seed: committed site content tree, sharded for HF dir limits (part 15)

content-documents/ds8/be/EFTA00038799.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038799)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038799"
+ocrPages: 2
+ocrChars: 2076
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+parseTier: "internal"
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+---
+
+### Re: Video Conference
+
+
+
+How does Friday January 29th at 2pm (New York time) work for you?
+
+Let us know,
+
+| a                                                                                                                                                                                                                  |
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| > On Jan 16, 2021, at 20:07,<br>wrote:                                                                                                                                                                             |
+|                                                                                                                                                                                                                    |
+| > Hey                                                                                                                                                                                                              |
+|                                                                                                                                                                                                                    |
+| > As per our conversation I've CC'd my partner<br>from the FBI. We look forward to<br>speaking with you something during the week of January 25th. Good luck next week and let us know<br>what works best for you. |
+|                                                                                                                                                                                                                    |
+| > Thanks,                                                                                                                                                                                                          |
+
+- > a

content-documents/ds8/bf/EFTA00011074.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00011074)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00011074"
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+---
+
+| From: Chris Dilorio<br>To: ' |  |
+|------------------------------|--|
+|                              |  |
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+
+## Subject: Apollo/ Epstein!Kushner connection Date: Sat, 13 Apr 2019 17:30:57 +0000
+
+Find a shell Find a fraud Enviromental Solutions Worldwide Inc https://www.sec.gov/cgi-bin/browse-edgar? action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
+
+Florida? Pennsylvania? Or Canada? Welcomed on Cromwell/Wimpfheimer OTCM
+
+De registered in 2015 and Frozen in time Literally http://eswgroup.com/esw-group-corporate/our-board/
+
+| Our Board - ESW Group®                                                                                                                                                                                                                                                                                                              |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| MARK YUNG Mr. Yung is Co-Founder and Managing Principal of<br>OCV Management, LLC ("OCV"), an investor, owner and operator<br>of technology and life science companies based in Los Angeles.<br>Previously, Mr. Yung was a Managing Director at Orchard Capital<br>Corp., a firm he joined in 2006. Through his affiliation with [1 |
+| eswgroup.com                                                                                                                                                                                                                                                                                                                        |
+
+Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al Then,
+
+There's this:
+
+Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade? The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
+
+wait for it
+
+Leon Black/Apollo Environmental Solutions Worldwide
+
+https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
+
+Enter the Amicus blocking release of Epstein dots Krieger, Kim and Lewin https://www.kkIllp.com/
+
+Krieger Kim & Lewin LLP
+
+We are committed to providing the highest level of partner-driven representation in order to efficiently achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United States Government.
+
+www.kkIllp.com
+
+## Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
+
+#### Now,
+
+# it gets VERY interesting
+
+https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.html
+
+| Trump: Kushner's security clearance is up to<br>Kelly                                                                                                    |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------|
+| Kushner even discussed the possibility of a White House job for<br>the founder of private equity firm Apollo, the New York Times<br>reported on Tuesday. |
+| www.cnbc.com                                                                                                                                             |
+
+## Where another Milken protege/Apollo founding partner Josh Harris was considered for a White House job
+
+"Coindences"
+
+https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-companyL
+
+| SEC dropped probe month after firm aided<br>Kushner company                                                                                                                                                 |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| The feds last year dropped an investigation into a financial<br>company a month after the firm gave Jared Kushner's family real<br>estate business a \$180 million loan, a new report said Friday.<br>There |
+| nypost.com                                                                                                                                                                                                  |
+
+Oh, baby \$60 billion+ inflows in 2018 for Apollo https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports-Quarter-2018
+
+
+
+Mr's Krieger,Kim,Boltz et al: Discovery will be a hoot!
+
+Fucking A I am good Cheers! Christopher Dilorio

content-documents/ds8/bf/EFTA00013250.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00013250)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+ocrPages: 2
+ocrChars: 497
+ocrElapsed: 0.3
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+---
+
+
+
+| Sender:                                                        |
+|----------------------------------------------------------------|
+| Subject: Re: Epstein SW returns                                |
+| Messa e-Id: <3430E72C-113B-4F38-AB40-C13D5359BBCB®usa.doj.gov> |
+| To:                                                            |
+| Cc:                                                            |
+| Cc:                                                            |

content-documents/ds8/bf/EFTA00013464.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00013464)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00013464"
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+ocrChars: 444
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: | (USANYS) 3" alMIE>                         |
+|-------|--------------------------------------------|
+| To:   | (USANYS)" alMIE>                           |
+|       | Subject: Automatic reply: UMR - Epstein/DB |
+|       | Date: Thu, 19 Sep 2019 12:26:02 +0000      |
+
+I will be out of the office on work travel until September 20th. I will be checkin email intermittently, but if you need urgent assistance before then, please contact a

content-documents/ds8/bf/EFTA00014611.md

@@ -0,0 +1,27 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014611)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014611"
+ocrPages: 4
+ocrChars: 412
+ocrElapsed: 0.4
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+and put the disc in an envelope addressed to:
+
+Special Agent Detective •
+
+If it's possible to get the disc by 11:30, we'll give the disc to at the conference, or if not, if you could put the envelope with security and reply all that it's ready, they can pick up when convenient.
+
+thanks,
+
+
+
+Assistant U.S. Attorney Southern District of New York 212.637.2415

content-documents/ds8/bf/EFTA00016927.md

@@ -0,0 +1,25 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00016927)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00016927"
+ocrPages: 2
+ocrChars: 305
+ocrElapsed: 0.3
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: To:
+
+Subject: new arty / victims
+
+Date: Tue, 03 Dec 2019 23:08:18 +0000
+
+I don't think Jordan Merson has been on our radar at all, so just flagging ...
+
+https:Thypost.com/2019/12/03/jeffrey-epstein-accused-of-sexually-abusing-9-more-women-suit/
+
+Assistant U.S. Attorney Southern District of New York

content-documents/ds8/bf/EFTA00017867.md

@@ -0,0 +1,40 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00017867)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00017867"
+ocrPages: 0
+ocrChars: 1450
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Thanks very much. See attached. As to the second attachment (the blackbook), we only showed her page 19 of the attached PDF. When you send this 302, please be sure to include whatever attachments you include to the 302. Thanks again!
+
+| From:                                      |  |  |
+|--------------------------------------------|--|--|
+| Sent: Thursday, September 9, 2021 12:40 PM |  |  |
+| To:                                        |  |  |
+| Cc:                                        |  |  |
+| Subject: Re: Notes from last week          |  |  |
+
+No problem. I'm not in the office today but will be back tomorrow and I can send all of my notes along. Can you please send me the documents we discussed that we're shown during the interview that was just me and you present for? Once I have those I can finalize the 302 and send that to you tomorrow as well once it gets approved.
+
+On Sep 9, 2021, at 11:58, wrote:
+
+CAUTION! EXTERNAL SENDER
+
+STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide user ID or password. Suspicious? Please report to this email address: reportphishing(drivpd.org
+
+## Hi
+
+I know you guys are still working on the 302s from out meetings last week, but can you please send us the notes from the meetings last week?
+
+Thanks,
+
+Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 Tel:

content-documents/ds8/bf/EFTA00018841.md

@@ -0,0 +1,77 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018841)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00018841"
+ocrPages: 0
+ocrChars: 2704
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Good afternoon ,
+
+Our Counsel had a further question regarding the subpoena. In the subpoena, it states the Sacramento County Clerk/Recorder is to appear in person to testify, and produce the requested record, at the U.S. District Court for the Southern District of New York. Is this a requirement, or will presentation of the record to your office suffice?
+
+Your assistance in this matter is greatly appreciated.
+
+Thanks,
+
+## Andrew B. Graham
+
+Deputy Clerk/Recorder Sacramento County Clerk/Recorder
+
+
+
+Subject: RE: Court Subpoena
+
+I just spoke with our Counsel regarding the subpoena. She agrees that, since this is in regards to a federal criminal case, the record should be issued at no fee. We will need an vital record application completed. The application can be completed in our office by one of your representatives. As an alternative, please complete the attached application form and email back to me. After receiving the completed application, we can process the request and mail it immediately to the address of your choosing. The application will need to be signed, but there is not a requirement that the application be notarized.
+
+If you have any questions, please feel free to contact me.
+
+Thanks,
+
+## Andrew B. Graham
+
+Deputy Clerk/Recorder Sacramento County Clerk/Recorder
+
+
+
+From: Graham. Andrew Sent: Monday, October 4, 2021 12:25 PM To:
+
+Cc: Subject: FW: Court Subpoena
+
+You can reach me between 8-5 (Pacific Time), Monday thru Friday.
+
+Thanks,
+
+## Andrew B. Graham
+
+Deputy Clerk/Recorder Sacramento County Clerk/Recorder
+
+
+
+| From:                                  |                   |                              |   |
+|----------------------------------------|-------------------|------------------------------|---|
+| Sent: Monday, October 4, 2021 11:43 AM |                   |                              |   |
+| To: Hermison. Jon                      | ; Colston. Noriko | <m< td=""><td>&gt;</td></m<> | > |
+| Cc                                     |                   |                              |   |
+| Subject: Court Subpoena                |                   |                              |   |
+|                                        |                   |                              |   |
+
+EXTERNAL EMAIL: If unknown sender, do not click links/attachments.
+
+Good afternoon,
+
+I'm reaching out regarding the attached subpoena, which was served on your office in connection with an upcoming criminal trial in the United States District Court for the Southern District of New York. I understand there have been some questions regarding compliance. Could you please let me know your availability for a call?
+
+Thank you,
+
+es Attorney
+
+Southern District of New York

