giuffre-maxwell
Unknown
4 pages
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS
SUBJECT TO IMPROPER OBJECTIONS
I, Sigrid S. McCawley, declare that the below is true and correct to the best of my
knowledge as follows:
1. I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s
Motion to Compel Production of Documents Subject to Improper Objections.
3. Attached hereto as Exhibit 1, is a true and correct copy of an Excerpt from the
March 24, 2010 Deposition Transcript of Sarah Kellen.
4. Attached hereto as Exhibit 2, is a true and correct copy of Defendant Ghislaine
Maxwell’s Responses and Objections to Plaintiff’s First Request for Production.
5. Attached hereto as Exhibit 3, is a true and correct copy of Defendant Ghislaine
Maxwell’s Privilege Log.
1
6. Attached hereto as Exhibit 4, is a true and correct copy of Jeffrey Epstein’s
private plane Flight Logs.
7. Attached hereto as Composite Exhibit 5, is a true and correct copy of excerpts
from the July 29, 2009 and August 7, 2009 Deposition Transcripts of Alfredo Rodriguez.
8. Attached hereto as Composite Exhibit 6, is a true and correct copy of the message
pads obtained from Jeffrey Epstein’s residence by law enforcement.
9. Attached hereto as Composite Exhibit 7, is a true and correct copy of the
September 9, 2008 Victim Notification Letter.
10. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice
of Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January
13, 2015 Daily Mail Article.
11. Attached hereto as Exhibit 9, is a true and correct copy of Bates GM_00001 –
GM_00015.
12. Attached hereto as Exhibit 10, is a true and correct copy of Jeffrey Epstein’s
phone book.
13. Attached hereto as Exhibit 11, is a true and correct copy of a photo of Ghislaine
Maxwell, Prince Andrew, and Virginia Giuffre.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley______
Sigrid S. McCawley, Esq.
2
Dated: February 26, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies, Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
Boies, Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
(212) 446-2300
3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on February 26, 2016, I electronically filed the foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger@hmflaw.com
/s/ Sigrid S. McCawley
Sigrid S. McCawley
4
DataSet-10
Unknown
180 pages
Original Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
Plaintiff,
vs. CASE No.
502008CA028051XXXXMB AD
JESTRF.Y EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
October, 20, 2009
1010 a.m.
Reported By: Teresa Whalen, RPR, FPR, Notary Public. State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, Ft. 33410
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE No.502008CA028051XXXXMB AB
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
Tuesday, October, 20, 2009
10:10 - 3:30 p.m.
Reported By:
Teresa Whalen, RPR, FPR
Notary Public, State of Florida
West Palm Beach Office Job #118991
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA •
CASE No.08-CV-80119-CIV-MARRA/JOHNSON
4
Plaintiff,
-vs-
7 JEFFREY EPSTEIN,
Defendant.
9 Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
10 08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
11
12
DEPOSITION OF
13 VOLUME II
14
Tuesday, October 20, 2009
15 10:10 - 3:30 p.m.
16
17
18
19
20
21 Reported By:
Teresa Whalen, RPR, FPR
22 Notary Public, State of Florida
West Palm Beach Office Job #118991
23 Phone: 800.330.6952
561.659.4155
24
25
•
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1 APPEARANCES:
2
On behalf of the Defendant:
3
ROBERT D. CRITTON, JR., ESQUIRE
4 BURI4AN CRITTON LUTTLER & COLEMAN, LLP
303 Banyan Boulevard, Suite 400
5 West Palm Beach, Florida 33401
6
7 On behalf of Plaintiff III.:
B
9
10
11
12 On behalf of the Witness:
13
14
15
16
17 On behalf of Defendants/
18
19
20
21 On behalf of Plaintiff in related Case No. 08-80811
22
23
24
25
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2
•
3 INDEX
4
5
6 WITNESS: DIRECT CROSS REDIRECT RECROSS
9 BY MR. 190
10 BY MR. 135 208
11 BY MR. 156
12 BY MR. CRITTON: 173
13
14
15 EXHIBITS
•
16
17
18 NUMBER DESCRIPTION PAGE
19 DEFENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103
20 DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
21 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162
22
23
24
25
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• 1
2
PROCEEDINGS
3 Deposition taken before Teresa Whalen,
4 Registered Professional Reporter, Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 (Mr. joined the proceedings in person.)
9 CROSS (
10 BY MR.
11 O Good afternoon. Is it all right if I call you
12 1111111?
13 A Yes.
• 14
15
Q Okay. My name is
represent some plaintiffs in these cases, and it is my
, I also
16 turn to ask you some questions.
17 We were talking about when Mr. Epstein was in
18 jail, which was between June 30th of 2008 and July of
19 2009; correct?
20 A Yes.
21 Q Now, during that time you wont Lu wurk your
22 regular schedule at 358 El Brillo Way; is that correct?
23 A Yes.
24 Q So you were working basically --
25 MR. CRITTON: She's not finished.
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2
BY MR.
• I'm sorry. Go ahead.
•
3 : Do you need to expand on your
4 answer?
5 BY MR.
6 O Were you finished?
7 A I worked regular hours, but sometimes there
8 are times that I report eight, sometimes I report
9 nine o'clock.
10 Q And I believe --
11 A It's flexible
12 Q Okay. And it was after he left jail that you
13 started working at 6:00 a.m., correct?
14
15 •
A Yee.
So whether you start work at eight or nine is
•
16 your choice? When you say "it's flexible," it means you
17 can chose whether to come at eight or nine?
18 A Yes. When he was not there.
19 o Okay. it didn't matter whether you there at
20 eight or nine when he was not there, correct?
21 A No.
22 • And what kind of things did you do at the
23 house -- let me ask the question this way.
24 How were your duties different when he was nuL
25 there during the time he was in jail from when he would
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come there before he went to jail?
A When he was in jail?
3 • Yes.
4 A I clean the house.
5 • You had less to clean, is that fair to say,
6 because Mr. Epstein, I assume, based on your testimony,
7 there were much fewer people in the house than before,
8 correct?
9 A Yes. I made inventory of the linens.
10 Q I'm sorry?
11 A Of the linens, I made inventory of the liners.
12 Q Oh. Inventory of the linens?
13 A Inventory.
• 14
15
Q Okay. So you did that.
do to fill the time?
And what else did you
16 A Wash the clothes that was in storage, you
17 know.
18 O You washed clothes in storage?
19 A Yes. Because it was right there, so I just
20 wash it and then press if it needs pressing.
21 Q So he has clothes stored outside La the house?
22 A No. In the house.
23 O In the house. Okay. So even if they aadn't
24 been worn, you washed them, correct?
25 A And press them.
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2
MR. CRITTON:
THE WITNESS:
Form.
Yes.
•
3 BY MR.
4 Q What other type of things did you do while he
5 wasn't there?
6 A If there are plants, I attend to the plants.
7 Q Okay. Is that something you didn't do before
8 he went to jail?
9 A I do that also when before he went to jail.
10 Q Okay.
11 A If there are orchids or plants in the house,
12 then I attend to it.
13 • I guess my question is what kind of projects
14
15
did you work on when he was not there to fill your time
after he went to jail?
•
16 A Cleaning, tidying, just going around the
17 house. If I see something that needs painting, I tell
18 Janusz.
19 Q Now, are you paid on the basis of a yearly
20 salary, or are you paid weekly or monthly; how does that
21 work?
22 A We are paid twice a month.
23 Q Okay. That's when you receive your pay?
24 A Yes.
25 • I guess my question is this: say you have to
•
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take a half a day of work off, do you get paid for that?
2 A Yes. In my situation.
3 Q I'm sorry. In your what?
4 A In my situation I was paid.
5 Q Okay. So you're on like a fixed salary, if
6 you miss some time you still get the same amount of
7 money, correct?
8 A Yes.
9 Q And I take it that during the period in which
10 Mr. Epstein was in jail, you continued to receive the
11 same salary, plus a raise, I assume, at the beginning of
12 the year; correct?
13 A Yes.
• 14
15
Q So you continued to receive the same salary
that you did before Mr. Epstein went to jail, correct?
16 A Yes, sir.
17 Q Did Mr. Epstein ever pay bonuses or any extra
18 money to you?
19 A Yes.
20 Q What kind of bonuses did you receive?
21 A Yearly bonus.
22 Q You get a yearly bonus. When is that paid, is
23 that paid at holiday time, Christmas time?
24 A After the year.
25 Q At the end of the year?
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2
1 A
Q
At the end of the year.
At New Years?
•
3 A New Years.
4 • And this past year, when 2008 became 2009, how
5 much of a bonus did you receive?
6 A I did not receive any.
7 Q And what about before that, what kind of bonus
8 did you receive?
9 A The yearly bonus.
10 • Okay. What would be the amount of the yearly
11 bonus?
12 A Oh. For me? The last one I receive was
13 5,000.
14
15
• Okay.
salary of $42,000?
So this would be in addition to your
•
16 A Yes.
17 Q And this $5,000 bonus you would have received
18 in or about January 2008; is that correct?
19 A Not eight.
20 Q Pardon?
21 A Not eight. We did not get any bonus in 2008.
22 Q Okay. So when was the last time you received
23 a $5,000 bonus?
24 A I think 2007.
25 Q So it's been two years since you've gotten a
0 •
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1 bonus; is that correct?
2 A Let me see. Yes.
3 Q Okay. Did Mr. Epstein explain to you why he
4 wasn't giving you a bonus in the last two years?
5 A He did not personally told us.
6 • Did someone tell you why you were not getting
7 a bonus?
8 A Janusz was informed, and Janusz informed me.
9 Q Okay. Did Janusz give you a reason why you
10 weren't getting a bonus?
11 A Because of the economy, that's what he said.
12 Q Any other reason that he gave?
13 A No, sir.
14 Q Did you receive a $5,000 bonus for 2006 and
15 2005?
16 A It was different, it gradually increased.
17 Q Okay.
18 A It was not the same amount.
19 • what was the bonus in 2006 and 2005?
20 A 2005 was 2,000.
21 Q Uh-huh.
22 A And then the next is 5,000 and 5,000.
23 • Okay. So correct me if I am wrong, but in
24 January 2005 you received a $2,000 bonus?
25 A Yes.
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1
2
Q And at that point in time you had really just
started a month and a half before?
•
3 A No. I want to correct that. I receive a 500
4 after I started there November.
5 Q Yes. November of 2004 you started?
6 A At Christmas I receive, after Christmas I
7 receive $500.
8 Q Okay. So in January of 2005 you receive $500,
9 correct?
10 A Yes.
11 Q Then in January 2006 you received how much?
12 A 2,000.
13 Q And in January 2007 you received 5,000; is
14
15
that correct?
A Yes.
•
16 Q And in January 2008 you received no bonus?
17 A NO.
18 Q Is that correct?
19 A Correct.
20 Q Correct, you received no bonus?
21 A No bonus.
22 Q And the same in January 20U9, correct?
23 A Correct.
24 Q Has Mr. Epstein advised you, discussed with
25 you at all how much of a bonus you're going to receive
•
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after the holidays this year?
A No, sir.
3 Q Has anyone discussed with you what bonus you
4 will receive after the holidays this year?
A No.
6 Q Do you have any expectation as to what kind of
7 bonus you'll receive?
8 A I don't -- I did not expect anything.
O You testified earlier about Lyn, who is the
10 housekeeper in New York, correct?
11 A Yes.
12 Q Now, when was the first time you met Lyn in
13 person?
• 14
15
A
Q
In person? When I went to New York.
