. A list of members' names is available at this address.
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+
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+ GDPR: details of how we handle personal data can be found in our Privacy Statement
337
+
338
+ Authorised and regulated by the Solicitors Regulation Authority under number 462078.
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+
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+ | On 4 Jan 2020, at 01:38, | wrote: |
341
+ |--------------------------|--------|
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+ |--------------------------|--------|
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+
344
+ External email: is it safe to open attachments and links?
345
+
346
+ Mr. Bloxsome,
347
+
348
+ Thank you for your response and for confirming your representation. To respond to your question generally, in connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to inquire about his relationship and communications with Jeffrey Epstein and his associates, as well as certain allegations that have arisen publicly and in our investigation to date.
349
+
350
+ Although we recognize we separately have the ability to convey such a request through diplomatic and law enforcement channels, we understand we may also alternatively inquire directly with counsel, when an individual has legal representation. Given your representation, we are inquiring directly with counsel in the first instance.
351
+
352
+ Certainly we can discuss our request in more detail, but we hope this will provide the information you were seeking as a threshold matter, and we look forward to being in touch.
353
+
354
+ Regards,
355
+
356
+ Assistant U.S. Attorney Southern District of New York
357
+
358
+ | From: Gary Bloxsome | |
359
+ |-------------------------------------------------------|-----------------------|
360
+ | Sent: Friday, January 03, 2020 10:30 | |
361
+ | To:<br>(USANYS)<br>C | |
362
+ | Cc:<br>USANYS | >; Daniel<br>(USANYS) |
363
+ | ; Jennifer Richardson<br>Cundy | |
364
+ | Subject: Re: U.S. Department of Justice investigation | |
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+
366
+ Dear Sirs,
367
+
368
+ Thank you for your email dated 2 January 2020.
369
+
370
+ I confirm that we do represent HRH the Duke of York.
371
+
372
+ I would be grateful if you could please clarify what specifically you invite us to contact you about. Kind regards
373
+
374
+ Gary Bloxsome
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+
376
+ | Gary Bloxsome I Partner |
377
+ |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
378
+ | |
379
+ | London I EC4M 7EF<br>Blackfords LLP |
380
+ | I www.blackfords.com |
381
+ | annership registered in England & Wales with registered number<br>Blackfords LLP IS<br>0C325398 at<br>Croydon, CR0 lEA. A list of members names is available at this<br>address. |
382
+ | GOPR: details of how we handle personal data can be found in our Privacy Statement |
383
+ | Authorised and regulated by the Solicitors Regulation Authonty under number 462078. |
384
+
385
+ External email: is it safe to open attachments and links?
386
+
387
+ Mr. Bloxsome,
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+
389
+ We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of Justice, Southern District of New York. We have been advised that you currently represent HRH The Duke of York. Could you please advise whether that is correct? We — my colleagues and I — can be reached anytime at these email addresses, or please let us know if you would prefer to set up a time to discuss via phone.
390
+
391
+ On 2 Jan 2020, at 18:54, (USANYS) > wrote:
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+
393
+ Regards,
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+
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+
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+
397
+ Assistant U.S. Attorney Southern District of New York
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+ Map Address:
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ ---
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+
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+
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+
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+ I requested from MCC a complete list of all commissary purchases that Epstein made.
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+
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+ Sent from mobile device, please excuse typos.
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00031626)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+
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+ | From: |
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+ |-----------------------------------------------------------|
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+ | To: |
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+ | Cc: |
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+ | |
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+ | Subject: for witnesses |
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+ | Date: Wed, 28 Apr 2021 15:43:53 +0000 |
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+ | Embedded: Notes_from_4_28_2021_call_with_PBPD_Captain=msg |
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+ | |
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+ | M |
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+
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+ Would you please put the attached into a non-testifying witness folder for
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+
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+ Thanks
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+ ---
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+ ---
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+
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+
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+
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+ These 2 photos are taken of the identifying markers associated with the iPad recovered from him by customs.