content-documents/ds8/bf/EFTA00018997.md

@@ -0,0 +1,260 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018997)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00018997"
+ocrPages: 0
+ocrChars: 32029
+ocrElapsed: 0.0
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| UNITED STATES DISTRICT COURT<br>SOUTHERN DISTRICT OF NEW YORK |   |                 |
+|---------------------------------------------------------------|---|-----------------|
+| UNITED STATES OF AMERICA,                                     | x |                 |
+| v.                                                            |   | 20 Cr. 330 (MN) |
+| GHISLAINE MAXWELL,                                            |   |                 |
+| Defendant.                                                    |   |                 |
+|                                                               | x |                 |
+
+#### REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX
+
+Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364
+
+Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
+
+Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100
+
+Attorneys for Ghislaine Maxwell
+
+# TABLE OF CONTENTS
+
+| TABLE OF CONTENTS<br>ii                                                              |
+|--------------------------------------------------------------------------------------|
+| TABLE OF AUTHORITIES<br>iii                                                          |
+| TABLE OF EXHIBITS                                                                    |
+| Factual Background<br>1                                                              |
+| 1<br>Argument                                                                        |
+| I.<br>The Government's violation of the Fourth Amendment requires suppression<br>1   |
+| A.<br>Maxwell has standing.<br>1                                                     |
+| B.<br>There is no good faith.<br>5                                                   |
+| C.<br>The government's inevitable discovery doctrine fails<br>5                      |
+| II.<br>The Government's violation of Manindell requires suppression.<br>7            |
+| III.<br>The Government's violation of the Fifth Amendment requires suppression<br>10 |
+| IV. The Court should hold an evidentiary hearing<br>13                               |
+| CONCLUSION<br>13                                                                     |
+| Certificate of Service<br>15                                                         |
+
+## TABLE OF AUTHORITIES
+
+| Cases                                                                                     |
+|-------------------------------------------------------------------------------------------|
+| Appeal ofHughes, 633 F.2d 282 (3d Cir. 1980)<br>2                                         |
+| Carpenter v. United States, 138 S. Ct. 2206 (2018).<br>2, 3                               |
+| 6<br>Doe v. Indyke, Case No., 20-cv-00484 (S.D.N.Y.)                                      |
+| 6<br>Giuffre v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018)                              |
+| Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49            |
+| (S.D.N.Y. 1988)<br>1                                                                      |
+| 9<br>Raheem v. Kelly, 257 F.3d 122 (2d Cir. 2001)                                         |
+| Refco Grp. Ltd., LLC v. Cantor Fitzgerald, L.P., No. 13 CIV. 1654 RA HBP, 2014 WL 5420225 |
+| 2<br>(S.D.N.Y. Oct. 24, 2014)                                                             |
+| United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980)<br>5                              |
+| 7<br>United States v. Heath, 455 F.3d 52 (2d Cir. 2006)                                   |
+| 2, 4<br>United States v. Lavender, 583 F.2d 630 (2d Cir. 1978)                            |
+| United States v. Leon, 468 U.S. 897 (1984)<br>5                                           |
+| United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)<br>12                           |
+| United States v. Stein, 541 F.3d 130 (2d Cir. 2008)<br>10                                 |
+| 5, 6, 7<br>United States v. Stokes, 733 F.3d 438 (2d Cir. 2013)                           |
+| United States v. Taylor, 745 F.3d 15 (2d Cir. 2014)<br>12                                 |
+| US Bank Nat. Ass 'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249    |
+| (S.D.N.Y. Nov. 5, 2012)<br>2                                                              |
+
+#### Other Authorities
+
+| Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and |
+|-----------------------------------------------------------------------------------------|
+| Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020)<br>11               |
+| Rules                                                                                   |
+| 4<br>Fed. R. Civ. P. 24(b)                                                              |
+| Fed. R. Civ. P. 26(c)<br>13                                                             |
+| 4<br>Fed. R. Crim. P. 17(c)                                                             |
+| Constitutional Provisions                                                               |
+| U.S. CONST. amend. IV<br>1                                                              |
+| 1, 9<br>U.S. CONST. amend. V                                                            |
+
+### TABLE OF EXHIBITS
+
+EXHIBIT A: Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations by Law Enforcement" or, In the Alternative, to Stay Proceedings. Giuffre v. Maxwell, No. 15-cv-07433-RWS, Apr. 18, 2016
+
+EXHIBIT B: Giuffre v. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016
+
+Ghislaine Maxwell moves under the Fourth Amendment, Martindell v. Intl TeL & TeL Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena.
+
+#### Factual Background
+
+The facts relevant to this Motion are described in Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof.
+
+#### Argument
+
+## I. The Government's violation of the Fourth Amendment requires suppression.
+
+The government does not defend the overbreadth of its subpoena, or even respond to Maxwell's argument. Resp. at 82-95. The government also does not deny that the subpoena effected both a search and a seizure under the Fourth Amendment. Id.
+
+Instead, the government argues that (1) Maxwell has no standing to challenge the subpoena; (2) the government acted in good faith; and (3) the government inevitably would have come to possess the 90,000-sum pages of material it obtained from Boies Schiller.
+
+The facts and law belie the government's claims.
+
+### A. Maxwell has standing.
+
+The government's standing argument boils down to this: Maxwell cannot challenge the search because the material was in the possession of a third party and Maxwell lacked a reasonable expectation of privacy. Resp. at 84-86. This argument fails.
+
+Abundant authority holds that when confidential material is in the possession of a thirdparty, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private
+
+investigation firm). "The governing rule in these circumstances is that the possessor of the claimed privilege or right may intervene to assert it." Id. (quoting Appeal of Hughes, 633 F.2d 282, 288 (3d Cir. 1980)). See also US Bank Nat. Ass'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249, at *2 (S.D.N.Y. Nov. 5, 2012) ("A party [has] standing to challenge . . . a subpoena served on a non-party ... [when] the moving party assert[s] some right or privilege personal to it, such as an interest in proprietary, confidential information that would be disclosed or an interest in maintaining a privilege that would be breached by disclosure." (citing cases)). In turn, in determining whether there is standing, "[c]ourts should consider whether the information itself is private, confidential, privileged, or highly sensitive, and not the form the records take." Refco Grp. Ltd., LLC v. Cantor Fitzgerald, L.P., No. 13 CIV. 1654 RA HBP, 2014 WL 5420225, at *4 (S.D.N.Y. Oct. 24, 2014).
+
+In United States v. Lavender, the Second Circuit held that while a defendant could not file an interlocutory appeal of the district court's denial of his motion to quash a third-party subpoena, he was "free to raise his Fourth Amendment claims via motions to suppress...." 583 F.2d 630, 632 (2d Cir. 1978). Since Maxwell never had notice of the subpoena to Boies Schiller, she is doing here exactly what Lavender allows: filing a motion to suppress.
+
+To be sure, if the government were right—that the mere fact of a third-party's possession of property eliminates a defendant's standing—then Carpenter v. United States would have come out differently, since the defendant's historical cell-site location information was in the possession of MetroPCS and Sprint. 138 S. Ct. 2206, 2212 (2018). But the United States Supreme Court rejected application of the third-party doctrine for two reasons, as this Court should here.
+
+First, the Court recognized that
+
+[t]here is a world of difference between the limited types of personal information addressed in Smith and Miller and the exhaustive chronicle of location information casually collected by wireless carriers today. The Government thus is not asking for a straightforward application of the third-party doctrine, but instead a significant extension of it to a distinct category of information.
+
+Id. at 2219. Second, the Court concluded that in "in no meaningful sense" did Carpenter voluntarily "assume the risk" of "turning over a comprehensive dossier of his physical movements." Id. at 2220.
+
+The same logic applies here. There is "world of difference between the limited types of personal information addressed in Smith and Miller and the exhaustive" and personal details about Maxwell that are contained in Boies Schiller's 90,000 pages of confidential material. These details include, for example, information about Maxwell's sexual partners, sexual habits, finances, and much, much more.
+
+Moreover, "in no meaningful sense" did Maxwell voluntarily share this information with Boies Schiller. Giuffre sued Maxwell, not the other way around. And the defamation claim (the only claim Giuffre ever asserted against Maxwell, who did not file a counterclaim) had nothing to do with much of the confidential information Maxwell was forced, over objection, to provide. Maxwell's motion to dismiss the perjury counts for lack of materiality and her motion for severance, and the replies in support thereof, explain this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5.
+
+But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre, which then compelled Maxwell, over objection, to answer irrelevant and highly prejudicial personal questions. None of it was voluntary.
+
+In addition to the inapplicability of the third-party doctrine, the government's response fails to account for two other, dispositive facts proving that Maxwell has a reasonable expectation of privacy. First, the Protective Order by its terms affords Maxwell a reasonable expectation of privacy. Mot. 3, Ex. Al 3 (defining "CONFIDENTIAL" information as that which "implicates common law and statutory privacy interests of . . . Ghislaine Maxwell" (emphasis added)). What would it say to civil litigants if they could not rely on a court's promise of confidentiality, at least absent notice and an opportunity to object to any breach of that promise (which, of course, Maxwell was denied here). See Mot. 3, Ex. A, ¶ 14 (precluding modification of the Protective Order absent "good cause shown following notice to all parties and an opportunity for them to be heard").
+
+Second, Martindell affords Maxwell a reasonable expectation of privacy. Martindell, 594 F.2d at 294. In Martindell, the Second Circuit held that "the proper procedure" to obtain confidential material under a Protective Order, "as the Government should know, was either to subpoena the deposition transcripts for use in a pending proceeding such as a grand jury investigation or trial, in which the issue could be raised by motion to quash or modify the subpoena, [Fed. R. Crim. P. 17(c)] or to seek permissive intervention in the private action pursuant to [Fed. R. Civ. P. 24(b)], for the purpose of obtaining vacation or modification of the protective order." Id. (emphasis added)). By affording Maxwell a right to notice and an opportunity to be heard, Martindell makes clear that, having been denied those rights when the subpoena was first issued, Maxwell has standing to challenge the government's conduct now. Id.; see Lavender, 583 F.2d at 632.
+
+EFTA00019005
+
+## B. There is no good faith.
+
+The rebuttal to government's good faith claim is simple: There can be no good faith when the government willfully and intentionally misleads the court into authorizing its search. As the United States Supreme Court held in United States v. Leon,
+
+Suppression . . . remains an appropriate remedy if the magistrate or judge in issuing a warrant was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard of the truth.
+
+468 U.S. 897, 923 (1984).
+
+Here, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government acts in objective bad faith.
+
+## C. The government's inevitable discovery doctrine fails.
+
+There are several reasons the government's inevitable discovery argument fails.
+
+First, the inevitable discovery doctrine is an exception to the Fourth Amendment's exclusionary rule. United States v. Stokes, 733 F.3d 438, 442-43 (2d Cir. 2013) (reversing district court's denial of motion to suppress, which was based on "the inevitable discovery doctrine, an exception to the Fourth Amendment's exclusionary rule"). The doctrine has no applicability when a court exercises its inherent or supervisory authority to suppress evidence obtained through deliberate government misconduct. The exercise of that authority is meant to vindicate the dignity of the Court and to deter improper governmental conduct. See United States v. Cortina, 630 F.2d 1207, 1216 (7th Cir. 1980) ("The need for deterrence of illegal conduct is, in one sense, greater here than [elsewhere], for [the government's] offense was committed within the sanctity of the court itself.").
+
+Second, the government's inevitable discovery doctrine is far too speculative. The "typical application" of the inevitable discovery doctrine is when "the government seeks to invoke the doctrine on the basis of standardized, established procedures such as those requiring inventory searches." Stokes, 733 F.3d at 447. The government's "inevitability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id.
+
+In fact, unlike every other civil case in the Southern District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in Giuffre v. Maxwell. In the only other active SDNY case against Epstein, Doe v. Indyke, No. 20-cv-484-JLIC, the government intervened and moved to stay discovery, saying that continued discovery could threaten its case against Maxwell.
+
+By contrast, the government opted not to intervene and stay the unsealing in Giuffre v. Maxwell. The reason is obvious. Legitimately concerned about the propriety of its conduct in misleading Chief Judge McMahon and issuing an unconstitutionally overbroad subpoena to Boies Schiller, the government hoped to hedge its bets by allowing the unsealing process to unfold so it could make the inevitable discovery argument it now makes. This Court should not condone such gamesmanship.'
+
+Third, the government's inevitable discovery argument is far too broad. Even the government admits that the vast majority of material it obtained from Boies Schiller is not on the Giuffre v. Maxwell docket and has not been unsealed by Judge Preska. Resp. at 94. In fact, the government's response appears to concede that its inevitable discovery argument is limited to
+
+<sup>&#</sup>x27; As the government recognizes, Judge Preska recognized this possibility, but deferred to this Court on the question since it is presiding over the criminal case. Resp. at 94 n.41.
+
+Maxwell's two deposition transcripts, Resp. at 94 & n.41. And as to Count 6 in particular (alleging perjury in the July 2016 deposition), the government concedes, as it must, that Judge Preska has refused to unseal all of the testimony charged in the indictment, except one question and one answer. Resp. at 94 n.41. The government offers no explanation for how it inevitably would have obtained all 90,000 pages of material from Boies Schiller when the two deposition transcripts don't even total 1,000 pages.
+
+Fourth, the government misunderstands the burden of proof. The government tries to fault Maxwell for seeking "suppression of all evidence [it] obtained pursuant to the subpoena," calling this a "windfall." Resp. at 95. But it's the government's burden to prove the applicability of the inevitable discovery exception. Stokes, 733 F.3d at 444 (inevitable discovery doctrine applies only "if the government can prove that the evidence would have been obtained inevitably without the constitutional violation") (rejecting government's inevitable discovery claim). The government must explain why Maxwell isn't entitled to this remedy, not the other way around. The government has fallen far, far short of meeting its burden, if only because it offers no argument—on the facts or the law—for how it might have inevitably discovered more than 89,000 pages of material that hasn't been and won't be unsealed by Judge Preska. This Court should have no confidence, much less a "high level of confidence, that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." United States v. Heath, 455 F.3d 52, 55 (2d Cir. 2006) (articulating inevitable discovery standard).
+
+The inevitable discovery doctrine does not apply.
+
+## II. The Government's violation of Martindell requires suppression.
+
+The government ignores the primary argument Maxwell made in her Motion: The government circumvented Martindell, and deprived Maxwell of due process, by securing a modification of the Protective Order in an ex parte hearing (chock full of misrepresentations) without first providing Maxwell notice and an opportunity to be heard. Mot. No. 11, at 11-15. The government offers no response to this fundamental point—Martindell demands notice and an opportunity to be heard; Maxwell received neither. Resp. at 76—81.
+
+Now, in an audacious request, the government argues this Court cannot evaluate the propriety of Chief Judge McMahon's analysis of Martindell, because Judge McMahon is a coequal judge who exercised her sound discretion. Resp. at 81 & n.37. Were the government's unsupported argument correct, though, it would mean that Maxwell will never have an opportunity to challenge the subpoena under Martindell, as that case and due process require. The government is not right.
+
+This Court does not owe deference to Judge McMahon's decision, for at least three reasons. First, Maxwell never was given the chance to oppose the government's request, so due process demands that she be given that chance now. Second, Chief Judge McMahon did not possess all the relevant facts because the government improperly concealed them from her. To the contrary, the government misled Judge McMahon about its contacts with Boies Schiller and the origins of its investigation, facts that were central to Judge McMahon's decision to modify the Protective Order and authorize the subpoena. Mot. No. 3 & Reply in Support Thereof. Third, this Court is not tasked with deciding whether the Protective Order should be modified or even questioning the correctness of Judge McMahon's modification. This Court is deciding a different question entirely—whether the government's violation of Martindell requires suppression.
+
+As to remedy, the government says that no case addresses whether suppression is proper for a Martindell violation. Fair enough. Resp. at 81.
+
+But that's doubtless because that law has been clear for forty-two years that the government can modify a civil Protective Order and then subpoena confidential material only after notice to the real party in interest and an opportunity to respond. Martindell, 594 F.2d at 294 (Martindell decided in 1979). The proper procedure for modifying a civil Protective Order at the government's request, in other words, is the one that affords due process. U.S. CONST. amend. V.
+
+That no case has addressed the remedy for a Manindell violation is evidence only of (1) the government's prior compliance with Martindell (which should, of course, be expected), or (2) a criminal defendant having not raised the issue before. In this case, however, (1) the government violated Martindell, and (2) Maxwell seeks suppression as a sanction.
+
+Suppression is the proper remedy for at least two reasons. First, at its heart, Martindell is grounded in due process principles, and the government's conduct here violated Maxwell's right to due process. See U.S. CONST. amend. V. The essence of due process is notice and an opportunity to be heard. Martindell guaranteed Maxwell notice and an opportunity to be heard, 594 F.2d at 294, as did the Protective Order, Mot. 3, Ex. A, 1 14. But Maxwell had no idea that the Giuffre Protective Order had been modified behind her back until she was indicted and the government disclosed the 90,000 pages of material it obtained from Boies Schiller.' The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation).
+
+Second, because the government violated Martindell not only by denying Maxwell notice and an opportunity to be heard, but also by affirmatively misleading Chief Judge McMahon,
+
+<sup>2</sup> To this day, Judge Preska—who is presiding over the Giuffre action since Judge Sweet's passing and is addressing the Protective Order on a daily basis as the parties brief what material should be unsealed—apparently does not know the Protective Order was modified.
+
+suppression is proper under this Court's inherent and supervisory authority. Mot. No. 3 & Reply in Support Thereof.
+
+## III. The Government's violation of the Fifth Amendment requires suppression.
+
+The government offers three responses to Maxwell's Fifth Amendment argument. None is persuasive.
+
+The government's first response is to deny any state action. Resp. at 99-100. But as even the government admits, a private party, like Boies Schiller, is deemed to be an agent of the state when the government "has provided such significant encouragement, either overt or covert, that the choice must in law be deemed to be that of the State." Resp. at 99 (quoting United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008)). Here, based on the record of the government's contacts with Boies Schiller in the months before and after Maxwell's depositions, there is at least a genuine question of fact as to the government's role in encouraging Boies Schiller.
+
+We know that the government contemplated a perjury prosecution of Maxwell, as seen in the government's newly-disclosed notes from the meeting. Reply ISO Mot. to Suppress, Ex. K, p 5. And if the government is to be believed, there was only one meeting with Boies Schiller, two months before Maxwell's first deposition. If the government was contemplating a perjury prosecution before Maxwell even testified, it stands to reason that Boies Schiller and the government discussed at the February 29 meeting a plan to set a perjury trap for Maxwell.
+
+Indeed, the contemporaneous notes of the February 29 meeting show that Boies Schiller promised to send the government "depositions," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the government had not yet charged
+
+Maxwell with perjury.; There are compelling reasons, therefore, to think the government and Boles Schiller collaborated and that Boies Schiller's conduct was in part at the government's behest.
+
+The record in the Giuffre case preceding the first deposition supports this conclusion as well. Based on Giuffre's claim of an ongoing investigation, Maxwell requested, prior to her deposition, that Giuffre disclose any alleged "on-going criminal investigation by law enforcement" or alternatively to stay the action pending completion of any such investigation. Ex. A. In part, Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." Ex. A, p 3. The district court declined to afford Ms. Maxwell the requested relief. Ex. B.
+
+The day before Maxwell's April 2016 deposition, however, Judge Sweet ordered that "[a]ny materials that [Giuffre] has with respect to any criminal investigations will be turned over [by Giuffre] except for any statements made by [Giuffre] to law enforcement authority." Ex. B, p 21. Maxwell had in fact served a discovery request on Boies Schiller for any such documents, yet Giuffre produced no such materials, and the deposition proceeded as scheduled the next day.
+
+In reliance on the Protective Order, which included no exception for any law enforcement need or subpoena and based on Giuffre's failure to disclose any "ongoing criminal investigation," Maxwell did not assert her Fifth Amendment privilege against self-incrimination during that deposition and testified truthfully.
+
+As explained in Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof, the government has now disclosed several documents "with respect to any criminal investigations"
+
+<sup>3</sup> Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https://www.nydailynews.corninew-yorlany-jeffrey-epstein-maxwell-case-20201013 jinzh17zdrzdgrbbs7yc6binszu-stoty.html.
+
+that Giuffre possessed in February and March 2016. Under Judge Sweet's pre-deposition order, Giuffre should have turned these documents over to Maxwell before the April 2016 deposition. Giuffre's failure to turn the documents over, despite Judge Sweet's order, is compelling evidence that Boies Schiller was acting as an agent of the state for Fifth Amendment purposes when deposing Maxwell. At the very least, the possibility cannot be dismissed out of hand, and an evidentiary hearing is appropriate.
+
+The government's second argument is that Maxwell waived her Fifth Amendment right. Resp. at 100. Not so. A waiver is valid only if it is knowingly made. United States v. Taylor, 745 F.3d 15, 23 (2d Cir. 2014). And "'knowing' means with full awareness of the nature of the right being abandoned and the consequences of abandoning it." Id.
+
+Here, Maxwell did not knowingly waive her Fifth Amendment right. She declined to invoke it based on the protections afforded to her by the Protective Order, and on the understanding that the government was not actively investigating her. That understanding, as it turned out, was incorrect, but it was a misunderstanding deliberately encouraged by Boies Schiller with cooperation from the government. If Boies Schiller had disclosed that material Judge Sweet ordered them to disclose, Maxwell would have invoked her Fifth Amendment right and avoided the perjury trap the government and Boies Schiller set for her.
+
+It is for this reason that the government fails in its attempt to distinguish United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988). Resp. at 102. The government says that the logic of Oshatz does not apply because the defendant there had already been indicted whereas here, Maxwell was deposed "over two years before the Government opened its investigation." Resp. at 100; id. at 102 (noting that the defendant in Oshatz "had already been indicted at the time of his deposition in a civil case for almost seven months"). Of course, this argument depends on the
+
+government's claim that its investigation of Maxwell did not start until 2018. But based on the discovery provided to Maxwell in response to her Pretrial Motion No. 3, we know the investigation actually began as early as 2016, when two months before Maxwell's first deposition, Boies Schiller met with the government and pressed an investigation for, among other things, per hay. This Court should adhere to Oshatz and, as the court there granted the motion to quash, here it should grant the motion to suppress.
+
+The government's final argument is a red herring. Resp. at 103. Maxwell's argument is not, and has never been, that a Protective Order cannot be modified. Maxwell agrees that, under Martindell, and after notice to the real party in interest and an opportunity to be heard, modification of a Protective Order is appropriate if the government can show "improvidence in the grant of a Rule 26(c) protective order or some extraordinary circumstance or compelling need." 594 F.2d at 296. Here, Maxwell was never given notice and an opportunity to be heard, and Chief Judge McMahon's finding of "extraordinary circumstances" was fatally tainted by the government's misrepresentations to her about the origins of its investigation.
+
+## IV. The Court should hold an evidentiary hearing.
+
+Because there are genuine disputes of material fact, and for the reasons given in Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof, this Court should hold an evidentiary hearing.
+
+#### CONCLUSION
+
+For these reasons, as well as those given in the Motion, this Court should: (1) suppress all evidence the Government obtained from Boies Schiller and any other evidence derived therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this Motion.
+
+Dated: March 15, 2021
+
+Respectfully submitted,
+
+s/ Jeffrey S. Pagliuca
+
+Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364
+
+Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
+
+Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100
+
+Attorneys for Ghislaine Maxwell
+
+# Certificate of Service
+
+I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the Reply Memorandum of Ghislaine Maxwell in Support of Her Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following:
+
+
+
+One Saint Andrew's Plaza New York, NY 10007
+
+
+
+s/ Christian R. Everdell