And when was the first time you went to
16 Now York?
17 A In 2006.
18 Q 2006. And was the reason you went to New York
19 in 2006 for Ms. Maxwell's party?
20 A No. It was Lyn I think had a surgery.
21 ✓ Okay. And you were there to UUVOL fox her
22 while she had surgery?
23 A Yes.
24 • And how long were you there?
25 A I cannot remember, but after her surgery, then
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2
we left to Palm Beach.
Q Okay. You don't remember how long it was?
•
3 A I cannot remember, because I've been there
4 like four times, or more than four times.
5 Q More than four times?
6 A Yes.
7 Q Okay. So this first time when she had her
surgery, you were the housekeeper then in New York while
9 she was out, correct?
10 A Yes, sir.
11 • But did she come into the house in New York
12 and that's how you met her while she was recovering, or
13 how was it that you met her at that time?
14 A We met her before her surgery, I met her
15 before her surgery.
16 Q i see. Then she went and had her surgery.
iv Now, when you traveled to New York, did you go
18 on Mr. Epstein's plane?
19 A No, sir.
20 Q How did you travel to New York?
21 A Commercial.
22 Q So Mr. Epstein purchased you a ticket on an
23 airline to fly to New York?
24 MR. CRITTON: Form.
25 THE WITNESS: Yes, sir.
0 •
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BY MR.
Q Now, let's talk about the other times that you
3 went, you traveled to New York. When was the next time
4 dfLeL Lyn LeevveLed ftoo het uuLyesy Lhal you weal Lo
5 New York?
6 A I think when she went to the Philippines.
7 Q Okay. She went for like a vacation to go to
visit her family?
9 A No. I'm not really good. There was time
10 went there because I think I sometimes interchange, but
11 I went they, nn, time herauee to rover up for
12 ms. maxwell's housekeeper.
13 Q Okay.
• 14
15
A
Q
And when she was having a party.
Okay. So those are two separate times?
16 A Yea. Two separate times.
17 Q Both relating to Ms. Maxwell?
18 A No. The first one was -- first one to cover
19 up for Lyn.
20 • Right. I understood that. But after that,
21 when you came back --
22 A There was a time -- I don't know the sequence,
23 but you know, there was a time I have to cover up for
24 Ms. Maxwell's housekeeper.
25 • I see. What's her name?
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2
1
Q
A Florena.
And then there was another time where you went
•
3 to work for this party that she had, correct?
4 A Yes.
Q Okay. And the fourth time?
6 A When Lyn went to the Philippines.
7 Q Okay. About how long were these visits each
8 time?
9 A Sometimes a week, two weeks, then there was a
10 time I stayed there for like a month.
11 Q Which was that, when she had her surgery, Lyn
12 had her surgery, or was this a different time?
13 A Oh, what's this? Let me see. I cannot
14
15
really, what's this?
• Take your time, take your time.
•
16 A Oh. When, what's this, Ms. Maxwell's
17 housekeeper, I was to cover up for her because tor jury
18 duty. And then she was not part of the jury, so my stay
19 there was, like, extended. That's how I was able to
20 help with the party.
21 • She did not get on the jury?
22 A Yes. she was called.
23 Q But you stayed anyway to help with the party?
24 A Yes.
25 Q I think I understand. Now, have you ever,
•
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1 while you've been employed by Mr. Epstein, traveled
•
2 anywhere else for work?
3 A No, sir.
Q Those trips to New York was the only time
a you've traveled?
A Yes, sir.
7 Q You've never gone to New Mexico or to the
8 Virgin Islands for Mr. Epstein?
9 A No.
13 (Plaintiff's Exhibit No. 2 was marked for
II identification.)
12 BY MR.
13 • Let me show you what's been marked Exhibit 2.
• 14
15
Does it look like the paper that you were talking about
earlier where you wrote the names and the time?
16 A Yee, sir.
17 Q Okay. So this is kind of a notebook or a
18 message pad notebook that was I think you said located
19 by the pantry?
20 A Yes, sir.
21 Q can you look through this and cell me if any
22 of these, point out any of those that are in your
23 handwriting?
24 : Take your time, look at each
25 one, and just tell him if you see any that you
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1
2
recognize your handwriting.
MR. CRITTON: You asked her to identify if she
•
3 sees anything in her writing?
4 MR. : Yes.
5 THE WITNESS: (Shaking head.)
6 BY MR.
7 Q Okay. I understand your response is that you
8 reviewed the various message slips included in Exhibit
9 No. 2 and none of them are your writing, correct?
10 A Yes, correct.
11 Q But you do recall writing messages on this
12 type of pad for Mr. Epstein, correct?
13 A Correct.
14
15
MR. CRITTON:
Mr. Rodriguez's deposition?
that was exhibit what at
•
16 MR. : Exhibit 1 at Mr. Rodriguez's
deposition.
18 MR. CRITTON: Okay.
19 BY MR.
20 O In the period 2004 to 2008 before Mr. Epstein
21 went to jail, do you recall whether there were females
22 who were sitting at the pool in the home at 358
23 El Brillo Way who were topless?
24 A There was one time.
25 One time you remember. Tell me what happened
0 •
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that time.
2 A I was tidying the living room, then not
3 really -- there was like part of the wall, so I saw one
4 female there but not really, I saw it like this side
5 (indicating), so...
6 Q She was at the pool, or inside the house?
7 A This side, not really frontal, but on the side
8 I saw only -- I saw her side, not really like...
9 : His question was, was she
10 inside the house or out by the pool when you saw
11 her from the side.
12 THE WITNESS: The question -- they were in the
13 pool.
• 14
15
BY MR.
• okay. So she was not wearing a bathing suit
16 top, correct?
17 A Yes.
18 Q Was she wearing a bathing suit bottom?
19 A I did not know.
20 Q And how did you -- did you do anything in
21 response to this?
22 A No. I went to, what's this, to kitchen and I
23 told Alfredo not to go to the pool.
24 Q And this was the only time you ever remember
25 seeing a girl who wasn't wearing a top at the pool?
Toll Free: 866.709.8777
• 0 Facsimile: 561.394.2621
sun. WO
4440 PGA Boulevard
ESQLI,RE Palm Beach Gardens, FL 33410
www.esquiresolutions.com
3501.172-002
CONFIDENTIAL Page 21 of 180
EFTA_00070865
EFTA01247588
- Volume II October 20, 2009
150
1
2
A
Q
Yes.
Were there frequently females at the pool to
•
3 the house?
4 A No. Not frequently.
5 Q Not frequently. Sometimes?
6 A Sometimes.
7 Q Mr. Epstein would travel with some females, I
8 think they would come on the plane with him to the
9 house; is that correct?
10 MR. CRITTON: Form.
11 BY MR.
12 Q You can answer.
13 A I cannot remember if they -- let me see. I
14
15
remember Because when Mr. Epstein arrives, most
of the time I'm already off.
•
16 Q Let me ask the question this way: Were there
17 Females other than who would come with Mr. Epstein
18 on the plane and stay at the house?
19 MR. CRITTON: Form, predicate.
20 BY MR.
21 Q Stay overnight at the house?
22 MR. CRITTON: Same.
23 THE WITNESS: I did not know if they came with
24 Mr. Epstein, I did not see.
25
9 Toil Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
•
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
3501.172.002
CONFIDENTIAL Page 22 of 180
EFTA_00070866
EFTA01247589
- Volume II October 20, 2009
151
BY MR.
2 O Okay. There were females who would stay
3 overnight at the house, but you're not sure how they got
4 to the house; is Lhilt. Lai: W say?
5 A Yes.
6 Q Did any of the females who came to the kitchen
7 entrance to give a massage, did any of them stay
8 overnight?
9 A No, sir.
10 Q Never, correct?
11 A Yes, sir.
12 MR. CRITTON: Did you say correct and she said
13 yes?
• 14
15
MR.
MR. CRITTON:
:
Okay.
Yes.
Thank you.
16 BY MR.
17 • The girl at the pool who was topless, do you
18 recall what her name was?
19 A No.
20 • Do you recall how she got to the house or, you
21 know, what her purpose was in being there?
22 A I cannot remember.
23 O Was she a girl who had come to give
24 Mr. Epstein a massage?
25 MR. CRITTON: Form.
Toll Free: 866.709.8777
Facsimile: 561.394.2621
• Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
3501.172-002
CONFIDENTIAL Page 23 of 180
EFTA_00070867
EFTA01247590
- Volume II October 20, 2009
152
1
2 BY MR.
THE WITNESS: No.
•
3 0 The females who came to give Mr. Epstein a
4 massage, did they ever use the pool?
5 MR. CRITTON: Form, predicate.
6 THE WITNESS: I did not see.
7 BY
DataSet-10
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EFTA00129645
17-I (Rev. 1.05.2015)
ATTENTION
The following documents appearing in FBI files have been reviewed under the provisions of The Freedom of
Information Act (FOIA) (Title 5, United States Code, Section 552); Privacy Act of 1974 (PA) (Title 5, United States Code,
Section 552a); and/or Litigation.
IX I FOIA/PA Litigation Executive Order Applied
Requester: etrocK Nev.)S
Subject h it redo K0cirtgaez
Computer or Case Identification Numla: EOM tt I gl e/P4
Title of Case: Section
* File .72- MM - 113327- 119
Serials Reviewed: A
Release Location: *File Section
This file section has been scanned into the FOIPA Document Processing System (FDPS) prior to National Security
Classification review. Please see the documents located in the FDPS for current classification action, if warranted.
File Number: Section
Serial(s) Reviewed:
FOIPA Requester:
FOIPA Subject:
FOIPA Computer Number.
File Number: Section
Serial(s) Reviewed:
FOIPA Requester:
FOIPA Subject:
FOIPA Computer Number:
File Number: Section
Serial(s) Reviewed:
FOIPA Requester:
FOIPA Subject
FOIPA Computer Number:
THIS FORM IS TO BE MAINTAINED AS THE TOP SERIAL OF THE FILE, BUT NOT SERIALIZED.
SCANNED BY DocLab (RIND)
Date: 1,2•Alqr
Last Serial: pie
ATTENTION
DO NOT REMOVE FROM FILE
EFTA00129646
• 1A Envelope •
Case ID: 72-MM-113327
! MM 1 1 FD-395-SUAREZ
MM 2 ORIGINAL NOTES RE INTERVIEW OF JULIO CESAR SUAREZ
MM 3 1)FD-597 SIGNED BY ALFREDO RODRIGUEZ
MM 4 1 1)FD-26 CONSENT TO SEARCH SIGNED BY ALFREDO RODRIGUEZ
2)FD-395 SIGNED BY ALFREDO RODRIGUEZ
MM 5 FGJ SUBPOENA RESULTS FOR PHONE NUMBER 205-435-8487
MM 6 LEETER AND EMAIL CORRESPONDENCE BETWEEN ALFREDO RODRIGUEZ
AND BRADLEY EDWARDS
MM 7 DVD/CD'S OF CONSENSUALLY MONITORED PHONE CALLS WITH
ALFREDO RODRIGUEZ (7 DISCS)
MM 8 ALFREDO RODRIGUEZ 2 PASSPORTS;FL DRIVER LICENSE,RESIDENT
ALIEN CARD;SOCIAL SECURITY CARD;
MM 9 1 BOUND BLACK ADDRESS BOOK AND 2 STAPLED HANDWRITTEN SET OF !