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+
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+ ### iPad
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+
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+ FCC ID:BCA1652 IC 579C A155::
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+
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+
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+
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+
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+
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+ our bosses are asking us if we have any better info now about any current phone numbers and/or emails tor Epstein, with the hope of getting tolls, subscriber info, heading info, etc. if we can.
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+
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+ In connection with the arrest, did he provide any current contact info? And what was the number for the cell phone that was seized, if we know (and if we don't, could you please send the IMEI and any other identifying or registration numbers)? Thanks very much.
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+
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+ Assistant U.S. Attorney Southern District of New York
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+
15
+ To: Cc: Fran: Sent: Mon 8(12/2019 7:14:35 PM Subject: I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 8: 45 am (S/W) TEXT htm 2019 08 12 15 10 43 df
16
+
17
+ UM companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (SIW)
18
+
19
+ Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M companion was utilized).
20
+
21
+ Associate Warden MCC New York 150 Park Row New York NY 10007
22
+
23
+
24
+
25
+ EFTA00033873
content-documents/ds8/ef/EFTA00034504.md ADDED
@@ -0,0 +1,21 @@
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00034504)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
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+ ---
14
+
15
+ To: From: Sent: Sat 8/10/2019 7:41:05 PM Subject: Referral TEXT htm 2019 08 10 15 39 08 pdf
16
+
17
+ Attached is the referral.
18
+
19
+
20
+
21
+ EFTA00034504
content-documents/ds8/ef/EFTA00034902.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00034902)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
+ eftaNumber: "EFTA00034902"
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+ ---
14
+
15
+ | | Shift-Day-Date: M/W Thursday, July 18, 2019<br>Beginning Count: 784 | | SHU: 75/4 | | | | | |
16
+ |------------------------------------------------------------------|------------------------------------------------------------------------------|-----|-----------|--|--|--|--|--|
17
+ | Daily Sensitive Information: | | | | | | | | |
18
+ | M/W | on Suicide Watch w/inmate companion<br>I/N1 | | | | | | | |
19
+ | | I/M Burnett #76254-054 at Local Hospice W/USMS Guards | | | | | | | |
20
+ | TIME | CHRONOLOGICAL EVENTS | | | | | | | |
21
+ | | 12:00 AM Lieutenant<br>assumes duties as<br>the<br>Morning<br>Watch | 784 | 75/4 | | | | | |
22
+ | | Operations Lieutenant. The fire alarm and sprinkler system are | | | | | | | |
23
+ | | operational. PREA announcement conducted<br>via<br>the<br>Institution | | | | | | | |
24
+ | | Public Address System and/or Radio. Restraint Equipment Cage | | | | | | | |
25
+ | | inventory conducted. All equipment accounted for. Metal Detector | | | | | | | |
26
+ | | of<br>checks<br>conducted.<br>All<br>operative<br>w/the<br>exception<br>Rear | | | | | | | |
27
+ | | Gate/Facilities/R&D.<br>Roof Check completed. All secure. Temporary | | | | | | | |
28
+ | | Chit Inventory: #1:2; #2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0 | | | | | | | |