content-documents/ds8/bf/EFTA00019126.md

@@ -0,0 +1,29 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00019126)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+
+
+and
+
+Would you have time for a call this afternoon to give you an update on a new development?
+
+Thanks, Marc
+
+### Marc A. Weinstein I Partner
+
+Chair. White Collar Defense
+
+Hughes Hubbard & Reed LLP
+
+This message contains confidential information and is intended only (or the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted. corrupted, lost. destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message. which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

content-documents/ds8/bf/EFTA00019479.md

@@ -0,0 +1,45 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00019479)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00019479"
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+
+| From:                                                              |                                 |
+|--------------------------------------------------------------------|---------------------------------|
+| To:                                                                |                                 |
+| Subject: RE: status memo draft                                     |                                 |
+| Date: Wed, 06 Mar 2019 17:42:18 +0000                              |                                 |
+| Importance: Normal                                                 |                                 |
+|                                                                    |                                 |
+| sorry,                                                             |                                 |
+| From:                                                              |                                 |
+| Sent: Wednesday, March 06, 2019 12:42                              |                                 |
+| To:<br>Subject: RE: status memo draft                              |                                 |
+|                                                                    |                                 |
+| From:                                                              |                                 |
+| Sent: Wednesday, March 6, 2019 12:39 PM                            |                                 |
+| To:<br>Subject: RE: status memo draft                              |                                 |
+| 302:                                                               |                                 |
+| During one of the visits Epstein asked her<br>and she told him no. |                                 |
+| 302:                                                               |                                 |
+| Epstein wanted<br>to                                               | Epstein used his hand to direct |
+|                                                                    |                                 |
+| From:                                                              |                                 |
+| Sent: Wednesday, March 06, 2019 10:17<br>To:                       |                                 |
+| Subject: RE: status memo draft                                     |                                 |
+| Redline attached—let me know if you want to discuss. Thanks!       |                                 |
+| From:                                                              |                                 |
+| Sent: Tuesday, March 5, 2019 9:22 PM                               |                                 |
+| To:                                                                |                                 |
+
+Subject: status memo draft
+
+Thoughts? It's a little on the long side (chiefs said —3 pages was fine) just due to the legal analysis, but they can always cut that down. Anyway I've never done one of these in particular before so very happy for suggestions. Thanks!

content-documents/ds8/bf/EFTA00019926.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00019926)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00019926"
+ocrPages: 0
+ocrChars: 4184
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Subject: RE: GM - Letter re Warden
+
+Date: Tue, 01 Dec 2020 20:15:35 +0000
+
+Attachments: 2020-12-01_GMJetter_regarding_defense_request_re_MDC_warden_v1.docx
+
+I'm back at my desk. I can send this along to the chiefs. I just added quotes around her statement in the attached. If you have something else in mind, let me know!
+
+| From:<br>Sent: Tuesday, December 01, 2020 1:38 PM<br>(USANYS) .ca<br>To:<br>)<br>Subject: RE: GM - Letter re Warden                                                                                                                                                  |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| . Otherwise nothing from me. Thanks very much.<br>Agree with your proposal,                                                                                                                                                                                          |
+| From:<br>><br>sc<br>Sent: Tuesday, December 1, 2020 1:27 PM<br>To:<br>(USANYS)<br>Cc:<br>Subject: Re: GM - Letter re Warden                                                                                                                                          |
+| Sure, no problem<br>any comments?                                                                                                                                                                                                                                    |
+| Sent from my iPhone                                                                                                                                                                                                                                                  |
+| On Dec 1, 2020, at 1:20 PM,<br>> wrote:<br>(USANYS) <                                                                                                                                                                                                                |
+| If you guys want to make any edits you like and then send to the chiefs, that's fine with me. I'm not sure when I'll be<br>done here                                                                                                                                 |
+| On Dec 1, 2020, at 12:48 PM,<br>> wrote:<br><                                                                                                                                                                                                                        |
+| Hi M,                                                                                                                                                                                                                                                                |
+| Thanks so much for drafting — I think my only suggestion would be to tweak the language a little bit to make it more<br>obvious that the language from Bobbi is a direct quote from them/ that they wrote it (and that we aren't just<br>characterizing their view). |
+| Thanks!                                                                                                                                                                                                                                                              |
+| From:<br>(USANYS)<br>Sent: Tuesday, December 1, 202012:45 PM<br>1S;<br>To:I<br>Subject: GM - Letter re Warden                                                                                                                                                        |
+
+Hi — I didn't have as much time to work on this as I had hoped before I have to leave the office, but wanted to get the draft circulating. Sorry about that. Please feel free to edit as much as you like. Saved in the correspondence folder, and attached.
+
+Thanks,
+
+M
+
+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:

content-documents/ds8/bf/EFTA00021356.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00021356)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+| From:                     |  |
+|---------------------------|--|
+| To:                       |  |
+| Subject: RE: Cover Letter |  |
+
+Date: Fri, 26 Feb 2021 07:48:06 +0000
+
+Attachments: 2020-12-16 _ GM _ renewed _ bail _ motion _ cover _ letter .docx
+
+Attached, thanks.
+
+Ori in 1 M
+
+From:
+
+Sent: Frkla,F6n .
+
+To: Subject: Cover Letter
+
+If there is a prior letter from this case that I can use as a go by, do you mind emailing it to me when you have a chance? I can try to work off of that. I can't do anything on the shared.

content-documents/ds8/bf/EFTA00022524.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00022524)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+
+
+
+Because the unredacted search warrant materials and July 15 status report will be filed at 11 and the Epstein bail hearing is at 11:30, a couple of reporters have asked if I can tell them how many pages the status report is, so they have a sense of how much they'll have to read between 11 and 11:30 if they're covering both.

content-documents/ds8/bf/EFTA00024447.md

@@ -0,0 +1,33 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00024447)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
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+
+
+
+This message has not been virus scanned because it contains encrypted or otherwise protected data. Please ensure you know who the message is coming from and that it is virus scanned by your desktop antivirus software.
+
+This message has not been virus scanned because it contains encrypted or otherwise protected data. Please ensure you know who the message is coming from and that it is virus scanned by your desktop antivirus software.
+
+Attached is part 1 of the document production along with our cover letter for the above referenced subpoena. The production is password protected. The password to the production will be provided separately.
+
+Thank you,
+
+Jezebel
+
+
+
+Diaz Paralegal Authorized Officer
+
+UBS Group AG Legal — Subpoenas, Levies & Garnishments 1285 Avenue of the Americas —12th Floor New York, NY 10019 (615) 393-7621
+
+EFTA00024448

content-documents/ds8/bf/EFTA00027933.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00027933)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+| From: |  |
+|-------|--|
+|       |  |
+
+Subject: RE: 3 pm is good for the Epstein team Date: Wed, 14 Aug 2019 13:41:35 +0000
+
+Excellent, thank you. See you all then
+
+From:
+
+t.
+
+Subject: 3 pm is good for the Epstein team
+
+United States Attorney's Office for the Southern District of New York 1 St. Andrew's Plaza
+
+EFTA00027933

content-documents/ds8/bf/EFTA00028028.md

@@ -0,0 +1,59 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00028028)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00028028"
+ocrPages: 0
+ocrChars: 1341
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Attachments: Govt_Omnibus_Opp_v4.docx
+
+### Hi
+
+Brief attached. Before you make the TOC, will you do a quick scroll through to confirm that (1) there's no weird spacing issues, and (2) the only highlighting is green? I just did that but could use someone double-checking.
+
+# Thanks! From Sent: Monde , October 25, 2021 9:53 PM To: Cc: Su
+
+Sounds good!
+
+| From:                                  |  |
+|----------------------------------------|--|
+| Sent: Monde , October 25, 2021 9:51 PM |  |
+| To:                                    |  |
+|                                        |  |
+| Cc                                     |  |
+
+Subject: RE: Brief
+
+OK! Just TOC this time. Thanks!
+
+## From: Sent: on a cto er : To: Cc
+
+### Subject: RE: Brief
+
+You can send it to me, thanks. Are you going to need a TOA and TOC or just one or the other?
+
+| From:                             |  |
+|-----------------------------------|--|
+| :<br>o er<br>on ay,<br>,<br>Sent: |  |
+|                                   |  |
+|                                   |  |
+|                                   |  |
+
+### Cc: Subject: Brief
+
+Hi all,
+
+Just checking in to see who I should send the brief to tonight when it's ready to be finalized. Thanks!
+
+Andrew
+
+Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York. New York 10007

content-documents/ds8/bf/EFTA00028771.md

@@ -0,0 +1,29 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00028771)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00028771"
+ocrPages: 0
+ocrChars: 971
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Good morning,
+
+The above-captioned case was wheeled out to Judge Nathan this morning. Attached please find the indictment.
+
+The defendant was arrested at approximately 8:30am in New Hampshire, and the Government expects that she will be presented before a Untied States Magistrate Judge in the District of New Hampshire this afternoon. The Government intends to seek the defendant's detention, and if that application is denied in New Hampshire, the Government expects to seek an appeal of that determination before Judge Nathan.
+
+The AUSAs on this case are cc'd on this email, and I have listed our respective phone numbers below:
+
+We would be very grateful if the Court would be able to set an initial conference date that the Government can convey at this afternoon's presentment. We can be reached at any time should the Court have any questions.
+
+Respectfully,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007

content-documents/ds8/bf/EFTA00029306.md

@@ -0,0 +1,31 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00029306)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00029306"
+ocrPages: 0
+ocrChars: 2255
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Great. Thank you!
+
+| (NY) (FBI) <<br>From:<br>><br>Sent: Tuesday, September 3, 2019 4:40 PM<br>(NY) (OGA) (FBI) c<br>(USANYS) ‹<br>;<br>><br>To:<br>;<br>Cc:<br>(USANYS)<br>(USANYS)<br>Subject: RE: Response to Epstein Touhy Requests |  |
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
+| info:<br>Here is                                                                                                                                                                                                   |  |
+| Tel:<br>Email:                                                                                                                                                                                                     |  |
+|                                                                                                                                                                                                                    |  |
+| (USANYS) [ma ilto:<br>From:                                                                                                                                                                                        |  |
+| Sent: Tuesday, September 03, 2019 12:08 PM                                                                                                                                                                         |  |
+| (NY) (OGA) se;<br>To:<br>• (NY) (FBI) •z<br>>                                                                                                                                                                      |  |
+| Cc:<br>(USANYS)<br>(USANYS)<br>Subject: Response to Epstein Touhy Requests                                                                                                                                         |  |
+
+Hey guys —
+
+AUSA in our Civil Division and copied here, is handling the Touhy requests from Epstein's lawyers and wanted to make sure that he spoke with the right FBI P0C about the request to FBI (attached). Could you provide us with the contact information for ? Thanks!

content-documents/ds8/bf/EFTA00029864.md

@@ -0,0 +1,32 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00029864)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00029864"
+ocrPages: 0
+ocrChars: 1799
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From:                                                                                           |
+|-------------------------------------------------------------------------------------------------|
+| To: S                                                                                           |
+| Subject: RE: Documents for<br>302                                                               |
+| Date: Wed, 21 Jul 2021 22:00:26 +0000                                                           |
+| Attachments:<br>Vol.pdf                                                                         |
+| Attached, thanksl                                                                               |
+| ,=<<br>From:<br>Sent: Wednesday, July 21, 2021 4:42 PM                                          |
+| To:<br>)                                                                                        |
+| Subject: Documents for<br>302                                                                   |
+| Hey                                                                                             |
+| Can you please send me the transcript that was shown to<br>during our first interview with her? |
+| Thanks,                                                                                         |
+|                                                                                                 |
+| Detective                                                                                       |
+| NYED / FBI                                                                                      |
+| Child Exploitation Human Trafficking Task Force                                                 |
+| Office:                                                                                         |

content-documents/ds8/bf/EFTA00031526.md

@@ -0,0 +1,75 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00031526)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00031526"
+ocrPages: 6
+ocrChars: 8738
+ocrElapsed: 0.9
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From To
+
+### Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
+
+Date: Thu, 02 Jul 2020 18:16:22 +0000
+
+Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf; Ghislaine_Maxwell_Indictment_PR.pdf Inline-Images: image001.png
+
+From:
+
+Sent: Thursday, July 2, 2020 1:22 PM Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
+
+
+
+### UNITED STATES ATTORNEY'S OFFICE Southern District of New York
+
+### GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
+
+Maxwell is Alleged to Have Facilita- ted, Participated in Acts of Abuse
+
+Additionally Charged With Perjury in Connection With 2016 Depositions
+
+Audrey Strauss, the Acting United States Attorney- for the Southern District of New York, William F. Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"), announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity, conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls, MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
+
+Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust. All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself. Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
+
+FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The example set by the women involved has been a powerful one. They persevered against the rich and connected, and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery exhibited by the women involved here has empowered others to speak up about the crimes of which they've been subjected."
+
+NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
+
+### If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact the FBI at 1-800-CALL FBI, and reference this case.
+
+According to the Indictment[l I unsealed today in Manhattan federal court:
+
+From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims, MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
+
+As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example, MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior. Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage Epstein, and undressing in front of a victim.
+
+As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein involving a minor victim where MAXWELL was present.
+
+As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as well as MAXWELL's residence in London, England.
+
+Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made false statements, including about certain specific acts and events alleged in the Indictment.
+
+GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which carries a maximum sentence of five years in prison.
+
+The statutory maximum penalties are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant would be determined by the judge.
+
+Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
+
+This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys and are in charge of the prosecution.
+
+The charges contained in the Indictment are merely accusations. The defendant is presumed innocent unless and until proven guilty.
+
+20-138
+
+### DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE AT (212) 637-2600.
+
+Follow us on Facebook 'Follow us on Twitter ISDNY website IYouTube
+
+PI As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent unless and until proven guilty.