DOCUMENTS ON YELLOW LEGAL PAD PAPER
MM 10 1)ADVICE OF RIGHTS FORM
2)ALFREDO RODRIGUEZ,11/6/2009 INTERROGATION
MM 11 FOUR (4) DVDS OF DEPOSITION OF ALFREDO RODRIGUEZ
AUG 2009
MM 12 INVOICE FOR PAYMENT OF STAGEHAND FEES/MONEY WIRE FEE AND COP !
Y OF CASHIERS CHECK FOR PAYMENT
MM 13 ATT PHONE RECORDS FOR SUBJ ALFREDO RODRIGUEZ, JULY 1,2009
11/2009,
MM 14 BOP RECORDS RE; AND
MM 15 (2) BALEEN SWEEP CD'S FOR TOLL RECORD
MM 16 BOP INMATE RECORD RE: AND
MM 17 OR ERVIEW OF !
1) ON 11/16/2010 !
2) CONTACT INFORMATION FOR EPSTEIN'S ASSOCIATES AND !
EMPLOYEES WRITTEN OUT BYSSSISTANT !
MM 18 VARIOUS TELEPHONE CD'S AND SUBPOENA FOR ALFREDO RODRIGUEZ
CASE; SENT OUT TO HQ FOR BALEEN SWEEP
EFTA00129647
FD440 (Rev. 441-03)
File Number -7g- mil- t/L72. -2 /
Field Office Acquiring Evidence WM,
Serial # of Originating Document
'
Date Received Ii/o Van,
From
(Name ofContributor/Interviewee)
(Address)
.(City and State)
By
To Be Retumed 0 Yes g No
Receipt Given 0 Yes a
No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
O Yes 21. No
Federal Taxpayer Information (Ft)
O Yes gi-No
Title:
Reference:
(Communkation Enclosing Material)
• Description: 0 Original notes re interview of
I) — < (i frit F.7
EFTA00129648
FD-395 (Rev. 11.5-02)
ADVICE OF RIGHTS
Place 006* 2y1ViV, fl_
Date fil Cy tong
Time P.
YOUR RIGHTS
Before we ask you any questions, you must understand your rights.
You have the right to remain silent.
Anything you say can be used against you in court.
You have the right to talk to a lawyer for advice before we ask you any questions.
You have the right to have a lawyer with you during questioning.
If you cannot afford a lawyer, one will be appointed for you before any questioning if you wish.
If you decide to answer questions now without a lawyer present, you have the right to stop
answering at any tithe.
I have read this statement of my rights and I understand wha my rig is are. At this time, I am
willing to answer questions without a lawyer present.
Signed
Witness:
Witness:
Time:
• %.
EFTA00129649
42.-myn- 11332,9 - / A /
EFTA00129650
FD•340 (Rev. 4-I I.03)
File Number
Field Office Acquiring Evidence frivit
Serial # of Originating Document
Date Received 1110 1/ 2 o o 9
From
(Name oltontnbutorl)ntemexte)
(Address)
(City and State) •
By
To Be Returned ❑ Yes 10 No
Receipt Given ❑ Yes -.
No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
❑ Yes a No
Federal Taxpayer Information (FT!)
❑ Yes la No
Title:
Reference:
(Communication Enclosing Material)
Description: 5 Original notes re interview of
Tit tio Catt fkr 47eC7
EFTA00129651
On- 5-b-,4,-rd. 7_- Pt•
So( U
Ragi at. If s
46,444 ( 4
"Lt.. its
‘t•-•- —4
.
1.104_ _ 64-4'LNA"
- -
tete --el& /-tAna-e0A
EFTA00129652
Fli3.340 (Rev. 4.11.03)
File Number 72--Pusi\-- 1133- 7 -1113
Field Office Acquiring Evidence
Serial # of Originating Document
Date Received MAD A9
From
(Name of Contnbutor/Iniernewee)
(Address)
Ca end Stale)
By
To Be Returned 0 Yes 0 No
Receipt Given 0 Yes 0 No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
0 Yes 0 No
Federal Taxpayer Information (FTI)
0 Yes 0 No
Title:
Reference:
(Communication Enclosing Material)
Description: 0 Original notes re interview of
FA- 591 c;sylle,d Aberdo
EFTA00129653
FD-597 (Rev 8-11-94) Page / of
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File # 7) ,— A1147111121
On (date) U /0 6 /0 9 item(s) listed below were:
O Received From
Re iteuarsneedd TToo
. O Seized
(Name) Alfredo Add r; (Aril.
(Street Address)
(City) itA vOiv `'
J
Description of item(s): D 1.:-phone.
lap441-4.sovol £ricssokl
Received By: Lavk (IAN Received From:
EFTA00129654
,- Map-
;y. 3 -1413
EFTA00129655
C
FD-340 (Rev. 4-1143)
File Number 12- -PI - 113 3n--/ A 14
Field Office Acquiring Evidence
Serial # of Originating/ Document
Date Received t )
From
(Name of Contributondnternewee)
(Address)
(City 2nd State)
By
To Be Returned 0 Yes 0 No
Receipt Given 0 Yes 0 No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
0 yes 0 No
Federal Taxpayer Information (FTI)
0 Yes 0 No
Title:
Reference:
(Com4utication Enclosing Material)
Description: 0 Original notes re interview of.
rfr.p.6 Coms tA4 -K, cce,fArz.,1, I e
I rrij o *Sr cspez
FO -34 5 5 d credo
EFTA00129656
FD•395 (Rev. 11.542)
ADVICE OF RIGHTS
Place
Date
Time
YOUR RIGHTS
Before we ask you any questions, you must understand your rights.
You have the right to remain silent.
Anything you say can be used against you in court.
You have the right to talk to a lawyer for advice before we ask you any questions.
You have the right to have a lawyer with you during questioning.
If you cannot afford a lawyer, one will be appointed for you before any questioning if you wish.
If you decide to answer questions now without a lawyer present, you have the right to stop
answering at any time.
I have read this statement of my rights and I understand what my rights are. At this time, I am
willing to answer questions without a lawyer present.
Signed-I
Witne
Witness
Time:
EFTA00129657
! r FD-26
- (Rev. 7-20.94)
DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
CONSENT TO SEARCH
1. I have been asked by Special Agents of the Federal Bureau of Investigation to permit a complete
search of
(Describe the person(s). place(s), or thing(s) to be couched.)
elstrY (44 L.61— Mz44 t_ et-an:at
-oar —
Vint
(1,5 Possrol-
u.s. Age, set
Pi- o t_
Social r,:ly (Itive,)
@ irks (SeiZei
4SZ, - eme "gc%/11 0- 5 cite
I S
KO) A4e-f sony Ericsson s tit/ FP (sehfckesekzej
2. I have been advised of my right to refuse consent.
3. I give this permission voluntarily.
4. I authorize these agents to take any items which they determine may be related to their investigation.
1/4 7/2-0947
Date
(:)»vt inrenf"\
Witness
EFTA00129658
newr 1133.2.?.._
ill9?
EFTA00129659
C C 895"
Ftt.340 (Rev. 4-11.03)
ir
File Number it4 PIA14/- 11 3 3
51 2-Y, 19
Field Office Acquiring Evidence
Serial # of Originating Document
Date Received
From
(Warne of ContributorlIntervIewee)
(Address)
(City and Stole)
By S
To Be Returned 0 Yes 0 No
Receipt Given 0 Yes 0 No
Only Pursua nt to Rule 6 (e)
Grand Jury Material - Disseminate
Federal Rules of Criminal Proced ure
Yes 0 No
Federal Taxpayer Int rmation (FTI)
0 Yes 0 No
Tide:
Reference:
Kommsgication Enclosing Material)
Description 0 Original notes re interview of
6
EFTA00129660
Page 1 of 1
CSS- List magiclecks
List magIcJacks
ktp://csrinaltlazkccm/jacklimrbxca.ntid=11a5151 (11/1812009 12:42143PM)
https://www.324mail.cordowa/WebReadyViewBody.aspx?t=attecid=RgAAAAC96vWni... 11/18/2009
EFTA00129661
Page 1 of 1
CSR • magiciack Pulls
magicJack Details
4411WIFitt
Account
Jack ID: 2727122 Active: 'Y'
Distributor: walgreens (05122(2009) Resource Group ID: 900
Serial No: A921050302E528 Set Adm in State
Phone No:
Tim es Changed: 0
Op State:
Special Routing:
UNRE GIS TEREI
Normal
0_
IPP/PM Balance: No account
IPPIPM Used: Vendor Id: 0
Service Began: 2009-08-03 19:42:55:000 Mini num Ver:
License Expires: 2010-08-03 19:42:55:000 Software Ver: 20090801000001
Past Due Flag:
LERG Inform ation:
Homed to: Atlanta
S
a: Standing
Added:
Added CSR:
2009-08-0319:42:5:
USE R:Instant Activa
Updated: 2009-10-30 09:13:51
Updated CSR: CSR:
hittpillannagk jadc.comffick de tad StniTaccoun ticl.118151510srag Riad:W.2727122 (1 /42) 111/18/200912:4406 061
https://www.324mail.eonilowa/WebReadyViewBody.aspx?t=att&id=RgAAAAC96vWni... 11/18/2009
EFTA00129662
Page 1 of 1
magidadc
more meter &Ails
MN:
Numb.:
14Looalion:
efy
SlatoRlp: 13045
1000.0110.35:000
9000..1, 00 00b0:000
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LESS Infonnation:
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1...c. bora to IN co9tM 0IU‘40/20 }thjogs. 0:
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https://www.324mail.com/owafWebReadyViewBody.aspx?t=att&id-RgAAAAC96vWni... 11/18/2009
EFTA00129663
1-01- - AM - I 136) ,2-q- -IAA
EFTA00129664
Page 1 of 1
CSR- kcountettlilb
• rnagiduck
-arssaakkKmessage pads or schedules;
• The confidentiality agreement;
• Copy of the house manual;
• Copies of documents reflecting banks where Epstein had accounts; and
• Names of any of Epstein's businesses.
Please bring whatever other related information that you have. I appreciate your
cooperation in this regard.
Very Truly Yours,
ROTHSTEIN ROSENFELDT ADLER
Bradley J. Edwards, Esq.
FOR THE FIRM
BJE/jj
EFTA00129672
Page 1 of 2
Bradley J. Edwards
From: Alfredo Rodriguez
Sent: Monday, August 10, 2009 7:45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards wrote:
From: Bradley J. Edwards ‹ >
Subject: E stein
To: '
Date: Monday, August 10, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler] Attorneys at Law
11/8/2009
EFTA00129673
Page 2 of 2
Fort Lauderdale, FL 33301
11/8/2009
EFTA00129674
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Tuesday, August 11, 2009 8:43 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Sure. My cell phone number My direct line at work is I'll wait to hear from you.
Thanks. Take care.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler Attorne s at Law
3
ile
From: Alfredo Rodriguez [manta
Sent: Monday, August 10, 2009 7:45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards wrote:
From: Bradley J. Edwards < MM>
Subject: E stein
To: " " '( )P
Date: Monday, August 10, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
11/8/2009
EFTA00129675
Page 2 of 2
Rothstein Rosenfeldt Adler Attorneys at Law
e, FL 33301
11/8/2009
EFTA00129676
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Saturday, August 22, 2009 11:23 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Alfredo,
I have been trying to call you for days and it seems your phone is shut off. Is there a new number where you can
be reached? Give me a call whenever you have a chance. Thanks. Hope all is well.
Sincerely,
Bradley J. Edwards
Partner
From: Alfredo Rodriguez [mallto corn]
Sent: Monday, August 10, 2009 7:45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello M:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
-- On Mon, 8/10/09, Bradley J. Edwards ‹ > wrote:
From: Bradley J. Edwards ‹ >
Subject:
To: " .. .,:: .