29
+ | | Note: Control Center Sallyport Door malfunctioning.<br>Door manually | | | | | | | |
30
+ | | operated. | | | | | | | |
31
+ | 12:00 | Institution Count in progress | | | | | | | |
32
+ | AM<br>12:00 | NYPD Phone Check #2748 | | | | | | | |
33
+ | AM | | | | | | | | |
34
+ | 12:12 | Body Alarm testing in progress | | | | | | | |
35
+ | AM | | | | | | | | |
36
+ | 12:26 | Body alarm testing completed | | | | | | | |
37
+ | AM | | | | | | | | |
38
+ | 12:30 | Watch Calls cont. | | | | | | | |
39
+ | AM | | | | | | | | |
40
+ | 12:48 | Good Verbal count announced | | | | | | | |
41
+ | AM | | | | | | | | |
42
+ | 12:52 | Clear Institution count announced | | | | | | | |
43
+ | AM | | | | | | | | |
44
+ | | 3:00 AM Institution Count in progress<br>3:25 AM Good Verbal count announced | | | | | | | |
45
+ | | 3:27 AM Clear Institution count announced | | | | | | | |
46
+ | | 5:00 AM Institution Count in progress | | | | | | | |
47
+ | | 5:43 AM Good Verbal count announced | | | | | | | |
48
+ | | 5:43 AM Clear Institution count announced | | | | | | | |
49
+ | | 8:00 AM Relieved of duties by Lt.<br>as D/W Operations Lieutenant | | | | | | | |
50
+ | STG International Terrorist phone calls monitored: | | | | | | | | |
51
+ | | WITSEC inquiry(s) was/were received during my tour of duty: | | | | | | | |
52
+ | The following Inmate(s) were placed in Administrative Detention: | | | | | | | | |
53
+ | Name | Unit<br>Reg: Number<br>Reason<br>Time | | AD Order | | | | | |
54
+ | | | | | | | | | |
55
+ | | | | | | | | | |
56
+ | Ending Count: 784 SHU: 75; 10-South: 04; SHU OBS: 00; | | | | | | | | |
57
+ | Ops Lt. | Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00 | | | | | | | |
58
+
59
+ ### CONFIDENTIAL SDNY_00012834
60
+
61
+ EFTA00034902
62
+
63
+ | | | SHIFT-DAY-DATE: D/W - Thursday, July 18, 2019 | Beginning Count: 784 | | | SHU:75/4 | | |
64
+ |---------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------|----------------------|---------------------|-------|----------|--|--|
65
+ | i)dfli | Daily Sensitive Information: | | | | | | | |
66
+ | | I/M<br>on Psych Ohs. w/inmate companion. | | | | | | | |
67
+ | | I/M<br>on Suicide Watch w/inmate companion | | | | | | | |
68
+ | | I/M<br>on Suicide Watch w/inmate companion | | | | | | | |
69
+ | | I/M Burnett 876254-054 at Gold crest nursing facility w/USAB Guards.<br>784<br>75/4 | | | | | | | |
70
+ | | assumes duties as the Day Watch Operations<br>8:00 AM Lieutenant<br>system are operational.<br>Lieutenant. The fire alarm and sprinkler | | | | | | | |
71
+ | | Unable to conduct PREA announcement<br>over the Institution Public | | | | | | | |
72
+ | | | Address System, due to, system malfunction. | | Restraint Equipment | | | | |
73
+ | | | Cage inventory conducted. All equipment | accounted for. Metal | | | | | |
74
+ | | w/the exception of Rear<br>Detector checks conducted.<br>All operative | | | | | | | |
75
+ | | Gate. | Roof Check completed. All secure. | Temporary Chit | | | | | |
76
+ | | | Inventory: #1:0; #2:5; #3:5; #4:6; | #5:6; #6:5; Hosp:O | | | | | |
77
+ | | Daily Hand Stamp :GPKJ/RIGHT HAND<br>8:00 AM NYPD Phone Check #2352 | | | | | | | |
78
+ | | 8:23 AM Body Alarm Test Initiated | | | | | | | |
79
+ | | 8:30 AM AM Census Count | | | | | | | |
80
+ | | 8:50 AM Body Alarm Testing Complete | | | | | | | |
81
+ | | 9:43 AM -1 Out to court: Goswami #75954-054 | | | | | 783 75/4 | | |
82
+ | | 9:56 AM -1 HLD REMOVE: Hunt #70119-054 | | | | 782 | 74/4 | | |
83
+ | | 10:30 AM Mass Unit shakedown conducted on 11 south. | | | | | | | |
84
+ | | 10:52 AM -1 L-HOSP : Sepiashvili #85956-054 | | | | 781 | 74/5 | | |
85
+ | | 11:00 AM Mainline feeding in progress | | | | | | | |
86
+ | | 12:30 AM PM Census count | | | | 781 | 74/4 | | |