content-documents/ds8/bf/EFTA00031910.md

@@ -0,0 +1,21 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00031910)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00031910"
+ocrPages: 0
+ocrChars: 454
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From:                |                                       |
+|----------------------|---------------------------------------|
+| To:                  |                                       |
+|                      | Subject: Accepted: Epstein Meeting    |
+|                      | Date: Mon, 06 Jan 2020 16:16:53 +0000 |
+| Importance: Normal   |                                       |
+| Attachments: unnamed |                                       |

content-documents/ds8/bf/EFTA00032336.md

@@ -0,0 +1,39 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00032336)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00032336"
+ocrPages: 0
+ocrChars: 801
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+Start Date: 2019-11-07 18:00:00 +0000
+
+End Date: 2019-11-07 18:30:00 +0000
+
+Organizer: Hudgens, Johanna Rae <JHudgens@winston.com>
+
+Location:
+
+Class: X-PERSONAL
+
+Date Created: 2019-11-06 18:09:02 +0000
+
+Date Modified: 2019-11-06 18:09:02 +0000
+
+Priority: 5
+
+DTSTAMP: 2019-11-06 17:54:42 +0000
+
+
+
+Reminder
+
+Telephone:
+
+The contents of this message may be privileged and confidential. If this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under applicable tax laws and regulations.

content-documents/ds8/bf/EFTA00033107.md

@@ -0,0 +1,15 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033107)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+ocrPages: 2
+ocrChars: 22
+ocrElapsed: 0.2
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### No Images Produced

content-documents/ds8/bf/EFTA00033187.md

@@ -0,0 +1,15 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033187)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+ocrElapsed: 0.0
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+## No Images Produced

content-documents/ds8/bf/EFTA00033312.md

@@ -0,0 +1,15 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033312)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
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+category: "DOJ Data Set"
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+---
+
+### No Images Produced

content-documents/ds8/bf/EFTA00033334.md

@@ -0,0 +1,15 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033334)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### No Images Produced

content-documents/ds8/bf/EFTA00034516.md

@@ -0,0 +1,327 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00034516)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00034516"
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+
+
+## MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET ZA TIER-G
+
+# DATE: 08/08/2019
+
+| TIME<br>FRAME                             | TIME<br>START | TIME<br>ENO | SIGNATURE | E FRAME                               | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                        | TIAdE<br>START | TIME<br>END | SIGNATURE |
+|-------------------------------------------|---------------|-------------|-----------|---------------------------------------|---------------|-------------|-----------|-----------------------------------|----------------|-------------|-----------|
+| 12:00-12:30 AM                            | 1<br>13       |             |           | 30 AM                                 |               |             |           | 4:00-4:30 PM                      |                | LIcic       |           |
+| 12:30- 1:00 AM                            | 'st           | nJ          |           | 9:00 AM                               |               |             |           | 4:30-600 PM                       |                | Oa          |           |
+| 1:00-1:30 AM                              | VA            |             |           | 9:30 AM                               |               |             |           | 5:00.5:30 PM                      | sts            | QC.         |           |
+| 1:30-2:00 AM                              |               |             |           | 0-10.00 AM                            |               |             |           | 5:304:00 PM                       | 9'.            | S2C.        |           |
+| 2:00-2:30 AM                              | tet           | 21          |           | 00-10:30 AM                           |               |             |           | 6:0043:30 PM                      | aot            | (2 0t.      |           |
+| 2:30-3:00 AM                              |               |             |           | 30-11:00 AM                           |               |             |           | 8:30-7:00 PM                      | tt<br>(9-      | ;031        |           |
+| 3:00-3:30 AM                              |               | 341-        |           | 00-11:30 AM                           |               |             |           | 7:00-7:30 PM                      |                | -tot        |           |
+| 3:30-4:00 AM                              | 3'35          | 33`e        |           | 30-12:00 AM                           |               |             |           | 7:30-8:63 PM                      | 915t4          | -7v-<br>k   |           |
+| 4:004:30 AM                               | q             | q           |           | 00-12:30 PM                           |               |             |           | 8:004:30 PM                       | 860            | sok         |           |
+| 4:30-5:00 AM                              | 404           |             |           | 30- 1:00 PM                           |               |             |           | 8:30- 9:00 PM                     | -zdsc          | 2           |           |
+| 5:00 -5:30 AM                             | 5"            | "<br>✓      |           | :30 PM                                |               |             |           | 91004:30 PM                       | c°             | 0(03        |           |
+| 5:30-600 AM                               |               | n`"         |           | 2:00 PM                               |               |             |           | 9:30-10:00 PM                     | Ct?‹           | SIC         |           |
+| 8:004:30 AM                               |               | let         |           | 2:30 PM                               |               |             |           | 10.00-10:30 PM                    | too:-          | en          |           |
+| 8:367:00 AM                               |               |             |           | 3:00 PM                               |               |             |           | 10:30-11:00 PM                    | 163,-          |             |           |
+| 7:00-7:30 AM                              | 101           |             |           | 0-3.30 PM                             |               |             |           | 11:00-11:30 PM                    | tble<br>i      | U0'         |           |
+| 7:30-8:00 MI                              | 32-           | 3>          |           | 0-4:00 PM                             |               |             |           | 11:30-12:00 PM                    | 3`1            | 3?          |           |
+|                                           |               |             |           |                                       |               |             |           |                                   |                |             |           |
+| MORNING WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | DAY WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | NINO WATCH<br>ERATIONS<br>UTENANT |                |             |           |
+|                                           |               |             |           |                                       |               |             |           |                                   |                |             |           |
+
+A staff mem I r must observe all inmates confined in a continuous locked down status, such deten ion or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 a.m. — 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 am — 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rojInds are to be conducted on an irregular schedule and no more than 40 minutes apart. All observations m st be documented.
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+CAPTAIN
+
+
+
+EFTA00034516
+
+HEOL ITSU DOWN
+
+
+
+SPECIAL HOUSING UNIT
+
+### MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET ZA TIER-H
+
+#### 08/08/2019 DATE:
+
+| TIME<br>FRAME  | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME     | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME     | TIME<br>START | TIME<br>END | SIGNATURE |
+|----------------|---------------|-------------|-----------|----------------|---------------|-------------|-----------|----------------|---------------|-------------|-----------|
+| 12:00-12:30 AM |               |             |           | 00-8:30 AM     |               |             |           | 4:00-4:30 PM   |               | 407         |           |
+| 12:30- 1:00 AM |               |             |           | 30- 9:00 AM    |               |             |           | 4:30-5:00 PM   |               | 431         |           |
+| 1:00-1:30 AM   |               | 110         |           | 00-9:30 AM     |               |             |           | 5:00 -5:30 PM  |               | 08          |           |
+| 1:30-2:00 AM   |               | રે રે       |           | :30-10:00 AM   |               |             |           | 5:30-6:00 PM   |               | 58          |           |
+| 2:00-2:30 AM   | 20            | 21          |           | 0:00-10:30 AM  |               |             |           | 6:00-6:30 PM   |               | 600         |           |
+| 2:30-3:00 AM   |               |             |           | 10:30-11:00 AM |               |             |           | 6:30-7:00 PM   |               | ુજર         |           |
+| 3:00-3:30 AM   |               |             |           | 1:00-11:30 AM  |               |             |           | 7:00-7:30 PM   |               | 700         |           |
+| 3:30-4:00 AM   |               | 251         |           | 1:30-12:00 AM  |               |             |           | 7:30-8:00 PM   | 25            | ਤੇ ਵੱਟ      |           |
+| 4:00-4:30 AM   | 24            | 25          |           | 12:00-12:30 PM |               |             |           | 8:00-8:30 PM   | 00            | QOCJ        |           |
+| 4:30-5:00 AM   | વડ્           | 1440        |           | 2:30- 1:00 PM  |               |             |           | 8:30- 9:00 PM  |               |             |           |
+| 5:00 -5:30 AM  |               | 13          |           | :00-1:30 PM    |               |             |           | 9:00-9:30 PM   |               | 02          |           |
+| 5:30-6:00 AM   |               | 42          |           | :30-2:00 PM    |               |             |           | 9:30-10:00 PM  |               | ને રેજિ     |           |
+| 6:00-6:30 AM   |               |             |           | :00-2:30 PM    |               |             |           | 10:00-10:30 PM |               | 1004        |           |
+| 6:30-7:00 AM   |               |             |           | 30-3:00 PM     |               |             |           | 10:30-11:00 PM |               | 031         |           |
+| 7:00-7:30 AM   | B             |             |           | :00-3:30 PM    |               |             |           | 11:00-11:30 PM |               |             |           |
+| 7:30-8:00 AM   | 31            |             |           | :30-4:00 PM    |               |             |           | 11:30-12:00 PM |               |             |           |
+
+MORNING WATCH DAY WATCH EVENING WATCH OPERATIONS OPERATIONS OPERATIONS LIEUTENANT LIEUTENANT LIEUTENANT
+
+> A staff member must observe all inmates confined in a continuous locked down status, such as administrative detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 am - 1:00 a.m.), thus ensuring an innuate is observed at least twice per hour. These rounds are to be conducted on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+CAPTAIN
+
+
+
+SDNY 00011243 EFTA00034517
+
+
+
+IPECIAL HOUSING UNIT
+
+GOODEW FORH
+
+
+
+## MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET ZA TIER-J
+
+
+
+#### 08/08/2019 DATE:
+
+| TIME<br>FRAME                             | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                            | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                                | TIME<br>START | TIME<br>END | SIGNATURE |
+|-------------------------------------------|---------------|-------------|-----------|---------------------------------------|---------------|-------------|-----------|-------------------------------------------|---------------|-------------|-----------|
+| 12:00-12:30 AM                            | 709           |             |           | -8:30 AM                              | 207           | 0-08<br>0   |           | 00-4:30 PM                                | 403           | 403         |           |
+| 12:30- 1:00 AM                            | 13            | 244         |           | 9:00 AM                               | તર            | 040         |           | :30-5:00 PM                               | 434           | 435         |           |
+| 1:00-1:30 AM                              | 12            | 13          |           | 9:30 AM                               | 06            | 907         |           | :00 -5:30 PM                              | 02            | (03         |           |
+| 1:30-2:00 AM                              | 151           | 52          |           | -10:00 AM                             | માં<br>6      | 945         |           | 30-6:00 PM                                |               | 524         |           |
+| 2:00-2:30 AM                              |               | 1 જે        |           | 0-10:30 AM                            | 11            | 1016        |           | 00-6:30 PM                                |               | 203         |           |
+| 2:30-3:00 AM                              | 24            | 135         |           | 0-11:00 AM                            |               | ળે કેવ      |           | :30-7:00 PM                               | 32            | 32          |           |
+| 3:00-3:30 AM                              | 05            | -107<br>1)  |           | 0-11:30 AM                            | 03            | 144         |           | 00-7:30 PM                                | 0 ਤੋ          | 704         |           |
+| 3:30-4:00 AM                              | 33<br>7       | 59          |           | 0-12:00 AM                            |               |             |           | 30-8:00 PM                                | 32            | 22          |           |
+| 4:00-4:30 AM                              | 11            | 22          |           | 0-12:30 PM                            | 005           |             |           | 00-8:30 PM                                |               | 266         |           |
+| 4:30-5:00 AM                              | 42            | 147         |           | 30- 1:00 PM                           |               | 731         |           | 30- 9:00 PM                               |               | રજક         |           |
+| 6:00 -5:30 AM                             | 05            | 507         |           | 1:30 PM                               | 07            | 67          |           | :00-9:30 PM                               |               | তীয়        |           |
+| 5:30-6:00 AM                              | રે રે         | 361         |           | 0-2:00 PM                             | 27            | 27          |           | 30-10:00 PM                               |               | 0,82        |           |
+| 6:00-6:30 AM                              | 23            |             |           | -2:30 PM                              | 02            | 82          |           | 0:00-10:30 PM                             |               | DO2         |           |
+| 6:30-7:00 AM                              |               |             |           | 0-3:00 PM                             |               |             |           | 0:30-11:00 PM                             |               | િકેટ        |           |
+| 7:00-7:30 AM                              | 04            |             |           | -3:30 PM                              | 06            | 207         |           | 1:00-11:30 PM                             |               |             |           |
+| 7-30-8:00 AM                              |               |             |           | -4:00 PM                              |               |             |           | 1:30-12:00 PM                             |               |             |           |
+|                                           |               |             |           |                                       |               |             |           |                                           |               |             |           |
+| MORNING WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | DAY WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | EVENING WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           |
+
+A staff member must observe all inmates confined in a continuous locked down status, such as administrative detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
+
+12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at 1 conducted on an irregular schedule and no more than 40 minu documented.
+
+These rounds are to be ations must be
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+
+
+CAPTAIN
+
+
+
+SDNY_00011244 EFTA00034518 BOX BYO CORK
+
+IFECIAL HOUSING UNIT
+
+## MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET ZA TIER-K
+
+MOC NEW YORK SPECIAL HOUSIng UNIT
+
+#### DATE: 08/08/2019
+
+| TIME<br>FRAME                             | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                                                                                                                                                                                           | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                                | TIME<br>START | TIME<br>END | SIGNATURE |
+|-------------------------------------------|---------------|-------------|-----------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|-------------|-----------|-------------------------------------------|---------------|-------------|-----------|
+| 12:00-12:30 AM                            |               |             |           | 0-8:30 AM                                                                                                                                                                                            | 709           | 10          |           | 4:00-4:30 PM                              |               | 404         |           |
+| 12:30- 1:00 AM                            |               |             |           | 0- 9:00 AM                                                                                                                                                                                           |               |             |           | 4:30-5:00 PM                              |               |             |           |
+| 1:00-1:30 AM                              | 5             |             |           | 0-9-30 AM                                                                                                                                                                                            | 0409          | (U          |           | 5:00 -5:30 PM                             |               | 100         |           |
+| 1:30-2:00 AM                              |               | 55          |           | 0-10:00 AM                                                                                                                                                                                           | 10            |             |           | 5:30-6:00 PM                              |               | ર ર         |           |