Date: Monday, August 10, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
11/8/2009
EFTA00129677
Page 2 of 2
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfehat Adler Attorne s at Law
'0, FL 33301
- facsimile
11/8/2009
EFTA00129678
Page 1 of 1
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Monday, October 19, 200911:52 AM
To: 'Alfredo Rodriguez'
Subject: Hello
Alfredo,
You have literally fallen off the face of the earth. I hope everything is ok. I want to talk to you. Please call me
ASAP. The number I was reaching you on is no longer good. Please call me when you get this email. Again, I
hope all is well.
Bradley J. Edwards
Partner
Rothstein Rosentel Ad r A i t Law
F , FL 33301
- facsimile
11/8/2009
•
EFTA00129679
1.2.-A4,O- i 135 ag- — t atc,
EFTA00129680
O
FD-340 (Rev. 4-11-03)
File Number -49.- Nunn - 148
Field Office Acquiring Evidence 4
/ 1/ Waif- PA—C41/1
114 1043
Serial # of Originating Document
Date Received
From S 4T
(Address)
(City and State)
By c A--
To Be Returned 0 Yes g No
Receipt Given 0 Yes IS1 No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
❑ Yes No
Federal Taxpayer Information (FIT)
0 Yes 0 No
Title:
Reference:
(Communication Enclosing Material)
A
•
Description: 0 Originalnotes re interview of
("1,•N DP- omse,risua olovittaireoi
?haw f /A tki 441 t i tHrl ezt2t0 ROCittA 0
' fr al r3NS
1
EFTA00129681
ITEM(S)
CANNOT
BE
SCANNED
DESCRIPTION
etflcial DocLah Instruction,s, Revised 10-Ap.014
EFTA00129682
Agency:
Date:
Office: —
CD; o.:
92
Case No24 tral -1327 ..../
Wave File CI
Audio CD CI
o Original . 41.M
411 Copy cs . I. `Video AVI O
4,,
Iiae MJPEG O
)
18;. lb • nC4Rl UPS I
lektiet .04 I 31 .or
EFTA00129683
I
EFTA00129684
EFTA00129685
•i
EFTA00129686
•
Capy in el€1.5-lic.
61.0eSieti- weal CA 5C_,
EFTA00129687
FO-340 (Rev. 4.11-03)
File Number n-rwm- tioaaR- gc
Field Office Acquiring Evidence MietArii /We,* PaCwt
Serial N of Originating Document
Date Received
From plArrIn Roagi toilAt?—
Name oltontribunaribuanitwee)
(Address)
(City and Stale)
By - •
To Be Returned'Yes th,No
Receipt Given 0 Yes 0 NO
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
0 Yes
Federal Taxpayer Information (FTI)
0 Yes
Title:
•
Reference:
(Communication Enclosing Material)
Description: 0 Original notes re inteiview of •
Df
- 62- passports, Ft A tiveAr I(Geoce, P4siolzmic
Mitn &AI Sociej scumAhi atroi
EFTA00129688
SA —returned items listed in 1A and were to provide a copy of FD-597 to 1A8 Envelope
EFTA00129689
tt.-340 (Rev. 4-11.03)
File Number levt The — —/ ft
Field Office Acquiring Evidence 'AA I Ct414( WE* A6-4,
Serial # of Originating Document
Date Received it 31 0g
From M 0 go
(Name ofContributor/Int
urn.
wee)
(Address)
(City and State)
By
To Be Returned O Yes %jN o
Receipt Given O Yes No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
O Yes O No
Federal Taxpayer Information (FTI)
O Yes gNo
Title:
Reference:
(Communication Enclosing Material)
Description: O Original notes re interview of
. .—Limigia black_ ariebn.sc [coot 4,,nd
0€- occprreit
____cra_vd ko 0,4.5k.0 /299-r,r-
`- .11aSiNvmenown.i..-
EFTA00129690
ITEM(S)
CANNOT
BE
SCANNED
DESCRIPTION
P1,4 P1
Officlal Dottab Instructio.)— Revised 10-Apr.2010
EFTA00129691
N,
EFTA00129692
C?
CON:F-1 D . 1\t T I A L --
EFTA00129693
l
EFTA00129694
_
EFTA00129695
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3 pages
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Subject: Disposition Project: Evidence in Pending Inactive Cases — UNCLASSIFIED
Date: Wed, 06 Oct 2021 15:51:32 +0000
Importance: Normal
Classification: UNCLASSIFIED
Good Afternoon,
The Evidence Unit is working on handling all outstanding evidence in pending Inactive cases.
You currently have charged out evidence that needs to be addressed in a pending inactive case. The case and 18 numbers are as follows:
Holding Case Case Primary
Cm. OPOIalional Casa Responsible Evidence
Dimcripcon
RespOnSible UCFN 161* Status Manager Evidence CIR Evidence Screed* Collected On Date
Office Overtmo Entity Subtype
Derision (Evidence)
11TAPED CONVERSATION MIN) 05-
237(1) 2)AUDIO TAPE II PePO 05-
243(1) 3)AUDIO TAPE 1212)4) COPY
CF TAPE PI (3) 51 MICRO TAPE NIP°
05.2541)6i PHOTO LINEUP FIFO OS
257(1) 7)AUC40 TAPE IWO05.29401
81MICRO TAPE (2) 01CD PBPD Ob
2B5(7)10)C-90 CASSETTE PBPD OS
31301111A/X ?ANL NIA PSPO 05.
378(1112) WHITE PAPER
NEW CRmNbI Irm)46/}6016 31F-MM-
EPSTEIN. GM
MIAMI rOALPS2 PeiwAngineclire SChERAL gia E4229230 MESSAG . E PS. (3) 14) Vri1 4
.4)2IE
)5cPAPE
3) FT 8/28/2006
YORK onvon 186432 J
MONIGCSIERY COUNTY. NO J11. (5)
16) WHITE PAPER V. POPO 054790 )
17) WHITE PAPER FLIGHT IWO (2) IS)
THREE WHITE PAPERS PREMIO
COMPUTER UTERNC05 (3)19)14WHITE
HE PAPEFt
Fm I PepO .380( 20 YELLOW
RECEIPT 04:01/05(2)20vmnt PAPER
C.W. (3)22) WHITE PAPER J. 44) 23)
mi
lNIIII TE pPAPERApERGFL1011T 04)05105 (5) 24)
05)
Ono boa conlamng: 11WHITE PAPERA.
WOOS-3610)21WHITE PAPERS
19-LIE RECEIPTa/SIWHITE PAPERJU.
(3)4)WKI1E PAPER JO. (4) 5)
MESSAGE MM. (5) 6) WHIM PAPER H.
5 16) 7)VAIITE PAPERA (7)8) WHITE
PAPER J.5 (6)9)WHITE PAPER H. (9)
10)VMM PAPER ST. BATONS (10) II)
EPSTEIN
NEW Cnnvnal Wrosipathe 31E.MM. GENERAL 194 MESSAGE • G. (II) 12) MESSAGE •
MIAMI nom...._ MIAP92 Peromb_leacitio E6516714 8/20.02006
YORK 100 JL 112)131
WHITE PAPER- F.113) 14)1ESSAGE S.
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MESSAGE IL. GIRL 06) IT) WRITE
PAPER -5 (17) 18) WHITE PAPER PS
116) 19)WHITE PAPER - J. (19)201
WHITE PAPER - J. (20) 21)VMFTE
PAPER (91/1121)22) WHITE PAPER
D.M. (22) 23) PHONE 6 PRINT OUT (23)
Of boa centring: 1)FIVE MESSAGE
PRINTOUTS PIP005-342(1)2)WHITE
PAPER C. J. (2) 3) MESSAGE M. (3)4)
MESSAGE PS. (4) 5) MESSAGE A. (5) 6)
MESSAGE JLL. (6) 7)14ESSAGE T. (7i II)
CLEAR PLASTIC STICK (S)911WEI.YE
WHITE PAPER- EXPENDITURES WO
05.353(I) 101 WHITE PAPER J. (2)11)
WHITE PAPER O. (3) 12) WHITE PAPER
C. (4) 13) WHITE PAPERJ. (5)14)
WHITE PAPER J. (6) 151WHITE PAPER
EPSTEIN.
NEW C6mini froesikistin) 1
31E-MM-
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MIAMI 1461-1, 82 IIIII Paring GENERAL DU E6516715 8/282006
YORK Dmgon SI (5) IT)
MESSAGE P. PBPD 05.3640 ) 16)
WHITE PAM T (2119) WHITE PAPER
J.H.(3) 20)WHRE PAPER F. (4) 21)
MESSAGE GO. (6) 22) MESSAGE 1(8)
23)MESSAGE M.M. H. (7)24)1NHITE
PAPER C.W.18)20.vmn PAPER (SIT)
FWD 06-385(I )26) WHITE PAPERA
12)271WHITE PAPER E. (3) 26) WHITE
PAPERI B. F. 14) 29)
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YORK Dhition a 2)727 LETTERHEAD 12) 3) 114vOICE
612700 (3)4)AALCONOOMMA (4)6)
WHITE MPER J.L (5)6) MESSAGE
FROM J. (6) 7)MESSAGE FROM J.L. (7)
8) WHITE PAPER 21$ (8)9) WHITE
PAPER (9171 (9) 10) MISC.
DOCUMENTS • TRASH PULL PBPD 06.
874(1)11) MISC. PAPERWORK -TRASH
PULL WO 054378(I) 121 TWO
MAGAZINES • TRASH PULL PBPD 06.
901(1113)PAPERWITHA.S.• TRASH
PULL WOOS-915W 14) VHS T-1150
CASSETTE PBPD 06-929(I) 15) SONY
MICRO CASSETTE T2) 16)SONY
MICRO CASSETTE T3) 17)SONY
MICRO CASSETTE 14) 18130NY
MICRO CASSETTE Pesvos-mo EN
SONY MICRO CASSETTE (2)20) SONY
MICRO CASSETTE (3) 211SONY
EFTA00174951
MICRO CASSETTE 14) 22)M7SC
PAPERWORK • TRASH PULL POPO 05.
911(1) 23) SONY MICRO CASSETTE
PBPD 05-942(1)241 SONY MICRO
CASSET TE (2) 251 MISC PAPERS •
TRASHPULL FBPD 05.943(1) 261
CLEAR PIECE OF PLASTIC PePo os.
944(1) mmgsc PIECES CF PAPER -
TRASHPULL (2) 28) SONY MICRO
CASSET TE PBPD 05-94511129) SONY
MICRO CASSETTE 12)
1) SONY MICRO CASSETTE PIDP 05.
972(1) 2) SONY MICRO CACSF TTE
3) SONY MICRO CASSETTE (3) 4)59SG
PAPERWORK • TRASH PULL POPO 05.
1005(115) THREE FLOOR PLANS PBPD
05-10281)61DRAWING A H PBPD OS
1025(11 7) 59SC PHONE MESSAGES
TRASHPULL FSPD 05 1027(1)8i T-160
VOE0 CASSETTE PBPD 054052(11 9)
SONY MICRO CASSETTE (2) 10) SONY
NEW pE-MM-
EPSTEIN. MICRO CASSETTE Pepo05-1C40(1) 11)
Unlined kweelSethe
MIAMI IAM.P132 PenentInacifro GEhERN. JAZ E4729234 THREE EMNL FROM DMV4X (2)12) 8/28,7006
YORK Division 105452 VHS VIDEOCASSETTE PBPD OS
106911113) VHS VOE0 CASSETTE RI
14)00 PBPD 05-107912) 15) MINI DV
TAPE PBPD 96-1000(11161VHS VIDEO
TAPE (2)171MINI DV TAPE 131 18)
SONY MICRO CASSET TE FBPD 86.