87
+ | | 1:30 PM +1 L-HOSP return: Sepiashvili #85956-054 | | | 782 | 74/4 | | | |
88
+ | | 1:45 PM Inmate Sellers #53267-054 placed on Dry Cell watch (ZA) | | | 782 | 75/4 | | | |
89
+ | | 2:23 PM -1 L-Hosp; Schifano #17437-104 | | | 781 | 75/4 | | | |
90
+ | | 3:45 PM Institutional lockdown for count | | | 781 | 75/4 | | | |
91
+ | | 4:00 PM Relieved of duties by Lt. =as<br>E/W Operations Lieutenant. | | | | | | | |
92
+ | | | Visitation: | 5-North | | | | | |
93
+ | | Inmates | Adults | Children | | Total | | | |
94
+ | | 17 | 21 | 5 | | 43 | | | |
95
+ | | ION SCANNING TESTED HITS: 0 | | | | | | | |
96
+ | STG/High Alert phone calls monitored: 0 | | | | | | | | |
97
+ | WITSEC inquiry(s) was/were received during my tour of duty: 0 | | | | | | | | |
98
+
99
+ The following Inmate(s) were placed in Administrative Detention: 0
100
+
101
+ # CONFIDENTIAL SDNY_00012835
102
+
103
+ | Name | Reg Number | Reason | Unit | TIME | A/D Order |
104
+ |------------------|------------|-------------------------------------------------------------------------------|------|---------------------------------------------------------|-----------|
105
+ | | | | | | |
106
+ | Ops Lt<br>Act Lt | | 75;<br>Ending Count:781<br>SHU:<br>;<br>Local Hosp: 01;<br>H/A<br>OBS:<br>01; | | 10-South: 04; SHU OBS: 00;<br>B/A OBS: 00; Dry Cell: 01 | |
107
+
108
+
109
+
110
+ EFTA00034904
111
+
112
+ | | | | SHIFT-DAY-DATE: E/W - Thursday, July 18, 2019 Beginning Count: 781 | | SHU:75/<br>4 | | | |
113
+ |----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--------------------------------------------------------------------|-----|--------------|----------|-----|-----------|
114
+ | Eli,' | Daily Sensitive Information.<br>I/M<br>on Suicide Watch w/inmate companion<br>I/M Burnett #76254-054 at Goldcrest nursing facility w/USMS<br>Guards.<br>I/M Sellers *53267-054 on dry cell w/staff observation | | | | | | | |
115
+ | TIME | | | CHRONOLOGICAL EVENTS | | | | B/C | SHU |
116
+ | 4:00 PM | Lieutenant<br>assumes duties as the Evening Watch<br>Operations Lieutenant. The fire alarm and sprinkler system are<br>operational. Unable to conduct PREA announcement over the<br>Institution Public Address System, due to, system malfunction.<br>Restraint Equipment Cage inventory conducted. All equipment<br>accounted for. Metal Detector checks conducted. All operative<br>w/the exception of Rear Gate.<br>Roof Check completed. All secure.<br>Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0; | | | 781 | 75/4 | | | |
117
+ | | 4:00 PM Institution count in progress. | | | | | | | |
118
+ | | 4:00 PM NYPD Phone Check *1356. | | | | | | | |
119
+ | | 4:35 PM Body Alarm testing in progress. | | | | | | | |
120
+ | | 4:55 PM Body alarm testing completed. | | | | | | | |
121
+ | | 5:13 PM Good verbal announced | | | | | | | |
122
+ | | 5:20 PM Clear institutional count. | | | | | | | |
123
+ | | 5:28 PM +1 L-Hosp return; Schifano #17437-104 | | | 782 | 75/4 | | | |
124
+ | | 5:29 PM +1 Court Return; Goswami #75954-054 | | | | 783 75/4 | | | |
125
+ | | 5:50 PM +4 new commits; Taveras #30772-069, Russell #87034-054, Hussett<br>#62670-054, and Arrera Moreno #23789-057 | | | | 787 75/4 | | | |
126
+ | | 6:00 PM Watch call in progress | | | | | | | |
127
+ | | 6:50 PM I/M Sellers #53267-054 produced 1 clean bowel movement | | | | | | | |
128
+ | | 7:00 PM 7 inmates from SHU to general population | | | | | 787 68/4 | | |
129
+ | | 8:00 PM Trash run commenced. | | | | | | | |
130
+ | | 9:15 PM Trash run complete. | | | | | | | |
131
+ | 10:00<br>PM | Institutional count in progress. | | | | | | | |
132
+ | | Good verbal count announced.<br>10:41<br>PM | | | | | | | |
133
+ | | 10:45<br>Clear institutional count announced.<br>PM | | | | 787 68/4 | | | |