+| 2:00-2:30 AM                              |               | 14          |           | 00-10:30 AM                                                                                                                                                                                          | 00            | 0 "         |           | 6:00-6:30 PM                              |               | 02          |           |
+| 2:30-3:00 AM                              |               | ગ્ર         |           | 30-11:00 AM                                                                                                                                                                                          |               |             |           | 6:30-7:00 PM                              |               |             |           |
+| 3:00-3:30 AM                              |               |             |           | 00-11:30 AM                                                                                                                                                                                          |               | 0 2         |           | 7:00-7:30 PM                              | 06            | 702         |           |
+| 3:30-4:00 AM                              |               |             |           | 30-12:00 AM                                                                                                                                                                                          | 40            | 41          |           | 7:30-8:00 PM                              |               | 53          |           |
+| 4:00-4:30 AM                              | 72            |             |           | 00-12:30 PM                                                                                                                                                                                          |               | ( B         |           | 8:00-8:30 PM                              |               | 204         |           |
+| 4:30-5:00 AM                              | 45            | 44          |           | 30- 1:00 PM                                                                                                                                                                                          |               |             |           | 8:30- 9:00 PM                             | 53            | ನ್ನೇ        |           |
+| 5:00 -5:30 AM                             | 01            | ರ್ಯ         |           | 0-1:30 PM                                                                                                                                                                                            | 61            | 02          |           | 9:00-9:30 PM                              | DC            | 04          |           |
+| 5:30-6:00 AM                              |               | 40          |           | 0-2:00 PM                                                                                                                                                                                            | 3 3           | ું તે       |           | 9:30-10:00 PM                             |               | રેત         |           |
+| 6:00-6:30 AM                              |               |             |           | 0-2:30 PM                                                                                                                                                                                            | 0             | ી બ્લ       |           | 10:00-10:30 PM                            |               |             |           |
+| 6:30-7:00 AM                              |               |             |           | 0-3:00 PM                                                                                                                                                                                            |               |             |           | 10:30-11:00 PM                            |               |             |           |
+| 7:00-7:30 AM                              |               |             |           | 0-3:30 PM                                                                                                                                                                                            | 0 7           |             |           | 11:00-11:30 PM                            |               |             |           |
+| 7:30-8:00 AM                              |               |             |           | 0-4:00 PM                                                                                                                                                                                            |               |             |           | 11:30-12:00 PM                            |               |             |           |
+|                                           |               |             |           |                                                                                                                                                                                                      |               |             |           |                                           |               |             |           |
+| MORNING WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | DAY WATCH<br>OPERATION'S<br>LIECTIENANT                                                                                                                                                              |               |             |           | EVENING WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           |
+|                                           |               |             |           | A staff member must observe all inmates confined in a continuous locked down status, such as administrative<br>w Hastelly any assuccess of for the Bund 20 minute named of the house (ovements 19,00 |               |             |           |                                           |               |             |           |
+
+detention or disciplinary segregation, at least onee in the first 30 minute period of the hour (example, 12:00 a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice ner hour. These rounds are to be conducted on an irregular schedule and no more than 40 minutes a ns must be documented.
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+
+
+CAPTAIN
+
+
+
+SDNY_00011245 EFTA00034519
+
+
+
+
+
+## MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET M-TIER
+
+
+
+SPECIAL HOUSING UNIT
+
+### DATE: 08/08/2019
+
+| TIME<br>FRAME  | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME  | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME     | TIME<br>START | TIME<br>END | SIGNATURE |
+|----------------|---------------|-------------|-----------|-------------|---------------|-------------|-----------|----------------|---------------|-------------|-----------|
+| 12:00-12:30 AM | 701           | 709         |           | 0-8:30 AM   | 0/15          | 0-66<br>0   |           | 4:00-4:30 PM   | 1102          | 402         |           |
+| 12:30- 1:00 AM | પ્રી          | નિક         |           | 0- 9:00 AM  | 0 21          | 834         |           | 4:30-5:00 PM   | 135           | 36<br>J     |           |
+| 1:00-1:30 AM   | 8 8 4         | 12          |           | 0-9:30 AM   | 007           | 908         |           | 5:00 -5:30 PM  | 00            | (Ol         |           |
+| 1:30-2:00 AM   | 50            | 21          |           | 60-10:00 AM | પ્રા          | 40          |           | 5:30-6:00 PM   | 532           | (33         |           |
+| 2:00-2:30 AM   | 20            |             |           | 00-10:30 AM |               | CIV         |           | 6:00-6:30 PM   | 04            | 604         |           |
+| 2:30-3:00 AM   | 33            | 734         |           | 30-11:00 AM | ત્વવ          |             |           | 6:30-7:00 PM   | ਤੀ            | 31<br>0     |           |
+| 3:00-3:30 AM   |               | 05          |           | 00-11:30 AM | વ્ય           | ಿ ೭         |           | 7:00-7:30 PM   | 105           | 705         |           |
+| 3:30-4:00 AM   |               | 53          |           | 30-12:00 AM | 71            | 32          |           | 7:30-8:00 PM   | ਨੀ            | 731         |           |
+| 4:00-4:30 AM   | 20            | 421         |           | 00-12:30 PM | 703           | 204         |           | 8:00-8:30 PM   | on            | 807         |           |
+| 4:30-5:00 AM   | 41            | 146         |           | 30- 1 00 PM |               | 1776        |           | 8:30- 9:00 PM  |               | 832         |           |
+| 5:00 -5:30 AM  | 03            | 2 05        |           | 0-1:30 PM   | 07            | 08          |           | 9:00-9:30 PM   | 06            | GOG         |           |
+| 5:30-6:00 AM   | 37            | 38          |           | 30-2:00 PM  | રે ર          | ાવ છ        |           | 9:30-10:00 PM  | ગ             | ਟ, ਡੈਫ      |           |
+| 6:00-6:30 AM   | 24            | 25          |           | 0-2:30 PM   |               | 12          |           | 10:00-10:30 PM | Dol           | (002        |           |
+| 6 30-7:00 AM   | 1             | 1,32        |           | 80-3:00 PM  |               | 34          |           | 10:30-11:00 PM | 036           | 1034        |           |
+| 7:00-7:30 AM   | ળુક           | 05          |           | 0-3:30 PM   | 900           | 306         |           | 11:00-11:30 PM | 00            | 102         |           |
+| 7:30-8:00 AM   |               |             |           | 0-4:00 PM   |               | 238         |           | 11:30-12:00 PM |               | 138         |           |
+
+| MORNING WATCH<br>OPERATIONS<br>LIEUTENANT | DAY WATCH<br>OPERATIONS<br>LIEUTENANT | EVENING WATCH<br>OPERATIONS<br>LIEUTENANT |  |  |
+|-------------------------------------------|---------------------------------------|-------------------------------------------|--|--|
+|                                           |                                       |                                           |  |  |
+
+A staff member must observe all inmates confined in a continuous locked down status, such as administrative detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, rounds are to be 12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice conducted on an irregular schedule and no more than 40 minutes apart must be documented.
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+
+
+CAPTAIN
+
+
+
+SDNY_00011246 EFTA00034520 PECIAL BOULDG UNIT
+
+acchild torn
+
+SPECIAL HOUSING UNIT
+
+### MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET L-TIER DATE: _ 08/08/2019
+
+| TIME<br>FRAME  | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME  | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME     | TIME<br>START     | TIME<br>END | SIGNATURE |
+|----------------|---------------|-------------|-----------|-------------|---------------|-------------|-----------|----------------|-------------------|-------------|-----------|
+| 12:00-12:30 AM | 1205          |             |           | 00-8:30 AM  | 101           | 20          |           | 4:00-4:30 PM   | 111               | 101         |           |
+| 12:30- 1:00 AM | 141           |             |           | 30- 9:00 AM | 151           |             |           | 4:30-5:00 PM   | 157               | 437         |           |
+| 1:00-1:30 AM   | 10            | 11          |           | 00-9:30 AM  | 6101          | 0162        |           | 5:00 -5:30 PM  | ಕೆಯ               | రా          |           |
+| 1:30-2:00 AM   | દી વ          | 150         |           | 30-10:00 AM | 6 3 €         | 0132        |           | 5:30-6:00 PM   | ਤੇ।               | 531         |           |
+| 2:00-2:30 AM   |               | 10          |           | 00-10:30 AM | 0'7           | 10°2        |           | 6:00-6:30 PM   |                   | 105         |           |
+| 2:30-3:00 AM   | 56            | 33          |           | 30-11:00 AM | 551           | 1156        |           | 6:30-7:00 PM   | 630               |             |           |
+| 3:00-3:30 AM   | 00            | 202         |           | 00-11:30 AM | 100           | 102         |           | 7:00-7:30 PM   | 706               | 202         |           |
+| 3:30-4:00 AM   | 00            | ್ರಿ ಒ       |           | 30-12:00 AM | રે દ          | 32          |           | 7:30-8:00 PM   |                   | 30          |           |
+| 4:00-4:30 AM   | ૧ વ<br>11     | 70          |           | 00-12:30 PM | 700           | 1262        |           | 8:00-8:30 PM   | ತಿದ್ದಾರೆ. ಇದರ್ ಸಾ | 808         |           |
+| 4:30-5:00 AM   | 40            | 41          |           | 30- 1:00 PM | 136           | 1732        |           | 8:30- 9:00 PM  | 120               | ್ರಿಸ್ತರ     |           |
+| 5:00 -5:30 AM  | 01            | 403         |           | 00-1:30 PM  | 0 €           | 02          |           | 9:00-9:30 PM   | o                 | :07         |           |
+| 5:30-6:00 AM   | నిల           | 37          |           | 30-2:00 PM  | 31            | 32          |           | 9:30-10:00 PM  | વ્                | ડેઇ<br>্    |           |
+| 6:00-6:30 AM   | 25            | 24<br>10    |           | 00-2:30 PM  | 701           | 702         |           | 10:00-10:30 PM | 000               | 1000        |           |
+| 6:30-7:00 AM   | 50<br>0       | り<br>10     |           | 30-3:00 PM  | 031           | 732         |           | 10:30-11:00 PM | 038               | 1039        |           |
+| 7:00-7:30 AM   |               | 186         |           | 00-3:30 PM  |               |             |           | 11:00-11:30 PM | 00                | 1100        |           |
+| 7:30-8:00 AM   |               | 737         |           | 30-4:00 PM  |               |             |           | 11:30-12:00 PM |                   | તેન         |           |
+
+### MORNING WATCH OPERATIONS LIEUTENANT
+
+DAY WATCH OPERATIONS LIEUTENANT EVENING WATCH OPERATIONS LIEUTENANT
+
+A start member must observe all inmates continuous rocked down status, such as administrative detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 a.m. - 12:30 a.m.) followed by another round in the second 30 minutes per 12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least two conducted on an irregular schedule and no more than 40 minutes apar documented.
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+CAPTAIN
+
+| iod of the same hour (example, |              |
+|--------------------------------|--------------|
+|                                | ds are to be |
+|                                | be           |
+|                                |              |
+|                                |              |
+|                                |              |
+|                                |              |
+|                                |              |
+|                                |              |
+|                                |              |
+|                                |              |
+
+
+
+
+
+# MCC NEW YORK SPECIAL HOUSING UNIT 30 MINUTE CHECK SHEET ZB 8 81-
+
+DATE:
+
+
+
+MOO MEW YORK
+
+| TIME<br>RAME                              | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                            | TIME<br>START | TIME<br>END | SIGNATURE | TIME FRAME                                 | TIME<br>START | TIME<br>END | SIGNATURE |
+|-------------------------------------------|---------------|-------------|-----------|---------------------------------------|---------------|-------------|-----------|--------------------------------------------|---------------|-------------|-----------|
+| 12:00-12:30 AM                            | 17:<br>65     | 1202        |           | 8:00-8:30 AM                          | 8.25          | 8:27        |           | 4:00-4:30 PM                               |               | OD WORK     |           |
+| 12:30- 1:00 AM                            | 1230          | 12:53       |           | 8:30- 9:00 AM                         | 6.46          | 6.46        |           | 4:30-5:00 PM                               |               | 4357        |           |
+| 1:00-1:30 AM                              | :00           | 03          |           | 9:00-9:30 AM                          | G:12          | 4.14        |           | 5:00 -5:30 PM                              | ાવી           | 15/V        |           |
+| 1:30-2:00 AM                              | 130           | 33          |           | 9:30-10:00 AM                         | 9.50          | 9:52        |           | 5:30-6:00 PM                               |               | 4           |           |
+| 2:00-2:30 AM                              | 000           | 55          |           | 10:00-10:30 AM                        | 10.17         | 10.10       |           | 6:00-6:30 PM                               |               | ర్<br>0     |           |
+| 2:30-3:00 AM                              | 250           | 123         |           | 10:30-11:00 AM                        | C 41          | 10.43       |           | 6:30-7:00 PM                               |               | 024         |           |
+| 3:00-3:30 AM                              | 500           | 502         |           | 11:00-11:30 AM                        | 11.22         | 11.24       |           | 7:00-7:30 PM                               |               | 196         |           |
+| 3:30-4:00 AM                              | 340           | 1990        |           | 11:30-12:00 AM                        | 11:44         | 11-46       |           | 7:30-8:00 PM                               |               |             |           |
+| 4:00-4:30 AM                              | બ્લેટ         | 400h        |           | 12:00-12:30 PM                        | 12:26         | 12:28       |           | 8:00-8:30 PM                               | 02            | 04          |           |
+| 4:30-5:00 AM                              | HY<br>ப       | 22<br>A     |           | 12:30- 1:00 PM                        | 12:40         | 12:42       |           | 8:30- 9:00 PM                              | 30            | 832         |           |
+| 5:00 -5:30 AM                             | 500           | 505         |           | 1:00-1:30 PM                          | 1:11          | :13<br>。    |           | 9:00-9:30 PM                               |               | 170         |           |
+| 5:30-6:00 AM                              | 000           | 533         |           | 1:30-2:00 PM                          | 1.37          | 1.39        |           | 9:30-10:00 PM                              |               |             |           |
+| 6:00-6:30 AM                              | 600           | 19 00       |           | 2:00-2:30 PM                          | 7:44          | 2:11        |           | 10:00-10:30 PM                             |               | 001 VOOS    |           |
+| 6:30-7:00 AM                              | 6 40          | 633         |           | 2:30-3:00 PM                          | 1:50          | 7.51        |           | 10:30-11:00 PM                             |               |             |           |
+| 7:00-7:30 AM                              | 1 00          | 703         |           | 3.00-3:30 PM                          | 3.23          | 3:25        |           | 11:00-11:30 PM                             |               | 10/113      |           |
+| 7:30-8:00 AM                              | 7 30          | 1733        |           | 3:30-4:00 PM                          | 3.39          | 3.41        |           | 11:30-12:00 PM                             |               | 44147       |           |
+|                                           |               |             |           |                                       |               |             |           |                                            |               |             |           |
+| MORNING WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | DAY WATCH<br>OPERATIONS<br>LIEUTENANT |               |             |           | EVENING WATCH<br>OPERATION'S<br>LIEUTENANT |               |             |           |
+
+A staff member must observe all inmates confined in a continuous locked down status, such as administrative detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00 a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
+
+REVIEWED BY MORNING WATCH LIEUTENANT
+
+CAPTAIN
+
+
+
+CON
+
+SDNY 00011248 EFTA00034522