1087(1119) SONY MICRO CASSETTE
PBPD 05-1090(1)201 SONY MICRO
CASSET TE PBPD OSI1192(1) 21)
PHOTO LINE UP (2) 22I SONY MICRO
CASSETTE PBPD 06-12031D
1) VHS TAPE CF SURVEILLANCE POPO
05-1206(1)21 VHS TAPE OF
SURVEILLANCE (2) 3) VHS TAPE (3)41
VHS TAPE (4) 5) VHS TAPE (5) 6) VHS
TAPE (6) 7) VHS TAPE (7) 8) SIXTEEN
DVDR DISCS PBSO POPO 05-1219(I )
9) CANGULAR ENVELOPE WITH
SUBPOENA INFO PBPD C6-1245(1)101
EPSTEIN. CIRCULAR WIRELESS CO 121111 SONY
NEW Unlined kweelSsIM, 31E-MM-
MIAMI MM-PB2 Pecong_Ineclire GETCRAL 131 E4229235 MCRO CASSETTE Pm:Joe-21(1)n) 8,21/204:6
YORK Dhition
GREEN FOLDER A. PBPD 06-24(1)13)
SONY MICRO CASSET TE PBPD 06
39( 1) 14) SONY MICRO CASSETTE
P09006 -69(I)151SONY MICRO
CASSETTE PBPD 06-95(11 16)T-160
VOE0 CASSETTE PBPD 06120(1)17)
SONY MICRO CASSET TE FBPD 06
182(1118) SONY MICRO CASSETTE
P09006-34641) 19) CD PBPD 06-3970 )
131) 32) ONE THRIFTY RENTµ
AGREEMENT. (S2) 33)
NOTE FROM
.133) 34)
PR IPI)S OFFICE
.134)35) MESSAGE
BOOK. GUEST HOUSE
1491136)0SE MESSAGE
pE MU- EPSTEIN. BOOK (501(37) TWO
NEW Unlined kweelSsIM, ID2
MIAMI MM-PB2 PecOng_INPlire GENERAL E4229229 COMPACT FLASH 8,21/204:6
YORK Dhition :UM CARDS (51)(38)S1X
CDS • GUEST HOUSE
1521139) POWER CORD TO CPU -
GUEST HOUSE (54)(40)CPU
OFFICE (55)411
ONE POWER CORD TO CPU •
OFFICE (56) 42)TMEE
CDS -OFFICE (58)
...HONE GREEN FRAMED PHOTO (59)
HONE PHONE MESSAGE BOOK
FS9005 1024 (1)21 TIREE PHONE
MESSAGE BOOKS 121 3)
ONE FILE FOLCER WITHTWO
FILES .13) 4) SHREDDED
PAPER (4) 510NE
FILE FOLDER ORANGE
II) 6) °LAO(
FRµIED PHOTO OF NUDE
48191 NINE
PICTURES IN FRAMES (9) (WEIGHT
PHOTOS FROM OFFICE (101 111 TWO
PHOTOS - SITTING ROOM (11) 12) TWO
PHOTOS TABLE
(12)13) TWO VHS TAPES POOL AREA
NEV Criminal Irnesnewn, 31E-MM. 101
MIAMI P12.2 PenantInadm2 GENERAL E4229228 (13) 14) TWO COS (SPRED 'HAPPY 8.28/2006
YORK Divitice BIRTHDAY (15) 16) ONE MESSAGE
PAD - 1ST FLOOR (16) 171 ONE
MESSAGE PAD - DESK Ill 18) THREE
CDS • DESK (18) 19) ONE BINA - DESK
(19) 20)INFRAmto PHOTOS- DESK
(20121) TAO FRAMED PHOTOS - DESK
(21) 22) TWO FRAMED PHOTOS •
TABLE (22)231 THREE SOAPS CNA
ROPE (23)24) TWO VIBRATORS -
TWIN TORPEDO* (24) 25) TWO SOAPS
ON A ROPE (26) 21) ONE MGM
SCHOOL TRANSCRPT AN 127)28)
ONE BOTTLE OF JOY JELLY- MASTER
BE CIROOm (26)29) THREE VIDEO
TAPES • MASTER BEDROOM
One red rope COrganting 1) BOOK - AN
NEV Cnminal Irnesnobo 31E-LIM. INVITATION 10 POETRY 21 VICTORIA'S
YORK
MIAMI
Omuta
TAW P12.2
1841032
m
EPSTEIN
PenantInadm2 GEhERN. IAD E6616732
SECRET Sinn BRA ANC/PANTIES
SET
44307007
EPSTEIN.
NEV Cnnunal Irnesnewn, 31E-MM. Ito rod rope: ONE (1) BOOK.MASSAGE
MIAMI IAM-PB2 1280680_10edhe GENERAL 7814 E6516712 6,72007
YORK DiNece FOR DUMMIES
If this evidence should not be disposed yet due to legal reasons, please reply to this email with the reason so that we can make note of that and remove you from the list.
To dispose of this eodence you can do one of the following:
EFTA00174952
1. Return the items to then original owner
2. Destroy the endence
3. Abandonment/Forfeiture (If applicable)
Please be sure you have AUSA concurrence before returning or disposing of any evidence. If no AUSA was assigned to the case, your SSA can give authorization.
To request abandonment/forfeiture please submit the request via sentinel. The request can be found under Templates .5 New York (Local) Request initiation of abandonment.
Please feel free to reach out to myself, , or NY Evidence if you have any questions.
Thank you so much.
Best Regards,
Operational Support Technician (OST)
New York Field Office
Federal Bureau of Investigation
Classification: UNCLASSIFIED
EFTA00174953
DataSet-10
Unknown
4 pages
-1 of 4 -
FD.302 (Rev. S.II•10)
FEDERAL BUREAU OF INVESTIGATION
Dan:amity 09/10/202'
JANUSZ BANASIAK (BANASIAK) was interviewed at over WEBEX audio on 9/27/2021
by AUSA AUSA and Det . After being
advised of the identity of the interviewing Agents and the nature of the
interview, BANASIAK provided the following information:
BANASIAK was interview in 2007 by FBI and states he had a lawyer then.
Currently not represented. Fine continuing talking today without lawyer.
BANASIAK started working for EPSTEIN in 2005 around February or March. He
stopped working for EPSTEIN in 2017. BANASIAK stopped working because he
found another job. It was a mutual separation. EPSTEIN hired another
person. BANASIAK worked for EPSTEIN in his Palm Beach house.
Very often BANASIAK was taken to New York City to work for EPSTEIN while
another couple that worked for EPSTEIN would be on vacation.
In 2005 BANASIAK was taking care of EPSTEIN's property. He would make sure
everything was working around the house, the pool, the air condition
systems, clean driveway, get house ready for EPSTEIN, make sure gardeners
are there. He would get the cars ready and make sure there was gas in them.
In 2005 BANASIAK would report to MAXWELL for the first 2-3 years working
there. MAXWELL was involved with everything, organizing EPSTEIN's schedule
and making sure BANASIAK knew when they were coming or if things needed to
be brought to the house. BANASIAK did not have a problem with MAXWELL. She
made decisions right way. If BANASIAK needed something from her MAXWELL got
Imustigati4mon 09/27/2021 at New York, New York, United States (Phone)
Hen SOD—NY-3027571 Datedralled 09/29/2021
by
This document contains neither recommendations nor conclusions of the 1:131.1t is the properly of the Fill and is loaned to your agency; il and lb contents am not
to be dis0ibutd outside your agency.
3507-012
Page I of 4
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00006865
EFTA00158450
FD302a (Re". $8.10)
SOD-NY-3027571
confinugio„rm.302or (U) Interview of JANUSZ BANASIAK .o„ 09/27/2021 page 2 of 4
it right away. BANASIAK had a good working relationship with her.
There were rules for the house. MAXWELL introduces BANASIAK to these in
the. She said EPSTEIN likes exotic flowers. BANASIAK bought food and
flowers before EPSTEIN came. MAXWELL says EPSTEIN doesn't like roses, he
likes exotic flowers.
BANASIAK would answer the phone and was told that he cannot tell the people
if EPSTEIN was at the house. BANASIAK was to take a message and pass
along. GM mentioned the house has to be clean and nice and cars full of gas
and clean.
When guests were in the house they would with luggage and BANASIAK would
bring the luggage to their rooms. BANASIAK wasn't involved in talking to
the guests. BANASIAK did not talk to or engage in conversation with them.
BANASIAK doesn't remember the rules about talking to the guests but BANASIAK
wanted himself to keep his distance because he is the worker and they are
different style of people.
Yes there was a household manual. There was some manual for the maids on
how to prepare the beds, clean bathrooms and maintain the house. BANASIAK
would recognize this if he saw it.
There were young women coming to give massages at the house during EPSTEIN's
stay almost every day.
These appointments were scheduled by his assistant. BANASIAK picked up some
phone calls and EPSTEIN's assistants would call
BANASIAK and give name of a particular person coming at certain time for
massage.
A few times some of the massage girls called the house if they weren't able
to make their appointment on those certain scheduled times and BANASIAK
would take a message with their numbers for EPSTEIN. BANASIAK didn't have
access to those numbers otherwise.
Yes there was a contact book. There was small books with all the numbers
for those people inside of them. They held the numbers for those girls. It
was a square black book for people he has contact with, famous people too,
CLINTON, TRUMP and others. BANASIAK thinks there was a couple books in the
3507-012
Page 2 of 4
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00006866
EFTA00158451
FD•302a (Rev. 5.8.10)
50D-NY-3027571
conthwalion ormme or (U) Interview of JANUSZ BANASIAK ,on 09/27/2021 .fts, 3 of 4
house, each house has this kind of book, seen in New York also. The book
was square, about 6 inches by 6 inches, 3 inches thick maybe, with names and
numbers inside. BANASIAK thinks the cover was a hard black cover. BANASIAK
never used this book. BANASIAK saw it on the desk next to the phone or next
to the bed, there was a few of them lying around. BANASIAK thinks it was
used for EPSTEIN or his assistants to use to call the number that EPSTEIN
asked them to call. It was used for the house workers if they needed
contacts.
BANASIAK didn't see any other address books in the house.
MAXWELL tells BANASIAK in beginning to take messages. He is to answer the
phone and ask for their name and take their number and say that they will
get a call back. These messages were taking in a message book. It was a
message book that you buy that makes 2 copies. You take a message out and
put on kitchen counter. At some point those books were kept in the house in
one of the desks, BANASIAK believes. If BANASIAK saw the message pads again
he would recognize his handwriting and probably some others. Of course he
would recognize the books. BANASIAK would also recognize the black books.
BANASIAK does not recall phone calls from MAXWELL about the girls coming for
massage. BANASIAK thinks he got the calls from his other assistants.
MAXWELL was inside the house when people would come for massages in the
beginning. After a few years she stepped aside from her engagement with
scheduling and coming to palm beach. After maybe 2-3 years MAXWELL didn't
come as often.
When BANASIAK first started working there around 2005 MAXWELL would go
around the town. Sometimes BANASIAK would drive her, sometimes she would
drive herself. BANASIAK used pool, went to dinner and played tennis at mar-
a-lago.
Massage appointments would happen in the beginning almost every day. Not
sure what MAXWELL would do at this time. BANASIAK was living in a small
house on the property at this time and didn't see what was going on.