134
+ | | Relieved of duties by<br>as M/W Operations Lieutenant.<br>12:00<br>AM | | | | 787 68/4 | | | |
135
+ | VISITING: 9N | | | | | | | | |
136
+ | | INMATES | | ADULTS | | CHILDREN | TOTAL | | |
137
+ | | 21 | | 29 | | 8 | | 58 | |
138
+ | STG/High Alert phone calls monitored: 0<br>WITSEC inquiry(s) was/were received during my tour of duty: 0 | | | | | | | | |
139
+ | The following Inmate(s) were placed in Administrative Detention: 0 | | | | | | | | |
140
+ | | REG NUMBER<br>NAME<br>I | | REASON | | UNIT<br>I | TIME | | A/D ORDER |
141
+
142
+ # CONFIDENTIAL SDNY_00012837
143
+
144
+ | Ops. Lt. | Ending Count:786 ; SHU: 78; 10-South: 04; SHU OBS: 00; | |
145
+ |----------|---------------------------------------------------------|--|
146
+ | Act. Lt. | Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00; | |
147
+ | | B/A SHU: 00 | |
148
+
149
+ CONFIDENTIAL SDNY_00012838
150
+
151
+ EFTA00034906
content-documents/ds8/ef/EFTA00035361.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00035361)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
7
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+ ---
14
+
15
+ This is the approved press release. Please release the PDF version only.
16
+
17
+ 8/10/2019 10:54 AM > »
18
+
19
+ The attached PDF is the final version that I will now send to all the reporters who contacted OPA (about 50 so far).
20
+
21
+ will have MCC NY send this PDF to media who contacted MCC NY.
22
+
23
+ The MS Word will not be released externally, but is provided to OLA in case helpful to them to have language for possible Member inquiries next week by email, etc.
24
+
25
+ Thanks,
26
+
27
+ Public Information Office Federal Bureau of Prisons
content-documents/ds8/ef/EFTA00036658.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00036658)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ ---
14
+
15
+
16
+
17
+ Attached
18
+
19
+ Regional Director Northeast Re ion
content-documents/ds8/ef/EFTA00036669.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00036669)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
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+ ---
14
+
15
+
16
+
17
+ Embedded: unnamed; unnamed(1); unnamed(2); unnamed(3); unnamed(4)
18
+
19
+ Attached
content-documents/ds8/ef/EFTA00037783.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00037783)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ ---
14
+
15
+ | From: "a | |
16
+ |---------------------------------------|--|
17
+ | To: | |
18
+ | | |
19
+ | Cc: "MMI=MINIIMMI=MINIMI> | |
20
+ | Subject: RE: Phone records | |
21
+ | Date: Wed, 01 May 2019 22:59:36 +0000 | |
22
+ | Importance: Normal | |
23
+ | | |
24
+
25
+ Thanks Mandy.
26
+
27
+ It looks like the subscriber records for the number start in November 2005, and the messages we looked at with the number are from October 2005. Looking at the tolls, those start in '04.
28
+
29
+ Could you please let me know who the service provider was in 10105? Thanks.
30
+
31
+ | From: |
32
+ |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
33
+ | Sent: Wcdn sd:n.\I<br>_J,t i<br>) ( c I<br>I |
34
+ | To: |
35
+ | |
36
+ | Cc: |
37
+ | Subject: Phone records |
38
+ | Folder 31E-MM-108062-1A SEC.00x<br>-page 172-173 subscriber info for<br>ICI<br>-page 312 subscriber info<br>and records follow Folder 31E-MM-108062-1A SEC.009<br>-page 413-476 (records from<br>and multiple calls to/from |
39
+
40
+ Special Agent FBI New York VCAC/Human Trafficking
content-documents/ds8/f0/EFTA00010199.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00010199)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
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13
+ ---
14
+
15
+
16
+
17
+ Not a problem.