content-documents/ds8/bf/EFTA00034611.md

@@ -0,0 +1,121 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00034611)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00034611"
+ocrPages: 0
+ocrChars: 15371
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| Name:                                                                           |  |
+|---------------------------------------------------------------------------------|--|
+| Position:                                                                       |  |
+| Agency/Component/ Office:                                                       |  |
+| User account name to access<br>network:                                         |  |
+| List all email addresses that<br>you use (or have used) for<br>agency business: |  |
+| Work telephone number:                                                          |  |
+| Date Legal Hold Notice was<br>received:                                         |  |
+
+Based on instructions by my agency's counsel and attorneys for the Department of Justice, I conducted a search for documents which may be responsive to the documents requested in the INMATE DEATH le al and as outlined in the legal hold distributed by counsel on Aug 14 see, Thcsc documcnts arc knOwnts "potcntiatrirsbonsive CoCitments").
+
+will not move or cony any files at this time. I acknowledge that I should not destroy, discard, alter, or make inaccessible any potentially responsive documents. If I discover any potentially responsive documents have been altered or destroyed, for whatever reason, I will immediately contact agency counsel. In the event that I leave the agency or change positions within the agency, I will work with my supervisor and agency counsel to make sure that any potentially responsive documents continue to be retained.
+
+| A.  | Electronic r                                                                                                                                                       | Yes or No |
+|-----|--------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
+| Al. | Electronic Files: Home drive(s) and/or Network Drives                                                                                                              |           |
+|     | There arc potentially relevant records on my Home Drive.                                                                                                           |           |
+|     | If applicable, please identify specific folders on your home drive where your relevant<br>records are saved:                                                       |           |
+|     | Who else (users or work units) has access to this home drive?                                                                                                      |           |
+|     | There arc potentially relevant records on my Shared Drive. If yes and if applicable, I<br>used the following criteria (e.g., subject matter folder; search terms): |           |
+|     | Please list the name(s) of the shared drive(s) to which you save files:                                                                                            | •••••     |
+
+ATTORNEY CLIENT COMMUNICATION/PRIVILEGED
+
+|     | If applicable, please identify specific folders on your shared drive where your<br>relevant records are saved:                                                                         |   |
+|-----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---|
+|     | Who else (users or work units) has access to this share drive?                                                                                                                         |   |
+| A2. | Electronic Files: Emails                                                                                                                                                               |   |
+|     | There arc potentially relevant records in my emails and/or archived emails. If yes<br>and if applicable, I used the following criteria (e.g., subject matter folder; search<br>terms): |   |
+|     | Please identify all locations where you archive emails (home, share, or local drives,<br>removable media, etc.):                                                                       |   |
+|     | Please identify all Groupwise Resource boxes that you have access to which may<br>contain relevant email/documents:                                                                    |   |
+|     | If applicable, please identify specific folders on your home drive where your relevant<br>emails are archived:                                                                         |   |
+|     | Are you pan of any pre-established email distribution groups? If so, please list:                                                                                                      |   |
+|     | If applicable, please identify specific folders on your shared drive where your<br>relevant emails are archived:                                                                       | I |
+|     | If applicable, please identify specific folders on your local drive where your relevant<br>emails are archived:                                                                        |   |
+| A.5 | Electronic Files: Databases                                                                                                                                                            |   |
+|     | I have access to agency databases or systems that may contain potentially responsive<br>documents                                                                                      |   |
+|     | If so, those databases and/or systems are listed below:                                                                                                                                |   |
+
+#### ATTORNEY CLIENT COMMUNICATION/PRIVILEGED
+
+| B.  | Files on Other Media (CD, DVD, Flash Drive, Other)                                                                                                                       | Yes or No |
+|-----|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
+| Bl. | Archived Electronic Files:                                                                                                                                               |           |
+|     | I archive/backup/save certain documents/electronic files onto media.<br>For example, CDs/DVDs, or portable storage devices (usb drives).                                 |           |
+|     | I searched the above media for potentially responsive documents. If yes and if<br>applicable, I used the following criteria (e.g., subject matter folder; search terms): |           |
+|     | I located potentially responsive documents on the above media.                                                                                                           |           |
+|     | These potentially responsive documents can be found at the following locations<br>and are labeled:                                                                       |           |
+
+| C.  | Hard Copy Files                                                                                                                                                        | Yes or No |
+|-----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
+| C1. | My Office workspace                                                                                                                                                    |           |
+|     | I searched hard copy files in my office or workspace (e.g., filing cabinets,<br>desk, desk drawers, boxes, bookshelves, etc.) for potentially responsive<br>documents. |           |
+|     | I located potentially responsive, hard copy documents.                                                                                                                 |           |
+|     | These potentially responsive documents can be found at the following locations<br>and arc labeled:                                                                     |           |
+| C2. | Repositories (Off-site or on location)                                                                                                                                 |           |
+|     | I searched hard copy files in a repository, library, archive, or records unit for<br>potentially responsive documents.                                                 |           |
+|     | I have reviewed the storage indices for a repository, library, archive, or records<br>unit for potentially responsive documents.                                       |           |
+|     | There is no such repository, library, archive, or records unit for my unit/office.                                                                                     |           |
+|     | I located potentially responsive documents.                                                                                                                            |           |
+|     | These potentially responsive documents can be found at the following locations<br>and are labeled:                                                                     |           |
+
+ATTORNEY CLIENT COMMUNICATION/PRIVILEGED
+
+|    | Have you given files that might be subject to the legal hold to any<br>other<br>employee? If yes, what and to whom?                                                                                                                                     |  |
+|----|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
+|    | Did you inherit electronic or hard copy files from any other (i.e. an out<br>going) employee that might be relevant to the legal hold? If so, where are<br>they?                                                                                        |  |
+|    |                                                                                                                                                                                                                                                         |  |
+|    | List all government-issued devices you use for work. (laptop, desktop,<br>iPhone, cellphone, black berry, iPad, tablets, etc.).                                                                                                                         |  |
+|    | For each piece of equipment listed above, was the equipment upgraded<br>within the past year? Was all data transferred successful?                                                                                                                      |  |
+|    | For each piece of equipment listed above, was the equipment replaced<br>within the past year? Was all data transferred to the new equipment?                                                                                                            |  |
+|    | Do you have texts, instant messages, or voice mails on your government<br>equipment that would be potentially relevant to the subject matter of this<br>litigation (please refer to the legal hold notice for a description of the<br>subject matters)? |  |
+|    | List all personal devices you use for work. (laptop, desktop, phones,<br>tablets, etc.). Are there work-related data or files saved on these devices?                                                                                                   |  |
+|    | Do you have any work-related files at home? Hard copy documents/<br>removable media, etc.?                                                                                                                                                              |  |
+|    | Do you have texts, instant messages, or voice mails on your personal<br>devices that would be potentially relevant to the subject matter of this<br>litigation (please refer to the legal hold notice for a description of the<br>subject matters)?     |  |
+|    |                                                                                                                                                                                                                                                         |  |
+| E. | Other relevant information                                                                                                                                                                                                                              |  |
+|    | Can you identify other emplo>ces who may have relevant information? If<br>so, list them here:                                                                                                                                                           |  |
+|    |                                                                                                                                                                                                                                                         |  |
+| F. | '                                                                                                                                                                                                                                                       |  |
+|    | Do you engage in social media activities/communications as a part of                                                                                                                                                                                    |  |
+
+ATTORNEY CLIENT COMMUNICATION/PRIVILEGED
+
+| yourofficial duties?                                                        |  |
+|-----------------------------------------------------------------------------|--|
+| If so, were any of your social media activities/communications related to   |  |
+| the subject of this litigation (please rcfcr to the legal hold notice for a |  |
+| description of the subject matters)? Please identify all such               |  |
+| communications/activities:                                                  |  |
+|                                                                             |  |
+
+I acknowledge that I will work with agency counsel and the appropriate agency IT personnel before collecting the potentially responsive documents identified above to determine whether procedures arc in place to ensure that tracking information and metadata (where applicable) is preserved before and during the collection process.
+
+Signature Date
+
+### OR IF APPLICABLE, SEARCHES RESULTED IN NO DOCUMENTS:
+
+| As a result of my searches, I did not find any responsive documents. |      |
+|----------------------------------------------------------------------|------|
+| Signature                                                            | Date |
+
+Please contact with any questions.
+
+We appreciate your assistance and diligence in this important matter.
+
+ATTORNEY CLIENT COMMUNICATION/PRIVILEGED

content-documents/ds8/bf/EFTA00035374.md

@@ -0,0 +1,26 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00035374)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00035374"
+ocrPages: 0
+ocrChars: 680
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+- The memo is very confusing. Please draft an email of his actions and current status. Also include what plans were in motion to move him to a GP unit. It will need to be something I can forward to IPPA and the Director.
+
+Sent from my Verizon, Samsung Galaxy smartphone
+
+| messa e<br>From:<br>Date: 7/23/19 11:12 AM GMT-05:00 |
+|------------------------------------------------------|
+| To:<br>Subject: Fwd: Epstein                         |
+| >»<br>' 07/23/2019 11:12 >»                          |
+| Sent from my Vcrizon, Samsung Galaxy smartphone      |
+| Ori inal messa e                                     |
+
+From: " Date: 7/23/19 10:55 AM GMT-05:00 To: Subject: Fwd: Epstein

content-documents/ds8/bf/EFTA00036775.md

@@ -0,0 +1,100 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036775)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036775"
+ocrPages: 0
+ocrChars: 3137
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: ""Party City" <partycitygemail.partycity.com>" <partycity@email.partycity.com>
+
+
+
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+Standard text message and data charges apply. For the terms and conditions of our text message program. welt Terms & Privacy. Texts may be sent using an automatic telephone dieing system. Consent not required for any purchase from Party City. Message frequency is recurring. Not all mobile carriers are supported. To opt out. Text STOP to 94467. For help, text HELP to 94467.
+
+Actual retal prices in your area may be substanbally different. Al prices are subgect to change without notice. Wade Party City strives to provide accurate pacing information. pricing or typocyaphocal errors may occur. Party City reserves the right to correct any errors, inaccuracies or omissions and to change or update information related to pricing and availability at any time without notice. Party City cannot confirm the price of an item until after you order. In the event that an item is listed at an incorrect price due to an error in pricing. Party City shall have the right. at Party City's sole discretion, to refuse or cancel any orders placed with that item. In the event that an item r3 mispnced. Party City may. at Party City's discretion. either contact you for instructions or cancel your order and nobly you of such cancellation. Product selection. avadabiny and pacing panicipation may vary by store or online. Valid in US stores and online only.
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content-documents/ds8/bf/EFTA00036861.md

@@ -0,0 +1,25 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036861)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036861"
+ocrPages: 0
+ocrChars: 339
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+Good Afternoon,
+
+It is showing that you have not completed the Nasal Naloxone training. Please take a minute, log in BLU and complete the training and notify me when it is done. Thank you.
+
+HSD•0630•BXX Nasal Naloxone Administration NYM NYM/BUSINESS OFFICE
+
+BUM ANAL 8/16/2019
+
+Associate Warden MCC New York
+
+New York. New York 10007 Oflic

content-documents/ds8/bf/EFTA00037097.md

@@ -0,0 +1,13 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00037097)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00037097"
+ocrPages: 0
+ocrChars: 4
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---

content-documents/ds8/bf/EFTA00037186.md

@@ -0,0 +1,28 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00037186)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00037186"
+ocrPages: 0
+ocrChars: 5859
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| IV (659) Inbo                                                                                    |                                                                                                                                                                            | Epstein Employee - Dropbox<br>tz                                                                                                                                                                                                                                                                                                                                                                                           |                            |
+|--------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|
+| * HOME<br>MAIL                                                                                   | NEWS<br>FINANCE<br>SPORT<br>CELEBRITY                                                                                                                                      | MORE<br>STYLE<br>WEATHER                                                                                                                                                                                                                                                                                                                                                                                                   |                            |
+| yahoolmail                                                                                       | Find messages, documents, photos or people                                                                                                                                 | ct<br>Advanced s,                                                                                                                                                                                                                                                                                                                                                                                                          |                            |
+| Compose                                                                                          | <— Back                                                                                                                                                                    | ei Archive<br>m Delete<br>rim Move<br>Spam<br>• • •                                                                                                                                                                                                                                                                                                                                                                        |                            |
+| Inbox<br>Unread<br>Starred<br>Drafts<br>21<br>Sent<br>Archive<br>Spam<br>Deleted Items<br>A Less | From<br>Se t:<br>rnaay. reoruary 09, LOU/<br>To<br>Subject: RE: FIT website<br>end of the month. Can you please check with Jeffery and let me know.<br>Thanks ever so much | Sorry for the delay. Here is my essay and thank you for letting me know that you recieved my application otherwise I would start to worry. Also I<br>really do need a flight booked back to New York preferably the 27th as it is high season here and there might not be any avalable flights at the<br>RS Could you also let him know that I am going to three different modelling agencies on Monday in search of a PA. |                            |
+| Hide<br>Views<br>!!! Photos<br>b Documents<br>;tI<br>s<br>Subscriptions<br>4- Travel             | The fish are biting.<br>Get more visitors<br>on your site using Yahoo! Search Marketing.                                                                                   | •••<br><4<br>4%                                                                                                                                                                                                                                                                                                                                                                                                            | Fri, 9 Feb 2007 at 22:09 * |
+| Show<br>Folders                                                                                  | H                                                                                                                                                                          | I will be flying from Cape Town International to New York hopefully on the 27th of Feb. As I do not have a visa yet I will need a return ticket but a<br>return to the UK (London). As I am on the visa waver I am only allowd to spend a maximum of 90 days in the US, so with the return ticket if you                                                                                                                   |                            |
+
+
+
+Thanks
+
+Finding fabulous fares is fun. Let Yahoo! FareChase search your favorite travel sites to find flight and hotel bargains.

content-documents/ds8/bf/EFTA00038543.md

@@ -0,0 +1,39 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038543)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038543"
+ocrPages: 0
+ocrChars: 1336
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| To:                                              |  |  |
+|--------------------------------------------------|--|--|
+| Subject: RE:                                     |  |  |
+| Date: Mon, 22 Feb 2021 17:58:12 +0000            |  |  |
+| Importance: Normal                               |  |  |
+| Sure. Her details are below. The case number is  |  |  |
+|                                                  |  |  |
+|                                                  |  |  |
+|                                                  |  |  |
+|                                                  |  |  |
+| Thanks for following up!                         |  |  |
+|                                                  |  |  |
+| Special Agent                                    |  |  |
+| FBI New York Field Office                        |  |  |
+|                                                  |  |  |
+| Child Exploitation/Human Trafficking             |  |  |
+| Desk.                                            |  |  |
+|                                                  |  |  |
+| From<br>Sent: Monday, February 22, 2021 11:43 AM |  |  |
+
+It sounds like our VS is having a hard time getting in touch with Can you send me her full name, DOB, and your caseff so I can run her in NCIC and maybe she has been arreste recent y somewhere.
+
+Thanks,
+
+Durango RA

content-documents/ds8/c0/EFTA00014557.md

@@ -0,0 +1,33 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014557)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014557"
+ocrPages: 0
+ocrChars: 294
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+## Event: Accepted: Epstein discovery deadline
+
+Start Date: 2019-10-31 21:00:00 +0000
+
+End Date: 2019-10-31 21:00:00 +0000
+
+Class: X-PERSONAL
+
+Comment:
+
+Date Created: 2019-07-31 16:48:30 +0000
+
+Date Modified: 2019-07-31 16:48:30 +0000
+
+Priority: 5
+
+DTSTAMP: 2019-07-31 16:08:35 +0000
+
+Attendee:

content-documents/ds8/c0/EFTA00014598.md

@@ -0,0 +1,207 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014598)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014598"
+ocrPages: 0
+ocrChars: 15941
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Thanks for the heads up
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York. NY 1
+
+Please excuse typographical errors. Messages sent through dictation.
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+On Jul 17, 2019, at 2:08 PM, > wrote:
+
+Michael,
+
+Just in an abundance of caution, wanted to let you know that our conference in this case tomorrow was just moved from 9:30 a.m. to 11:30 a.m. We think that should still leave more than enough time to complete the hearing and be back for our 2:00 discussion, but we wanted to advise in case the conference goes extraordinarily long — if so, we'll come back to meet you as soon as it is completed.
+
+Shanks
+
+| From: Michael Bachner              |    |  |
+|------------------------------------|----|--|
+| Sent: Monday, July 15, 2019 19:52  |    |  |
+| To:                                |    |  |
+| Cc:                                | >; |  |
+| Subject: Re: Epstein investigation |    |  |
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York, NY 10006
+
+Please excuse typographical errors. Messages sent through dictation.
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+| On Jul 15, 2019, at 7:29 PM,                                                              | > wrote: |
+|-------------------------------------------------------------------------------------------|----------|
+| Hi Michael,                                                                               |          |
+| How about Thursday afternoon?                                                             |          |
+| Thanks.                                                                                   |          |
+| Assistant United States Attorney<br>Southern District of New York<br>I St. Andrew's Plaza |          |
+| From: Michael Bachner<br>Sent: Monday, July 15, 2019 7:20 PM<br>To:                       |          |
+
+Any updates on dates?
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York NY 10006
+
+ographical errors. Messages sent through dictation.
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+On Jul 15, 2019, at 2:28 PM, Michael Bachner wrote:
+
+I was just notified that a client was arrested and is being arraigned in Queens County tomorrow on a state RICO charge at about 11 or 1130. I'm concerned that the 330 may be cutting it close. It may be better to do it at four or on Wednesday. Please advise
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York, NY 10006
+
+Please excuse typographical errors. Messages sent through dictation. <--WRD000.jpg>I
+
+### https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+| On Jul 15, 2019, at 1:55 PM,                                                                                                              | l> wrote:                       |
+|-------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|
+| Thanks very much. Let's plan for tomorrow at 3:30pm. You and<br>Andrews and just give security my name.                                   | can come to our office at 1 St. |
+| Best,                                                                                                                                     |                                 |
+| Assistant United States Attorney<br>Southern District of New York<br>1 St. Andrew's Plaza<br>N w Y rk NY 10 07                            |                                 |
+| Original Message<br>From: Michael Bachner<br>Sent: Monday,July 15, 2019 1:42 PM<br>To:<br>Cc:<br>Subject: RE: Epstein investigation<br>Hi |                                 |
+| Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.                                                                  |                                 |
+
+### https://www.actl.com/
+
+Michael Bachner, Esq. Bachner & Associates, PC 39 Broadway, Suite 1610
+
+www.bhlawfirm.com
+
+CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally privileged. If you are not the intended recipient, you are hereby notified that any retention, dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the sender that you have received the message in error and then delete it. Thank you.
+
+| Original Message<br>) [mailto:<br>From:<br>Sent: Monday, July 15 2019 12:50 PM<br>To: Michael Bachner<br>Cc:                                                                    |  |
+|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
+| Subject: Re: Epstein investigation                                                                                                                                              |  |
+| Hi Michael,                                                                                                                                                                     |  |
+| Apologies for the delay. Would you please let us know what times would work for you and<br>in<br>the next two or three days? We'll then figure out a time when we can all meet. |  |
+| Thank                                                                                                                                                                           |  |
+| On Jul 11, 2019, at 10:43 PM, Michael Bachner<br>wrote:                                                                                                                         |  |
+| 6 o'clock is somewhat late. The client lives in<br>Hello                                                                                                                        |  |
+| Michael Bachner<br>Bachner & Associates, PC<br>39 Broadway-Suite 1610<br>New York, NY 10006                                                                                     |  |
+
+ease excuse pographical errors. Messages sent through dictation. [X]
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+| On Jul 11, 2019, at 9:01 PM, |         |          |
+|------------------------------|---------|----------|
+|                              | mailto: | > wrote: |
+|                              |         |          |
+
+Michael,
+
+Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?
+
+| Thanks, |
+|---------|
+|---------|
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza
+
+|                                    | mailto:          |  |  |  |
+|------------------------------------|------------------|--|--|--|
+|                                    |                  |  |  |  |
+|                                    |                  |  |  |  |
+| From: Michael Bachner              |                  |  |  |  |
+| Sent: Thursda<br>Jul               | 0191226 PM<br>11 |  |  |  |
+| To:                                |                  |  |  |  |
+| Cc:                                |                  |  |  |  |
+|                                    |                  |  |  |  |
+| Subject: Re: Epstein investigation |                  |  |  |  |
+|                                    |                  |  |  |  |
+
+Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o'clock meeting in my office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in the morning if that works. Please let me know
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York NY 10006
+
+ease excuse pograp ical errors. Messages sent through dictation. <—WRD000.jpg>
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+On Jul 10, 2019, at 11:20 AM. Michael Bachner wrote: Sure.
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York, NY 10006
+
+x us typographical errors. Messages sent through dictation. <—WRD000.jpg>
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+| On Jul 10 2019, at 11:08 AM, |         |          |
+|------------------------------|---------|----------|
+|                              | mailto: | > wrote: |
+| Mike,                        |         |          |
+
+I think it would be useful to get a better understanding of your position—it would be helpful for us to know, for example, how much time you propose to take to evaluate matters, and whether we can provide any additional information that might be useful for that process of evaluation. That likely will affect our determination regarding the grand jury appearance, at which we would expect, were we to call to ask her a number of questions we would expect to argue to the court do not implicate a fifth amen ent privilege—i.e., that she couldn't simply blanket invoke. Would it be useful to discuss via phone?
+
+thanks,
+
+| From: Michael Bachner<br>Sent: Wednesda<br>Jul | 10 2019 10:25 |        |  |
+|------------------------------------------------|---------------|--------|--|
+| To:                                            |               | mailto |  |
+| Cc:                                            |               |        |  |
+| Subject: Re: Epstein investigation             |               |        |  |
+
+Dear Counsel:
+
+I met wit and I need time to evaluate matters. Regardin the sub na to testify before the Grand Jury o we hereby notify you that if called as a witness would invoke her Fifth Amendment privilege against compelled self-incrimination. Please let me know if you will require her to invoke in person or whether this communication suffices and no appertaining will be required.
+
+Yours truly,
+
+Michael Bachner
+
+Michael Bachner Bachner & Associates, PC 39 Broadway-Suite 1610 New York NY 10006
+
+ease excuse pographical errors. Messages sent through dictation. <—WRD026.jpg>
+
+https://www.actl.com/
+
+NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by email and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
+
+| On Jul 9 2019, at 11:43 AM, |         |          |
+|-----------------------------|---------|----------|
+|                             | mailto: | > wrote: |
+|                             |         |          |
+
+Mr. Bachner,
+
+Following up on our conversation earlier this morning, we wanted to provide you with the additional information and materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to reach out to any of us at any time; we're all available via email or at the following phone numbers:
+
+Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida, and a blank version of our standard proffer agreement, both as discussed.
+
+As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a time to speak again after you're able to confer with
+
+thank you
+
+Assistant U.S. Attorney ' York
+
+<blank proffer agreement.pdf> <Epstein NPA, dated 2007-09-24.pdf>

content-documents/ds8/c0/EFTA00014664.md

@@ -0,0 +1,48 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014664)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014664"
+ocrPages: 0
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+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+The Court has issued a scheduling order for the trial (attached). Jury selection will occur during the week of November 15th, and the trial will begin on November 29th.
+
+Thanks,
+
+| From:                                                                                                                                                                                         |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| Sent: Friday, May 7, 2021 2:14                                                                                                                                                                |
+| To:                                                                                                                                                                                           |
+| Cc                                                                                                                                                                                            |
+| (USANYS)<br>Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)                                                                                                                 |
+| Everyone is all clear for November/December.                                                                                                                                                  |
+| Sent from my iPhone                                                                                                                                                                           |
+|                                                                                                                                                                                               |
+| wrote:<br>On May 7, 2021, at 1:27 PM,                                                                                                                                                         |
+|                                                                                                                                                                                               |
+| Following up on our conversation yesterday, please let us know if there are any scheduling conflicts we should be aware<br>of. Our letter to the Court regarding scheduling is due on Monday. |
+| Thanks very much,                                                                                                                                                                             |
+|                                                                                                                                                                                               |
+
+| From                                 |    |  |
+|--------------------------------------|----|--|
+| Sent: Thursday, May 6, 2021 12:57 PM |    |  |
+| To:<br><                             | >  |  |
+| Cc: Brittany Henderson               | >; |  |
+| (USANYS)                             |    |  |
+|                                      |    |  |
+
+Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+
+
+
+Assistant United States Attorney Southern District of New York

content-documents/ds8/c0/EFTA00014907.md

@@ -0,0 +1,38 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014907)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014907"
+ocrPages: 0
+ocrChars: 1912
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From:        |                                       |                                                       |  |  |
+|--------------|---------------------------------------|-------------------------------------------------------|--|--|
+|              |                                       |                                                       |  |  |
+|              |                                       |                                                       |  |  |
+|              |                                       |                                                       |  |  |
+| Subject: FW: |                                       | Fan Club Request                                      |  |  |
+|              | Date: Tue, 30 Nov 2021 12:44:56 +0000 |                                                       |  |  |
+|              |                                       | Attachments: 2021.11.29_Openings,_Visoskiipublie).PDF |  |  |
+
+fan club is requesting a transcript of the opening. Can you please let me know whether it's okay to send Martin the public transcript from yesterday, attached?
+
+| From:                                    |  |
+|------------------------------------------|--|
+| Sent: Tuesday, November 30, 2021 1:37 AM |  |
+| To:                                      |  |
+| Subject: (EXTERNAL]<br>Fan Club Request  |  |
+
+Hope you're doing well. I am having a good time although I miss you and the Office, and I am still trying to figure out what to do with my brunches now that Heights Café / Giulia's is for-real gone.
+
+I have a special request. I am a massive fan, having done the retrial with her back in the day. And my partner and former Office guy is one of her mentors and counts himself a massive fan also. We weren't able to be there for the opening yesterday. We'd love a transcript. Can you get us one?
+
+Thanks, m
+
+Martin S. Bell (bio) Sim pson Thacher & Bartlett LLP

content-documents/ds8/c0/EFTA00014963.md

@@ -0,0 +1,50 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014963)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014963"
+ocrPages: 0
+ocrChars: 1175
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+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+11/26/21, 7:20 PM Mail - (NY) (FBI) - Outlook
+
+|  |  |  |  | [EXTERNAL EMAIL] - Re: Spreadsheets |
+|--|--|--|--|-------------------------------------|
+|--|--|--|--|-------------------------------------|
+
+|            | Wed 10/13/2021 10:SS AM    |          |
+|------------|----------------------------|----------|
+| To:<br>Cc: |                            |          |
+|            | Disregard                  |          |
+|            |                            |          |
+|            | On Oct 13, 2021, at 10:49, | > wrote: |
+
+Is this for the trial exhibit material? I sent it last week
+
+
+
+FYI
+
+They had asked me to ask you about this project. Not sure if you were aware of this.
+
+Begin forwarded message:
+
+
+
+Subject: Spreadsheets
+
+## CAUTION! EXTERNAL SENDER
+
+STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide user ID or password. Suspicious? Please report to this email address: Lep.oaphishing@jaypd.org
+
+Just spoke with El about this to check in, but if we could get these spreadsheets by tomorrow morning that would be ideal.
+
+Thanks!
+
+httpswoulloolcoffice365.usimailldeeplinlOpopoutv2=1&version=20211025002.13 2/2