BANASIAK would let the people in and let them know they had guests.
BANASIAK wasn't even sure what they were doing during certain periods of
time inside the house.
BANASIAK does not recall a time when anyone asked him to gather up things in
3507-012
Pagc 3 of 4
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00006867
EFTA00158452
FD•302a (Re". 5*I0)
50D—NY-3027571
conthwalk„rm302 or (U) Interview of JANUSZ BANASIAK .o„ 09/27/2021 •pygr 4 of 4
the house. BANASIAK got phone calls from his assistants when they were away
from the house, sometimes about picking up show tickets.
BANASIAK is asked about computers being in the house in 2005? He recalls
one day called him and told him that a man was coming to the house
to take all the desktop computers from the house. She said he would come
later on that day or next day and that this person is coming to take
computers. BANASIAK met him, let him in the house and he took 3-4 computers
from the house. BANASIAK is not sure if he took anything else. Maybe he
took some kind of disc or software connected to the computer also. He asked
BANASIAK to stay away and he would do it by himself so BANASIAK lead him to
the rooms and he took computers. BANASIAK's sense at the time was this man
works for EPSTEIN. BANASIAK doesn't think this person mentioned what his
position was in the organization. BANASIAK is not sure why he was taking
computers but BANASIAK assumed it was for replacement or upgrade but they
never told him BANASIAK was just guessing that.
worked for EPSTEIN. She would report to him. She was his
assistant. She worked full time for EPSTEIN. was the more
experienced of the 2 assistants ( other assistant).
BANASIAK is willing to talk to the government again.
Reporters and a production company has called BANASIAK a few months ago but
he declined to talk with them.
3507-012
Page 4 of 4
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00006868
EFTA00158453
DataSet-10
Unknown
39 pages
Villafana, Ann Marie C. (USAFLS)
From: Kuyrkendall, E N.
Sent: Tuesday, February 19. 2008 2:03 PM
To: Villafana. Ann Marie C. (USAFLS)
Subject: Response to questions
Mane,
Hope you had a great weekend.
Well it ha been easy and I dont know if you can make any sense of it.
Facts: —end SK had contact 9 times between (7/15/2004 - 10/26/2004)
and 5K had contact 1 time (10/26/2004) This is appears to be ACs fathers phone. We believe we
have AC cellphone at the time and no calls with SK
Testimony:
P( brought) stated Spring of her Junior year. (Estimated to be Spring 2004)
and NE stated sophomore year -( this time line does not fit at all) DH and AC both estimated to be
',mores
stated she went between January and May of Senior year which is believed to be Jan - May 2005. She turned
18 in Feb 2005. I do not know if she was being truthful about the time of the year or if she was more concerned about
when she turned 18.
SO000cowho knows....
H. Born in 1986
& graduated from RPBHS 2004
A. graduated from RPBHS 2004
1624
08-80736-CV-MARRA P-014584
EFTA00189310
Villafana, Ann Marie C. (USAFLS)
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 8:55 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Marie, I just recvd about 5 emails from you. I do not have my books here. I will
look at things first thing tues and answer whatever we did not already talk
about. We did hear back from amazon and they would like cc info, Jason will work
with them next week. Sorry I did not get your emails sooner.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.
Sent: Fri Feb 15 12:56:16 2008
Subject: RE: I am back with more questions
Hi Nesbitt -- Just one more question, I hope. Where did JA and KH go to school?
They both say they went to the same school, but one says Wellington High and the
other says Palm Beach Central. And do you know what year(s) they graduated?
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
Original Message
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 10:36 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with NR. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for JA. KH and NR went
betwn 10/03-05/04. JA's last visit.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for Jennifer A.?
Thanks.
1626
08-80736-CV-MARRA P-014585
EFTA00189311
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
1627
08-80736-CV-MARRA P-014586
EFTA00189312
Villafana, Ann Marie C. (USAFLS)
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 4:48 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: High Schools
• II. - Royal Palm Beach H.S.(taken by = A.)
lenniferA. - Royal Palm Beach H.S.(taken T n F.)
M C. - Wellington H.S.(went with H.)
IH. - Wellington H.S.(10th) & Palm Beach Central(11th) - DH believes she may have starting going her 10th
grade year while attending WHS. P. was taken by DH hernU cle year(both girls born In 87) and Jennifer P.
S.(went with C.)
lil
t both DH and herself were attendi
P. - Palm Beach Central (taken by H.)
E. - Palm Beach Central (taken by M.)
1630
08-80736-CV-MARRA P-014587
EFTA00189313
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday, February 15, 2008 4:50 PM
To: Kuyrkendall, E N.
Subject: RE: High Schools
Thank you so much! Have a good weekend. I am headed out now, but will work on this at home.
A. Marie Villain&
Assistant U.S. Attorney
561 209-1047
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 4:48 PM
To: Villafana, Ann Made C. (USAFLS)
Subject: High Schools
-H. - Royal Palm Beach H.S.(taken by A.)
Royal Palm Beach H.S.(taken T F.)
C. - Wellington H.S.(went with H.)
H. - Wellington H.S.(10th P Im Beach Central(11th) - DH believes she may have starting going her 10th
grade year while attending WHS. P. was taken by DH her aH le year(both girls born in 87) and P.
Ill
t both DH and herself were attend' S.(went with C.)
P. - Palm Beach Central (taken by H.)
E. - Palm Beach Central (taken by M.)
1632
08-80736-CV-MARRA P-014588
EFTA00189314
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday. February 15. 2008 1.38 PM
To: Kuyrkendall. E N.
Subject: Timeline
Hi Nesbitt —I read M.'s statement. She says she first went with AC and DH between January and May of her
senior year.
She says on the second visit she went with S.E., D.H., and A.C. This is weird because S.E. says she went with
She says on the third visit, she went v. ith J.P., A.C., and D.H.
Assuming C.M. is correct about the order of visits and that S.E. was with them on that trip. we are looking around July
2004 (because Kellen called S.E. in July 2004).
Is it safe to say that these events took place In or around the first half of 2004?
A. Marie Villafaila
Assistant U.S. Attorney
561 209-1047
1635
08-80736-CV-MARRA P-014589
EFTA00189315
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Friday. February 15. 2008 1.08 PM
To: Kuyrkendall. E N
Subject: Do we have a timeframe or any numbers or calls for D H /J P./A C ?
Thanks.
A. Marie VillafoMa
Assistant U.S. Attorney
561 209-1047
1636
08-80736-CV-MARRA P-014590
EFTA00189316
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday, February 15, 2008 1:09 PM
To: Kuyrkendall, E N.
Subject: RE: Do we have a timeframe or any numbers or calls forD.H.N.P /A.C.?
Thanks.
A. Marie Villafatia
Assistant U.S. Attorney
561 209-1047
1639
08-80736-CV-MARRA P-014591
EFTA00189317
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday. February 15, 2008 12:56 PM
To: Kuyrkendall, E N.
Subject: RE: I am back with more questions
Hi Nesbitt -- Just one more question, I hope. Where did JA and KH go to school?
They both say they went to the same school, but one says Wellington High and the
other says Palm Beach Central. And do you know what year(s) they graduated?
Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
Original Message
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 10:36 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with NR. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for JA. KH and NR went
betwn 10/03-05/04. JA's last visit.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for Jennifer A.?
Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
1640
08-80736-CV-MARRA P-014592
EFTA00189318
Villafana, Ann Marie C. (USAFLS)
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 11.48 AM
To: Villafana. Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
6462261463 only 1 message no date possible 05/05
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.
Sent: Fri Feb 15 11:06:06 2008
Subject: RE: I am back with more questions
What is B.'s phone number? Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
Original Message
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 10:36 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with NR. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for JA. KH and NR went
betwn 10/03-05/04. JA's last visit.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for Jennifer A.?
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1642
08-80736-CV-MARRA P-014593
EFTA00189319
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Friday. February 15, 2008 11:20 AM
To: Kuyrkendall, E N.
Subject: RE: I am back with more questions
I thought I had a complete set of the message pads here, but I only have the
copies of the messages that have identified girl Can you look through
the message pads and tell me what the ones from say?
Thank you (so sorry)
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
Original Message
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 10:36 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with NR. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for JA. KH and NR went
betwn 10/03-05/04. JA's last visit.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for Jennifer A.?
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1644
08-80736-CV-MARRA P-014594
EFTA00189320
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Mane C (USAFLS)
Sent: Friday. February 15, 2008 11:06 AM
To: Kuyrkendall, E N.
Subject: RE: I am back with more questions
What is B.'s phone number? Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
Original Message
From: Kuyrkendall, E N.
Sent: Friday, February 15, 2008 10:36 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with NR. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for JA. KH and NR went
betwn 10/03-05/04. JA's last visit.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for Jennifer A.?
Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
561 209-1047
1646
08-80736-CV-MARRA P-014595
EFTA00189321
Villafana, Ann Marie C. (USAFLS)
From: Kuyrkendall, E N.
Sent: Friday. February 15, 2008 10:36 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with NR. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for JA. KH and NR went
betwn 10/03-05/04. JA's last visit.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for Jennifer A.?
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1648
08-80736-CV-MARRA P-014596
EFTA00189322
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday. February 15, 2008 10:31 AM
To: Kuyrkendall, E N.
AIL
Hi Nesbitt — Didn't you tell me that
explain what happened during that
B. estimated that she brought 100 girls? It isn't in the 302. And did she
e with Epstein?
Thanks.
A. Marie Villafafia
Assistant U.S. Attorney
561 209-1047
1650
08-80736-CV-MARRA P-014597
EFTA00189323
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday, February 15, 2008 10:10 AM
To: Kuyrkendall. E N.. Richards. Jason R.
Subject: RE: I am back with more questions
Did you ever talk to Nicole R.?
Do we have any time frame, messages, or phone calls for A.?
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1654
08-80736-CV-MARRA P-014598
EFTA00189324
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 5:29 PM
To: Kuyrkendall, E N.; Richards, Jason R.
Subject: Draft Overt Acts
Hi guys — Here is the most recent draft. I have only looked at the overt acts sections for the girls we are keeping. Can you
go through those and check the facts? Also, can you figure out which trips we can drop from the oven acts? I think I only
have 2 phone calls from Nadia, so if there are some calls I can add, please point those out, too.
I will turn to the new girls tomorrow.
Thanks.
080214 revised
indictment.pdf
A. Marie Villafafia
Assistant U.S. Attorney
561 209-1047
1658
08-80736-CV-MARRA P-014599
EFTA00189325
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Thursday. February 14, 2008 3:13 PM
To: Richards. Jason R.
Subject: RE: List of names
I am having a really hard time e-mailing you guys. My e-mails are getting
bounced back so I have to re-send numerous times until it goes through. Do you
know if there is something wrong with the FBI's server?
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
Original Message
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 3:11 PM
To: Richards, Jason R.
Subject: RE: List of names
B
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
Original Message
From: Richards, Jason R.
Sent: Thursday, February 14, 2008 3:10 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: list of names
B??? NYC or d.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Thu Feb 14 14:57:31 2008
Subject: RE: List of names
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 1:43 PM
To: Braden, Myesha; Kuyrkendall, E N.; Richards, Jason R.
Subject: List of names
Here are the names of people I am intending to keep in the indictment:
1660
08-80736-CV-MARRA P-014600
EFTA00189326
Virginia ( eyewitness info only)
Carolyn
- initials only, not a listed Jane Doe
Courtney W
Courtney L
Alex H
Britany
Ashley
D
Jennifer A
Kara H
Nicole R
B
C
Jennifer P
Sabrina E
Not all will be in substantive counts, but they will be mentioned in the overt
acts.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1661
08-80736-CV-MARRA P-014601
EFTA00189327
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Thursday. February 14.2008 3:11 PM
To: Richards. Jason R.