18
+
19
+ Best,
20
+
21
+ >>> PM >» Hi all, " < IIMIE> 12/3/2020 5:24
22
+
23
+ Today our office is sending via FedEx a replacement drive for Ghislaine Maxwell, which should arrive at the MDC tomorrow. This drive will replace the drive that Maxwell recently dropped and broke, and the accompanying cover letters are attached. Would you please make sure Maxwell is given access to this drive?
24
+
25
+ Would you please mail the broken drive back to our office? It can be mailed to the below address:
26
+
27
+ Paralegal Specialist U.S. Attorneys Office, SDNY
28
+
29
+ New York, NY 10007
30
+
31
+ Thanks very much, as always, for your help.
32
+
33
+ Best,
34
+
35
+ Assistant United States Attorney Southern District of New York
36
+
37
+ New York, NY 10007
38
+
39
+ mailto:
content-documents/ds8/f0/EFTA00010435.md ADDED
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1
+ ---
2
+ title: "DOJ Epstein Files, Data Set 8 (EFTA00010435)"
3
+ source: "DOJ Epstein Files, Data Set 8"
4
+ sourceUrl: "https://www.justice.gov/epstein"
5
+ date: "2026-01-01"
6
+ category: "DOJ Data Set"
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+ ---
14
+
15
+ ## U.S. Department of Justice
16
+
17
+ United States Attorney Southern District of New York
18
+
19
+ 86 Chambers Street New York, New York 10007
20
+
21
+ April 21, 2020
22
+
23
+ By Electronic Mail
24
+
25
+ Roberta A. Kaplan Ka Ian Hecker & Fink LLP
26
+
27
+ New York, NY 10118
28
+
29
+ Re: Request for Information Relating to Jeffrey Epstein
30
+
31
+ Dear Ms. Kaplan:
32
+
33
+ I write in response to the your letter dated February 25, 2020, seeking documents from the Department of Justice ("DOJ") related to Jeffrey Epstein and plaintiff Jane Doe in Doe v. Estate of Jeffrey E. Epstein, No. 19-cv-8673 (S.D.N.Y.). As noted in my previous letter dated January 6, 2020, DOJ's response to your request is governed by federal regulations, referred to as "Touhy regulations." See United States a rel. Touhy v. Ragen, 340 U.S. 462 (1951). Pursuant to these regulations, the United States Attorney has authorized DOJ to provide certain documents responsive to your request. Please find electronic versions of these documents enclosed. The password for these documents will be sent to you by separate cover.
34
+
35
+ The enclosed documents are as follows:
36
+
37
+ - Pages numbered DO.1_001-005 are a report of service of a grand jury subpoena on Jane Doe.
38
+ - Pages numbered DO.1_006-007 are a report of service of a grand jury subpoena on Jane Doe.
39
+ - Pages numbered DOJ_008-009 are a report of service of a grand jury subpoena on Jane Doe.
40
+ - Pages numbered DO.1_010-076 are a biographical report of Jane Doe. Pages have been redacted to exclude non-responsive material and references to third parties.
41
+ - Pages numbered DO,1_077-078 are a report of contact between Jane Doe and agents of the Federal Bureau of Investigation.
42
+ - Pages numbered DO,1_079-080 are a report of contact between Jane Doe and agents of the Federal Bureau of Investigation.
43
+ - Pages numbered DO,1_081-087 are a document retrieved from an electronic search of a device in Epstein's New York residence in 2019.
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+ - Pages numbered DO,1_088-091 are pages from a document obtained in approximately April 2005 from discarded trash located outside the Palm Beach residence occupied by Jeffrey Epstein.
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+
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+ Please contact me once you have had a chance to review this letter if you would like to discuss the issues herein further.