content-documents/ds8/c0/EFTA00016865.md

@@ -0,0 +1,215 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00016865)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00016865"
+ocrPages: 0
+ocrChars: 26466
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+## LAST WILL AND TESTAMENT
+
+## OF
+
+## JEFFREY E. EPSTEIN
+
+I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made by me.
+
+FIRST: A. I direct my Executor to pay from my estate my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven and allowed against my estate.
+
+B. I direct my Executor to pay from my estate the federal and state transfer taxes described in Paragraph B(l) of Article SEVENTH.
+
+C. I direct my Executor to pay from my estate all expenses of storing, insuring, packing, shipping and delivering my tangible personal property.
+
+SECOND: I give all of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein Trust One created under that certain Trust Agreement (the "Trust Agreement") dated November 8, 2001, as amended from time to time, and as amended and restated contemporaneously with the execution of this Will, and as the same may be amended from time to time, to be held in accordance with the provisions comprising the Trust Agreement at the time of my death.
+
+THIRD: A. I appoint DARREN K. INDYKE, JOSEPH PAGANO and LAWRENCE NEWMAN to be the Executors of this Will. If any one or more of my Executors fails to qualify or ceases to act, I appoint JES STALEY and ANDREW FARKAS, singly and in the order named, as successor Executors. I authorize the last acting Executor to designate his successor as Executor.
+
+B. If my estate must be administered in whole or in part in any jurisdiction other than the state of my domicile at the date of my death and if my Executor is unable or unwilling to serve in such jurisdiction, then I appoint the first successor Executor of my estate designated in Paragraph A of Article THIRD who is able and willing to serve in such jurisdiction. If no Executor or successor Executor is able and willing to serve in
+
+2657367.1
+
+such jurisdiction, my Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be made by written instrument delivered to such successor Executor.
+
+C. No bond or other security shall be required of any Executor in any jurisdiction.
+
+D. Any Executor may resign by filing a written notice of resignation with the Court having jurisdiction of the administration of my estate. All of my Executor's fees and expenses (including attorneys' fees) attributable to the appointment of a successor Executor shall be paid by my estate.
+
+E. My Executor shall not be accountable or responsible to any person interested in my estate for the manner in which my Executor in good faith exercises or declines to exercise any discretionary authority or power of my Executor. My Executor shall not be liable for any loss or depreciation in value occasioned by reason of any negligence, error or mistake of judgment in entering into any transaction, in making any sale or investment, in continuing to hold any property or by reason of any action or omission, whether by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted within the scope of my Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted impartially as to all interested persons. An Executor shall not be liable for the acts or defaults of another Executor.
+
+FOURTH: The following provisions shall apply to my estate and to my Executor, except as is otherwise specifically provided in this Will:
+
+(1) My Executor has the entire care and custody of all assets of my estate. My Executor has the power to do everything my Executor in good faith deems advisable without necessity of any judicial authorization or approval, even though but for this power it would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My Executor shall exercise my Executor's best judgment and discretion for what my Executor believes to be in the best interests of the beneficiaries hereunder. If more than two Executors are empowered to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, a majority of such Executors shall be empowered to make such decision.
+
+- B. Except as otherwise provided herein, my Executor
+shall have the power:
+
+(1) to enter upon and take possession of the assets of my estate and collect the income and profits from such assets, and to invest and reinvest such assets in real, personal or mixed assets (including the common trust funds of a corporate fiduciary) or in undivided interests therein without being limited by any present or future investment laws;
+
+(2) to retain all or any part of the assets of my estate (without regard to the proportion that any one asset or class of assets may bear to the whole) in the form in which such assets were received or acquired by my Executor;
+
+2
+
+2657367.1
+
+(3) to sell or dispose of, exchange, transfer, invest or loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such sums or upon such terms as to payment, security or otherwise as my Executor determines, either by public or private transactions;
+
+(4) to buy and sell options, warrants, puts, calls or other rights to purchase or sell (collectively "options") relating to any security or securities, regardless of whether such security or securities are then held by my Executor, and whether such options are purchased or sold on a national securities exchange, and to exercise with respect to such options all powers which an individual owner thereof could exercise, including, without limitation, the right to allow the same to expire;
+
+(5) with respect to oil, natural gas, minerals, and all other natural resources and rights to and interests therein (together with all equipment pertaining thereto) including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or impose conditions on the transfer of any such rights or interests; (g) to employ the most advantageous business form in which properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships, mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to produce, process, sell or exchange all products recovered through the exploitation of such rights and interests, and to enter into contracts and agreements for or in respect of the installation or operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator of such property; and (k) to employ personnel, rent office space, buy or lease office equipment, contract and pay for geological surveys and studies, procure appraisals, and generally to conduct and engage in any and all activities incident to the foregoing powers, with full power to borrow and pledge in order to finance such activities; together with the power to allocate between principal and income any net proceeds received as consideration, whether as royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other natural resources;
+
+(6) to hold all or any part of the assets of my estate in cash or in bank accounts without the necessity of investing the same;
+
+(7) to improve, repair, partition, plat or subdivide all or any part of the assets of my estate;
+
+(8) to litigate, defend, compromise, settle, abandon or submit to arbitration on such terms and conditions as my Executor determines any claims in favor of or against my estate or the assets of my estate;
+
+(9) to loan or borrow money in such amounts and upon such terms and conditions as my Executor determines, assume such obligations or give such guarantees as my Executor determines, for the purpose of the acquisition, improvement, protection, retention or preservation of the assets of my estate, or for the welfare of the beneficiaries of my estate;
+
+(10) to carry on for as long and in such manner as my Executor determines any business enterprise in which I owned any interest at my death, either individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or undertake any other extraordinary corporate transaction relating to such business enterprise;
+
+(11) to vote in person or by proxy any and all stock or securities and to become a party to any voting trusts, reorganization, consolidation or other capital or debt readjustment of any corporation, association, partnership, limited liability partnership, limited liability company or individual with respect to stocks, securities or debts held by my estate;
+
+(12) to enter into any good faith transactions with my Executor individually or with any corporation, partnership or other entity in which my Executor has an ownership interest;
+
+(13) to lease, mortgage, pledge, grant a security interest in or otherwise encumber all or any part of the assets of my estate for any term of years whether or not beyond the duration of my estate (including, without limitation, any such action for the benefit of any of the beneficiaries of my estate);
+
+(14) to abandon any property, real or personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or protecting; to abstain from the payment of taxes, water rents or assessments and to forego making repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax sale or other proceedings or to convey any such property for a nominal consideration or without consideration so as to prevent the imposition of any liability by reason of the continued ownership thereof;
+
+(15) to elect the mode of distribution of the proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of such plan;
+
+(16) to allocate, in my Executors discretion, any adjustment to basis provided to my estate under the provisions of Federal and State law with respect to property comprising my estate, without any obligation to make a compensatory adjustment among the beneficiaries hereunder on account of such allocation;
+
+4
+
+G1_000130
+
+(17) to conduct any audit, assessment or investigation with respect to any asset of my estate regarding compliance with any law or regulation having as its object protection of public health, natural resources or the environment ("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be required in my Executor's judgment by any Environmental Law, to notify any governmental authority of any past, present or future non-compliance with any Environmental Law; and
+
+(18) to sell to the Trustee under the Trust Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under the Trust Agreement even though the same person or persons occupy the office of the Executor of my estate and the Trustee under the Trust Agreement.
+
+(19) No executor shall directly or indirectly buy or sell any property for the estate from or to himself, or from or to his relative, employer, employee, partner, or other business associate.
+
+(20) No executor shall lend estate funds to himself, or to his relative, employer, employee, partner, or other business associate.
+
+C. Except as otherwise provided herein, my Executor
+
+shall have the power:
+
+(1) to employ agents, attorneys-at-law, consultants, investment advisers (to whom my Executor has discretion to delegate my Executor's investment authority and responsibility), other executors and other fiduciaries in the administration of my Executor's duties; to delegate to such persons, or to one or more of my
+
+Executors, the custody, control or management of any part of my estate as my Executor determines and to pay for such services from the assets of my estate, without obtaining judicial authorization or approval;
+
+(2) to delegate, in whole or in part, to any person or persons the authority and power to (a) sign checks, drafts or orders for the payment or withdrawal of funds, securities and other assets from any bank, brokerage, custody or other account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may be located or which may be in the name of my Executor and remove part or all of the contents of any such safe deposit box or boxes and release and surrender the same, and (d) take any other action that my Executor may have the power to take with respect to my estate and the property thereof; no person or corporation acting in reliance on any such delegation shall be charged with notice of any revocation or change of such delegation unless such person or corporation receives actual notice thereof;
+
+5
+
+2657367.1
+
+GJ 000131
+
+(3) to pay any property distributable to a beneficiary under a legal disability, without liability to my Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) to a legal representative of such beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor;
+
+(4) to distribute to any of the beneficiaries of my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or disproportionate shares of assets or undivided interests in assets among all of such beneficiaries;
+
+(5) to have evidence of ownership of any security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to deposit funds in any bank or trust company; to carry in the name of my Executor or the nominee or nominees of my Executor and with or without designation of fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting of registration; and to cause any securities to be held by a depository corporation of which an Executor is a member or by an agent under a safekeeping contract; provided, however, that the books and records of my Executor shall at all times show that such investments are part of my estate;
+
+(6) to renounce and disclaim, in whole or in part, and in accordance with applicable law, any assets, interests, rights or powers (including any power of appointment) which are payable to (or exercisable by) me or my estate, which are includible in my estate or Gross Estate or over which I have any right, title, interest or power; and
+
+(7) to make, execute and deliver any and all such instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my estate.
+
+D. In connection with any insurance policy or annuity on the life of an Executor which is included in my estate, such Executor shall not participate in the decision to exercise or not exercise any fiduciary power in connection with any incidents of ownership for such policy or annuity, including, without limitation, any decision to continue, assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or annuity.
+
+E. An Executor hereunder may by a written notice delivered to the other Executor (or Executors) decline to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law.
+
+F. If an Executor is not empowered (because of a conflict of interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, then the remaining Executor or
+
+GJ_0001 32
+
+Executors shall be empowered to make such decision. If no Executor is empowered to participate in such decision, then the first successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing to act shall be empowered to make such decision. If no Executor or successor Executor is empowered to participate in such decision, my Executor may designate a successor Executor to serve as Executor of my estate who shall be empowered to make such decision but shall have no other power or authority of my Executor. Such designation shall be by written notice delivered to such successor Executor.
+
+G. (1) Except as otherwise specifically provided herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and disbursements in accordance with sound trust accounting principles and shall have discretion to allocate receipts and disbursements when the treatment is uncertain under applicable laws or generally accepted accounting principles in the judgment of my Executor.
+
+(2) Except as otherwise specifically provided in this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to distributions of income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any financial instrument originally issued or acquired at a discount equal to the amount which (a) has previously been characterized as ordinary income for income tax purposes or (b) will be characterized as ordinary income for income tax purposes in the year of such sale, as income for trust accounting purposes.
+
+FIFTH: Where a party to any proceeding with respect to my estate has the same interest as a person under a disability, it shall not be necessary to serve legal process on the person under a disability.
+
+SIXTH: If any beneficiary under The Jeffrey E. Epstein 2001 Trust One ("the trust") shall in any way directly or indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or provision of my Will or of the trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, objection or claim for the purpose of setting aside or invalidating my Will or the trust or any disposition therein or provision thereof, then I direct that (a) any and all provisions in the trust for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing under my Will or the trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all failed to survive me.
+
+SEVENTH: A. As used herein:
+
+(I) The term "Executor" of a person's estate means all persons or entities who occupy the office of executor, administrator, personal representative, or ancillary administrator while such persons or entities occupy such office, whether one or more persons or entities occupy such office at the same time or times, and includes any successor or successors to that office. The term "Trustee" means all persons or entities who occupy the office of Trustee under the Trust Agreement while such persons or entities occupy such office, whether one or more persons or entities occupy the office of Trustee
+
+G.1_000133
+
+at the same time or times, and includes any successor Trustee or Trustees. A reference to a person's estate or probate estate means that person's estate which is subject to probate administration. A reference to a person's Will means such person's Last Will and Testament and any Codicil or Codicils thereto.
+
+(2) The term "IRC section" means a section of the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal Revenue law, as in effect as of the date of my death.
+
+(3) A reference to any tax also includes any interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross estate as finally determined for purposes of computing such person's federal estate tax.
+
+(4) Whenever the singular number is used, the same shall include the plural, and the masculine gender shall include the feminine and neuter genders.
+
+B. (1) The federal and state transfer taxes which my Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of all federal and state estate, inheritance, succession, and similar taxes (including any federal or state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph B(2) of this Article, all federal estate taxes with respect to assets not passing under this Will or the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any applicable state estate taxes with respect to the Apportionment Assets shall be apportioned among all persons interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for such taxes from the recipients of the Apportionment Assets. My Executor shall not be personally liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect payment (or reimbursement) from any recipient of any Apportionment Assets for any or all of such taxes allocable to such assets.
+
+(2) My Executor has discretion to direct the Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes
+
+which my Executor directs the Trustee under the Trust Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement as provided under the Trust Agreement.
+
+C. Except as otherwise specifically provided in this Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding
+
+8
+
+Gl_000134
+
+any law to the contrary.
+
+D. To the extent that the distribution to the Trustee under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, be to held in trust under this Will in accordance with the provisions comprising the Trust Agreement at the time of my death, which provisions are incorporated in this Will by reference.
+
+IN WITNESS WHEREOF, I have duly executed this Will the 2 7 4day o .21,n44.7 , 2012.
+
+REY E.
+
+The foregoing written instrument was on the date thereof, signed, published and declared by the Testator therein named as the Testator's Will in the presence of us and of each of us, who, at the Testator's request, in the Testator's presence and in the presence of each er, have s ibed our names as witnesses thereto.
+
+| residing at |                                             |
+|-------------|---------------------------------------------|
+| residing at |                                             |
+|             | //of<br>v 7,<br>iefr Y<br>-affeW, C4<br>14, |
+
+We, JEFFREY E. EPSTEIN, 4 1/14 01 /Artier and, 4a AM et444. 44C ,,,,r" the Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, having been sworn, declared to the undersigned officer that the Testator, in the presence of the witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in presence of the Testator and in the presence of each other, signed the Will as aptness
+
+Oricadne-ent—e )(-4.4.e."-ntea-n.
+
+fr,c STATE OF ) rav y.4ss: COUNTY OFD )
+
+Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the known to me or who has produced as identification, who is personally known to me or who has produced , a witness who is personally known to m as identification, on14/::tailyt7 17 , 2012. Testator, who isp personally and bygia..../ tosho witness as identification, and e or who has produced
+
+Sworn to before me thisn day of January,2012
+
+Notary P lw
+
+HARRY I BELLER Notary No. Public. State of New York 0M:463:424 Qualified in Commission riee!zlend County hi Expires Feb. 17. 20Z.7
+
+2657367.1
+
+G.1_000136
+
+LAST WILL
+
+AND TESTAMENT
+
+OF
+
+## JEFFREY E. EPSTEIN
+
+Dated
+
+, 2012
+
+EFTA00016875

content-documents/ds8/c0/EFTA00016924.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00016924)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+
+
+
+Hi when you can, could you please save these in the Epstein witness folder with file naming convention? Thanks!
+
+| Ori inal Messa e         |                            |                     |         |
+|--------------------------|----------------------------|---------------------|---------|
+| From:                    |                            | <mminime></mminime> |         |
+| Sent: Wednesda           | November 27, 2019 11:46 AM |                     |         |
+| To:                      |                            |                     | alMIE>; |
+|                          |                            |                     |         |
+| Cc:                      |                            |                     |         |
+| Subject: 302s, photos, & | Proffer notes              |                     |         |
+|                          |                            |                     |         |
+
+Hi all,
+
+See attached.
+
+Thanks,

content-documents/ds8/c0/EFTA00018129.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018129)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+## Event: Call with FCA (Epstein)
+
+Start Date: 2019-12-06 15:00:00 +0000
+
+End Date: 2019-12-06 15:30:00 +0000
+
+Organizer:
+
+Class: X-PERSONAL
+
+Date Created: 2019-12-03 23:29:51 +0000
+
+Date Modified: 2019-12-03 23:29:51 +0000
+
+Priority: 5
+
+DTSTAMP: 2019-12-03 18:33:07 +0000
+
+Attendee:
+
+Alarm: Display the following message 15m before start
+
+Reminder

content-documents/ds8/c0/EFTA00018922.md

@@ -0,0 +1,43 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018922)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00018922"
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+---
+
+
+
+Deputy Assistant Commissioner Specialist Operations Headquarters
+
+New Scotland Yard 1- 8 Richmond Terrace Victoria Embankment London SW1A 2JL Telephone: Email:
+
+Reference: 53/DACSO/2019/RW
+
+91h December 2019
+
+Dear Mr. Berman,
+
+I am writing regarding your investigation into the allegations of sexual exploitation and abuse by Jeffrey Epstein as detailed in the case of United States v. Jeffrey Espstein, 19 Cr. 490 (RMB).
+
+I have been advised that US Embassy representatives in London have made contact with Metropolitan Police Colleagues on your behalf, requesting the contact details for the solicitor for HRH The Duke of York, Prince Andrew. These contact details are:
+
+Gerrard Tyrrell Harbottle & Lewis LLP 7 Savoy Court London WC2R 0EX Email: Telep .
+
+The above is supplied for your information.
+
+Yours sincerely,
+
+
+
+Deputy Assistant Commissioner — Specialist Operations Metropolitan Police Service
+
+Geoffrey S. Berman United States Attorney Southern District of New York
+
+By hand

content-documents/ds8/c0/EFTA00018994.md

@@ -0,0 +1,25 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018994)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+
+
+
+Begin forwarded message:
+
+| Front: "-(USANYS)"                     |   |       |
+|----------------------------------------|---|-------|
+| Date: March 16, 2021 at 7:39:41 PM EDT |   |       |
+| To: 'a                                 | c | IMIE> |
+| Subject: GM Suppression Replies        |   |       |
+
+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:

content-documents/ds8/c0/EFTA00019168.md

@@ -0,0 +1,27 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00019168)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00019168"
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+---
+
+
+
+All,
+
+Just wanted to let you I know got a call on my personal cell from a writer with The New Yorker Magazine on the Epstein case. She has interviewed
+
+The reporter asked me to verify that I was an agent and that Jason and myself traveled to Australia and interviewed and that she disclosed that she had sex with Epstein and Allan/Allen Dershowitz. I told her I was an agent and all inquiries about the case would have to through and M. I gave her both your email addresses. She said she had emailed previously.
+
+Have a feeling these calls may become more frequent.
+
+=, can't get email to pop up. Don't know if you want to forward so she's in the loop.
+
+Thanks,

content-documents/ds8/c0/EFTA00020129.md

@@ -0,0 +1,23 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00020129)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00020129"
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+
+
+
+Subject: revised search warrant Date: Sat, 10 Aug 2019 23:53:07 +0000 Attachments: Exhibit_D.pdf; Exhibit_A.pdf; Exhibit_B.pdf; Exhibit_C.pdf; USVI_SW.v6.docx
+
+Thanks again for your help today, and for being flexible while we evaluated how to proceed today. Attached is the revised application. The exhibits are the same as before, but I'm attaching them again just so you have the complete package. I'll call you in a moment to discuss logistics.
+
+is copied here. The FBI would greatly appreciate it if we could swear out the warrant first thing in the morning, if at all possible
+
+Thanks very much--

content-documents/ds8/c0/EFTA00020236.md

@@ -0,0 +1,17 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00020236)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+This is the draft with the FBI paragraph.

content-documents/ds8/c0/EFTA00021312.md

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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00021312)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+| From:    |  |  |
+|----------|--|--|
+| '<br>To: |  |  |
+|          |  |  |
+
+Subject: RE: Next steps
+
+Date: Mon, 30 Sep 2019 17:02:49 +0000
+
+## 3:30 work this afternoon?
+
+| From:                                    |  |
+|------------------------------------------|--|
+| Sent: Monday, September 30, 2019 1:02 PM |  |
+| To:                                      |  |
+| Subject: FW: Next steps                  |  |
+
+Do you guys have a couple minutes this afternoon to talk about the victims thing? mentioned it to me informally so I'm not sure if that was further discussed last week.
+
+| From:                                  |    |  |
+|----------------------------------------|----|--|
+| Sent: Monday, September 30, 2019 12:57 |    |  |
+| MEla:<br>To: I                         |    |  |
+| Cc:                                    | >; |  |
+| Subject: Re: Next steps                |    |  |
+
+If you have some time today we can chat about these steps at more length but in short...
+
+1) Sure we can make a photo array but also we have a photo book which we could just add to instead of the 6 pack.
+
+2) will be on vacation the first week of November but what about the week of October 14? FBI victim services is hosting the victim conference for Epstein victims in Miami on October 15 which we plan on attending. Are you guys coming to this? That might be the best week for us to knock out a few additional victim interviews, as well as meet with
+
+3) We have not come across any photos from the Manhattan house yet but we will certainly keep an eye out as we continue our analysis.
+
+Detective NYPD / FBI Child Exploitation Human Trafficking Task Force
+
+From: Sent: Saturday, September 28, 2019 4:43 PM To:
+
+| Cc:                                                                                                              |  |
+|------------------------------------------------------------------------------------------------------------------|--|
+|                                                                                                                  |  |
+| Subject: Next steps                                                                                              |  |
+| and                                                                                                              |  |
+| A few things on next steps:                                                                                      |  |
+| I) Could you please put together a photo array that includes_? I think we may need it for interviews with<br>and |  |
+| lawyer, I'd like to discuss dates for an interview.<br>is in Florida, so we could sync<br>2) When I reach out to |  |
+
+this up with interviews of an' all in one trip. Would the first week of November work for you guys?
+
+3) I'm aware of the photos from the Florida house, but if you could please let us know if you seized any from the Manhattan house, that would be great, thanks. Likewise, if her name is on any of the discs seized from Florida or NY please let us know.
+
+Thanks!
+
+Sent from my iPhone