Subject: RE: List of names
B
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
Original Message
From: Richards, Jason R.
Sent: Thursday, February 14, 2008 3:10 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: List of names
B??? NYC or d.
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.; Richards, Jason R.
Sent: Thu Feb 14 14:57:31 2008
Subject: RE: List of names
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 1:43 PM
To: Braden, Myesha; Kuyrkendall, E N.; Richards, Jason R.
Subject: List of names
Here are the names of people I am intending to keep in the indictment:
Virginia ( eyewitness info only)
Carolyn
- initials only, not a listed Jane Doe
w
L
Alex H
Britany
1664
08-80736-CV-MARRA P-014602
EFTA00189328
D
Jennifer A
H
Nicole R
B
C
Jennifer P
E
Not all will be in substantive counts, but they will be mentioned in the overt
acts.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1665
08-80736-CV-MARRA P-014603
EFTA00189329
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 2:58 PM
To: Kuyrkendall, E N.; Richards, Jason R.
Subject: RE: List of names
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 1:43 PM
To: Braden, Myesha; Kuyrkendall, E N.; Richards, Jason R.
Subject: Ust of names
Here are the names of people I am intending to keep in the indictment:
eyewitness info only)
— initials only, not a listed Jane Doe
w
L
Alex H
D
Jennifer A
Nicole R
B
C
P
E
Not all will be in substantive counts, but they will be mentioned in the overt acts.
A. Marie VillafaAa
Assistant U.S. Attorney
561 209-1047
t668
08-80736-CV-MARRA P-014604
EFTA00189330
Villafana, Ann Marie C. (USAFLS)
From: Viliafana. Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 2:39 PM
To: Kuyrkendall, E N.: Richards, Jason R.
Subject: I know you hate it when I do this, but . . .
I always seem to notice something new when I go through these records. In Janusz's notes, he shows a payment to
Golden Cab on 6/17/05. Can you call and see if they have any records or any trips tcl-ElBrillo Way? Or a Dennis
working there? And that long string of unknown numbers on Sarah's cell phone. Could those be a group of lines for
Yellow Cab?
Thanks.
I am almost finished with the changes to the girls we are keeping. I will send that to you and then when I finish the new
girls, I will send that portion.
A. Marie Villafaaa
Assistant U.S. Attorney
561 209-1047
1670
08-80736-CV-MARRA P-014605
EFTA00189331
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 1:43 PM
To: Braden. Myesha; Kuyrkendall, E N.; Richards, Jason R.
Subject: List of names
Here are the names of people I am intending to keep in the indictment:
eyewitness info only)
— initials only, not a listed Jane Doe
W
L
Alex H
3PC
A
It
Nicole R
IE
Not all will be in substantive counts, but they will be mentioned in the overt acts.
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1672
08-80736-CV-MARRA P-014606
EFTA00189332
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 1:35 PM
To: Richards, Jason R.; Kuyrkendall, E N.
Subject: RE: DOBs
Hi guys - sorry to bother you. On some of the new girls I don't have dobs.
Martell
Dicenso (the 302 says her dob is 8/15/2007)
and do we have a phone number?)
Have you guys ever talked to or Me Should I include them?
A. Marie Kuala&
Assistant U.S. Attorney
561 209-1047
1674
08-80736-CV-MARRA P-014607
EFTA00189333
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday. February 14, 2008 1:21 PM
To: Richards, Jason R.
Subject: RE: Epstein Indictment
Ili Jason — I didn't send the indictment yet. I was just asking for input on who to include and who to exclude.
Hots old was Angela Thomas when she went with Ashley?
.1 Marie Villalana
\ssistant ll.S. Attorney
361 209.1047
From: Richards, Jason R.
Sent: Thursday, February 14, 2008 1:00 PM
To: Villafana, Ann Mane C. (USAFLS)
Subject: RE: Epstein Indictment
Hey Mane,
There was no indictment attached to your email. Can you send it again.
In addition to the two calls from Sarah Kellen to on her cell phone 41/04 at 1:35 pm and 5/2/04 at 10:32 am,
we have two telephone calls from Sarah Kellen to Shawn Haught's ( boyfriend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.
Message pads reflect 10 messages from I. beginning 03/11/2003 ending 03/01/2006. Individuals identified as
taking the messages are Evelyne, Michae, Louella, and Alfredo Rodriguez.
From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov]
Sent: Thursday, February 14, 2008 11:41 AM
To: Kuyrkendall, E N.; Richards, Jason R.
Subject: RE: Epstein Indictment
FYI -- 'Fell me what you think. Also. can you pull the messages from and see if you can tell
what the dates are and who took the messages? Thanks.
And am I correct that we have only PA° phone calls with M. ) 4/23/04 and 5/2/04
.1. Marie 11///q/iiihr
Assistant l !.S. Attorney
561 209-1047
From: Villafana, Ann Mane C. (USAFLS)
Sent: Thursday, February 14, 2008 11:22 AM
To: Braden, Myesha
Subject: Epstein Indictment
1678
08-80736-CV-MARRA P-014608
EFTA00189334
Hi Myesha — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted
to talk about which girls we should drop.
and L. are the girls who have filed lawsuits. 1 have excluded them.
With respect to the other girls brought by , here are my thoughts. We c and S.
very easily. Both only gave I or 2 massages and did not disclose their ages. S. is a good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its pill.
I think we should drop P. because I don't believe she will ever be completely truthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation
day.")
That only leaves , the soccer player who cried for the entire interview. I think that she may be worth
keeping. We have such good documentary evidence related to her — message pads, car rental records, 156 calls
with Sarah Kellen, and 2 calls with Adriana Mucinska (we have very few phone calls with Adriana, so this is
U).
What do you think?
A. Marie Villafafia
Assistant U.S. Attorney
561 209-1047
1679
08-80736-CV-MARRA P-014609
EFTA00189335
Villafana, Ann Marie C. (USAFLS)
From: Richards, Jason R.
Sent: Thursday, February 14, 2008 1:00 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: RE: Epstein Indictment
Hey Marie,
There was no indictment attached to your email. Can you send it again.
In addition to the two calls from Sarah Kellen to on her cell phone at 1:35 pm and 5/2/04 at 10:32 am,
we have two telephone calls from Sarah Kellen to Shawn Haught's (boyfriend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.
Message pads reflect 10 messages from beginning 03/11/2003 ending 03/01/2006. Individuals identified as
taking the messages are Evelyne, Michael, Louella, and Alfredo Rodnguez.
From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdolgoy]
Sent: Thursday, February 14, 2008 11:41 AM
To: Kuyrkendall, E N.; Richards, Jason R.
Subject: RE: Epstein Indictment
FYI -'Tell me what you think. Also. can you pull the messages from and see if you can tell
what the dates arc and who took the messages? Thanks.
And am I correct that we have only two phone calls with 4/23/04 and 5/2/04
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 11:22 AM
To: Braden, Myesha
Subject: Epstein Indictment
Hi Myesha — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted
to talk about which girls we should drop.
and L. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by M, here are my thoughts. We cipalima and S.
very easily. Both only gave I or 2 massages and did not disclose their ages. S. is a good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its pr e.
I think we should drop P. because I don't believe she will ever be completely truthful about the amount of
sexual activity that occurre . (She is the girl that one of the witnesses described as "a virgin on graduation
day.")
That only leaves the soccer player who cried for the entire interview. I think that she may be worth
keeping. We have such good documentary evidence related to her — message pads, car rental records, 156 calls
1686
08-80736-CV-MARRA P-014610
EFTA00189336
with Sarah Kellen, and 2 calls with Adriana Mucinska (we have very few phone calls with Adriana, so this is
key).
What do you think?
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1687
08-80736-CV-MARRA P-014611
EFTA00189337
Villafana, Ann Marie C. (USAFLS)
From: Braden. Myesha
Sent: Thursday, February 14.2008 12:37 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: RE: Epstein Indictment
I'm not supposed to be involved in tantive decisions until I get word from "on high*. However, my general
thoughts are that you are correct. of th vidence and will be a good witness, although a
reluctant one. Am I correct to assume that A. and A. are still in? Their past history of commitment will
have to be dealt with and it won't be easy, but I agree that they should be left in. The fact that their commitments were
post-Epstein is gooditiii aitiiisare going to try to destroy them. Is Felecia in as well? I thought that she was
truthful. What about ?
From: Villafana, Ann Marie C. (USAFLS) hailto:Ann.Marie.C.Villafana@usdoj.goy]
Sent: Thursday, February 14, 2008 11:22 AM
To: Braden, Myesha
Subject: Epstein Indictment
Hi Myesha — Our server was down for a few hours this morning. so I am very behind on my revisions. I wanted
to talk about which girls we should drop.
and L. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by , here are my thoughts. We can drop and S.
very easily. Both only gave I or 2 massages and did not disclose their ages. . is a good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its prejudice.
I think we should drop P. because I don't believe she will ever be completely truthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation
day.")
That only leaves the soccer player who cried for the entire interview. I think that she may be worth
keeping. We have such good documentary evidence related to her — message pads, car rental records, 156 calls
with Sarah Kellen, and 2 calls with Adriana Mucinska (we have very few phone calls with Adriana, so this is
key).
What do you think?
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1690
08-80736-CV-MARRA P-014612
EFTA00189338
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Thursday. February 14, 2008 11:41 AM
To: Kuyrkendall. E N.: Richards. Jason R.
Subject: RE: Epstein Indictment
FYI — Tell me what you think. Also, can you pull the messages from Andridho and see if you can tell what the
dates are and who took the messages? Thanks.
And am I correct that we have only two phone calls with M! 4/23/04 and 5/2/04
A. Marie Villeffiala
Assistant U.S.
561 209.1047
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday, February 14, 2008 11:22 AM
To: Braden, Myesha
Subject: Epstein Indictment
Hi Myesha - Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk
about which girls we should drop.
and L. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by here are my th e can drop Il.ar etcd EFS. very easily.
Both only gave 1 or 2 massages and did notdisclose their ages. S. is a good witness ause s shows that, if
you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
I think we should drop P. because I don't believe she will ever be completely truthful about the amount of sexual
activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation day.")
That only leaves =, the soccer player who cried for the entire interview. I think that she may be worth keeping.
We have such good documentary evidence related to her — message pads, car rental records, 156 calls with Sarah Kellen,
and 2 calls with Adriana Mucinska (we have very few phone calls with Adriana, so this is key).
What do you think?
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1702
08-80736-CV-MARRA P-014613
EFTA00189339
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Thursday. February 14, 2008 11:28 AM
To: Kuyrkendall, E N.: Richards, Jason R.
Subject: FW: Epstein Indictment
FYI — Fell me what you think. Also, can you pull the messages from Carolyn Andriano and see if you can tell what the
dates are and who took the messages? Thanks.
And am I correct that we have only two phone calls with 4/23/04 and 5/2/04
A. Marie Villatiala
Assistant U.S. Attorney
561 209-1047
From: Villafana, Ann Made C. (USAFLS)
Sent: Thursday, February 14, 2008 11:22 At4
To: Braden, Myesha
Subject: Epstein Indictment
Hi Myesha — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk
about which girls we should drop.
In and L. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by here are my tha e can drop and S. very easily.
M.