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+
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+
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+
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+ Sincerely,
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+
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+ GEOFFREY S. BERMAN United States Attorney for the Southern District of New York
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+
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+ | nited States Attorney<br>Assistant | |
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+ |------------------------------------|--|
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+ | | |
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+ | | |
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00011095)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ ---
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+
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+
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+
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+ Good afternoon-
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+
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+ Attached please find courtesy copies of today's ECF filings.
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+
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+ Re ards-
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00013183)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ ---
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+
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+ | From:<br>To: | |
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+ |--------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
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+ | Subject: w.: | equestei Document |
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+ | | Date: Sun, 11 Aug 2019 15:01:55 +0000 |
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+ | | Attachments: 30_MINUTE ROUNDS 8-8-19.pdf; 30_MINUTE_ROUNDS_8-9-19.pdf;<br>30 MINUTE-<br>ROUNDS 8-10-19.pdf; PHOTOGRAPHS_OF_EPSTEIN_8-10-2019.pdf;<br>TRTU-SCOPCLOGS.pdfi Staff Roster 8-9-I9.pdf; Staff Roster 8-10-19.pdf;<br>Staff Emergency_Contacts.pdf; Sentry_Documentation.pdf |
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+
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+ Forwarded messa e From: Date: Aug 10, 2019 10:54 PM Sub To: Cc: ect: Re. uested Docu
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+ ---
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+ title: "DOJ Epstein Files, Data Set 8 (EFTA00013552)"
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+ source: "DOJ Epstein Files, Data Set 8"
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+ sourceUrl: "https://www.justice.gov/epstein"
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+ date: "2026-01-01"
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+ category: "DOJ Data Set"
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+ ---
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+
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+ | From• | |
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+ |--------------------|---------------------------------------|
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+ | To• | |
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+ | Subject: Epstein | |
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+ | | Date: Wed, 28 May 2008 15:28:45 +0000 |
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+ | Importance: Normal | |
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+
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+ ### •
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+
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+ In response to the possible further delay in the prosecution of Mr. Epstein, we have listed below the reasons why this would have a negative impact on the Government's case:
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+
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+ The statute of limitations issue is the state statute of limitations. According to Detective the statute of limitations is three years from the time of reporting. The statute of limitations will begin to expire in Fall 2008 for five of the 16 victims listed in the indictment. The issue is implicated in two ways. First, because of the state's leniency for the first set of girls, the additional girls have been presented only to us for prosecution. If we cannot go forward, then there will be no prosecution of those crimes. (In response to the argument that Joe should just present them now, we believe that some of the victims are unknown to the defense and disclosing them further weakens our case by allowing them to depose and harass those victims.) Second, our "state resolution" of the case requires Mr. Epstein to plead to something that hasn't been charged yet so further delay will allow him to escape one of the terms of the deal he signed several months ago. (There is also a statute of limitations on the private cause of action under 2255 pursuant to which he must pay damages to the girls. The delay will allow him to escape responsibility for that term, too.)
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+
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+ ### Other reasons:
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+ The victims are getting older. Clearly one of Mr. Epstein's arguments will be that he did not know they were minors. The older they are when they testify the more plausible Epstein's argument becomes.
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+ Several of the victims have relocated to other areas of the country which may become difficult should the case proceed to trial.
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+ The girls deserve swift justice so they can move on with their lives. The continued delay has had profound effects upon many of their lives is just one example).
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+ The delay so far has led many of the victims to reach out to private lawyers which, in turn, let's Mr. Epstein's counsel argue that they are only in it for money.
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+ The grand jury we are using will expire soon. We have already presented more than a dozen hours of testimony and the grand jury is invested and wants to indict.
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+ Why give him more time? He has already been afforded more than a year's delay. This is not a white collar or other nonviolent crime. This is a child exploitation crime with more than 20 known child victims. We are mandated by statute and DOJ policy to prosecute those cases vigorously and in a timely fashion - whether the children were prostitutes or unwilling victims.
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+ the state trial for Mr. Epstein is set for early July 2008. I'm unsure of the legal issues that may arise from the state prosecution and the effect they may have on the federal prosecution. Thank you for the updates and please let us know if we can be of further assistance.