Both only gave I or 2 massages and did not disclose their ages. S. is a good witness because she shows that, if
you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
I think we should drop P. because I don't believe she will ever be completely truthful about the amount of sexual
activity that occurred. (S is is the girl that one of the witnesses described as "a virgin on graduation day.")
That only soo .. the soccer player who cried for the entire interview. I think that she may be worth keeping.
We have such g ocumentary evidence related to her — message pads, car rental records, 156 calls with Sarah Kellen,
and 2 calls with Adriana Mucinska (we have very few phone calls with Adriana, so this is key).
What do you think?
A. Marie Villajafia
Assistant U.S. Attorney
561 209-1047
1704
08-80736-CV-MARRA P-014614
EFTA00189340
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Thursday. February 14, 2008 11:22 AM
To: Braden, Myesha
Subject: Epstein Indictment
Hi Myesha — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk
about which girls we should drop.
and L. are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by M, here are my th e can drop and S. very easily.
Both only gave I or 2 massages and did not disclose their ages. S. is a good witness because she shows that, if
you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweigh; its prejudice.
I think we should drop P. because I don't believe she will ever be completely truthful about the amount of sexual
activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation day.")
That only leaves M. the soccer player who cried for the entire interview. I think that she may be worth keeping.
We have such good documentary evidence related to her — message pads, car rental records, 156 calls with Sarah Kellen,
and 2 calls with Adriana Mucinska (we have very few phone calls with Adriana, so this is key).
What do you think?
A. Marie Villafana
Assistant U.S. Attorney
561 209-1047
1706
08-80736-CV-MARRA P-014615
EFTA00189341
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Tuesday, February 12, 2008 4:33 PM
To: Kuyrkendall, E N.
Subject: Telephone numbers
Marina 646 238-7671
646-226-1463
Natalie or Anja 917-204-9696
Dr. Bard 561-302-1844
Alisa (maybe Anisa?) 646-281-3514
Can you e-mail me your summary chart, too? The Excel spreadsheet.
Thanks.
A. Marie ViliajaFla
Assistant U.S. Attorney
561 209-1047
1713
08-80736-CV-MARRA P-014616
EFTA00189342
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Tuesday. February 12. 2008 4:33 PM
To: Kuyrkendall, E N.
Subject: Telephone numbers
Marina 646 238-7671
646-226-1463
Natalie or Anja 917-204-9696
Dr. Bard 561-302-1844
Alisa (maybe Anisa?) 646-281-3514
Can you e-mail me your summary chart, too? The Excel spreadsheet.
Thanks.
A. Marie Villafafia
Assistant U.S. Attorney
561 209-1047
1714
08-80736-CV-MARRA P-014617
EFTA00189343
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C (USAFLS)
Sent: Tuesday, February 12, 2008 3:19 PM
To: Kuyrkendall, E N.
Subject: Telephone charts and Kellen phone records
Hi Nesbitt — I am trying to get this indictment package finalized. Can you e-mail to me the final telephone charts for all of
the girls and Kellen, Nadia, and Adriana? Also, do you have all of Sarah Kellen's records electronically? Maybe we can
search for phone numbers for some of the new girls, even though we don't have their phone records yet.
Also, can you check on the lead to New York? Ideally, I would like to turn the package in on Thursday, so I need to know
if we can include any of those girls.
When you have a chance. please give me a call. I am in the U.S. Attorney's Office — 561-209-1021.
A. Marie I/Malan°
Assistant U.S. Attorney
561 209-1047
1717
08-80736-CV-MARRA P-014618
EFTA00189344
Villafana, Ann Marie C. (USAFLS)
From: Kuyrkendall, E N.
Sent: Friday, February 22, 2008 2:08 PM
To: Villafana. Ann Marie C. (USAFLS)
Subject: Re: Phone call info
Ill fax it in 5 min(what fax U?)
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.
Sent: Fri Feb 22 14:07:06 2008
Subject: Phone call info
Hi Nesbitt - Can you e-mail or fax me the dates of the calls? I can add them to
the indictment today. I think Karen is going to try to finish her review over
the weekend.
Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
1560
08-80736-CV-MARRA P-014619
EFTA00189345
Villafana, Ann Marie C. (USAFLS)
From: Villafana. Ann Marie C. (USAFLS)
Sent: Friday. February 22, 2008 2:10 PM
To: Kuyrkendall, E N.
Subject: RE: Phone call info
820-8777
Thanks
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Original Message
From: Kuyrkendall, E N.
Sent: Friday, February 22, 2008 2:08 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: Phone call info
Ill fax it in 5 min(what fax #?)
Original Message
From: Villafana, Ann Marie C. (USAFLS)
To: Kuyrkendall, E N.
Sent: Fri Feb 22 14:07:06 2008
Subject: Phone call info
Hi Nesbitt - Can you e-mail or fax me the dates of the calls? I can add them to
the indictment today. I think Karen is going to try to finish her review over
the weekend.
Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
1562
O8-8O736-CV-MARRA P-O1462O
EFTA00189346
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday, February 22, 2008 2:07 PM
To: Kuyrkendall, E N.
Subject: Phone call info
Hi Nesbitt — Can you e-mail or fax me the dates of the calls? I can add them to the indictment today. I think
Karen is going to try to finish her review over the weekend.
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
1564
08-80736-CV-MARRA P-014621
EFTA00189347
Villafana, Ann Marie C. (USAFLS)
From: Villafana, Ann Marie C. (USAFLS)
Sent: Friday, February 22, 2008 12:07 PM
To: 'Kuyrkendall, E N.'; Richards, Jason R.
Subject: Got the FedEx records
Cecilia's last name is Steen or Feen and her phone number is 212-750-9895 (this may be an office number, not
a cell phone number). They also show another corporate name: "Max Hotel Services Corp.-
They show a phone number for Epstein and Eric Gany as 212 750-9790
They have an e-mail address for Nadia as: Nadia2 I 02(avahoo.com and show her phone number as 917-476-
9463 •
The notes show that the Max Hotel Services Corp credit card was declined and then they show Bella Tsukeman
at 212-750-9896, with company name "NYSG LLC"
They want us to be more specific about individual shipment re
DataSet-10
Unknown
25 pages
(USAFLS)
From: (USAFLS)
Sent: 008 2:07 PM
To:
Subject:
Hi - Can you e-mail or fax me the dates of the calls? I can add them to the indictment today. I think
Karen is going to try to finish her review over the weekend.
Thanks.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
1569 EXHIBIT B-110
08-80736-CV-MARRA P-014621
EFTA00224567
. (USAFLS)
From: (USAFLS)
Sent:
To:
Subject: oft e x recor. s
last name is or and her phone number is, this may be an office number, not
a cell phone number). They also show another corporate name:
They show a phone number for Epstein and Eric Gany as
They have an e-mail address for as: and show her phone number as
The notes show that the credit card was declined and then they show
at with company name '
They want us to be more specific about individual shipment records, so we will have to comb through what they
gave us to identify specific shipments.
I am running to lunch but will be back this afternoon.
Thanks.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
1567
08-80736-CV-MARRA P-014622
EFTA00224568
. (USAFLS)
From:
Sent: 2008 2:03 PM
To: . (USAFLS)
Subject: Response to ques ions
Hope you had a great weekend.
Well it has not been easy and I dont know If you can make any sense of It.
Facts:mai d d contact 9 times between (7/15/2004 - 10/26/2004)
and had contact 1 time (10/6/2004) This is appears to be. fathers phone. We believe we
have cellphone at the time and no calls with
Testimony:
brought) stated Spring of her Junior year. (Estimated to be Spring 2004)
and stated sophomore year -( this time line does not fit at all) and, both estimated to be
Sophomores 02-03
stated she went between January and May of Senior year which is believed to be Jan - May 2005. She turned
18 in Feb 2005. 1 do not know if she was being truthful about the time of the year or If she was more concerned about
when she turned 18.
SO00000who knows....
Born In
MI aduated from
graduated from
1624
08-80736-CV-MARRA P-014584
EFTA00224569
(USAFLS)
From:
Sent: 08 8:55 PM
To: (USAFLS)
Subject: e: am ac ore questions
fa I just recvd about 5 emails from you. I do not have my books here. I will
look at things first thing tues and answer whatever we did not already talk
about. We did hear back from amazon and they would like cc info, Jason will work
with them next week. Sorry I did not get your emails sooner.
Original Message
From: (USAFLS)
To:
Sent: Fri Feb 15 12:56:16 2008
Subject: RE: I am back with more questions
Hi -- Just one more question, I hope. Where did and go to school?
They both say they went to the same school, but one says and the
other says . And do you know what year s ey gra u ted?
Thanks.
Assistant U.S. Attorney
Original Message
From:
Sent: Friday, February 15, 2008 10:36 AM
To: . (USAFLS)
Re: I more questions
Only pbpd spoke with II. (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for II. II and went
betwn 10/03-05/04. last visit.
Original Message
From: . (USAFLS) <
To:
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to .?
Do we have any time frame, messages, or phone calls for .?
Thanks.
1626
08-80736-CV-MARRA P-014585
EFTA00224570
Assistant U.S. Attorney
1627
08-80736-CV-MARRA P-014586
EFTA00224571
.(USAFLS)
From: . (USAFLS)
Sent: , 008 4:50 PM
To: .
Subject: :High SC 00S
Thank you so much! I lave a good weekend. I am headed out now, but will work on this at home.
Assistant U.S. Attorney
Front:
Sen Febr 5 2008 4:48 PM
To: .(USAFLS)
Subject: High Schoo s
h) believes she may have starting going
her h e ear(both girls born in 87)
went with
1632
08-80736-CV-MARRA P-014588
EFTA00224572
. (USAFLS)
From: . (USAFLS)
Sent: , 0081:38 PM
To: .
Subject: imelme
Hi — I read statement. She says she first went with ■ and between January and May of her
senior year.
She says on the second visit she went with ■and ■. This is weird because ■. says she went with
She says on the third visit, she went with ■., and ■.
Assuming . is correct about the order of visits and that.. was with them on that trip, we are looking around July
2004 (because called E. in July 2004).
Is it safe to say that these events took place In or around the first half of 2004?
Assistant U.S. Attorney
1635
08-80736-CV-MARRA P-014589
EFTA00224573
(USAFLS)
From: M r , ai((USAFLS)
3US
81 P S),,,ii
Sent:
To:
Subject: a a amerrame or any numbers or calls for ......?
wehave
Thanks.
Assistant U.S. Attorney
1636
08-80736-CV-MARRA P-014590
EFTA00224574
(USAFLS)
From:
Sent: 8 11:48 AM
To: =1111(USAFLS)
Subject: Re:I am back with more questions
only 1 message no date possible 05/05
Original Message
From: (USAFLS)
To:
Sent: Fri Feb 15 11:06:06 2008
Subject: RE: I am back with more questions
What is IIMMO phone number? Thanks.
MIMIEME
Assistant U.S. Attorney
Ori inal Messa e
From: I.
Sent: Frida , Februar 15 2008 10:36 AM
To: . (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with II. (She was 18 @ the time) but we will interview her and I
think she will be c22p2pative. We dont have time frame for U. • and U went
betwn 10/03-05/04. IIII last visit.
Original Messa e
From: USAFLS
To:
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to
Do we have any time frame, messages, or phone calls for
Thanks.
Assistant U.S. Attorney
1692
08-80736-CV-MARRA P-014593
EFTA00224575
(USA FLS)
From:
Sent:
00811:20 AM
To:
Subject: • am ac with more questions
I thought I had a complete set of the message pads here, but I only have the
copies of the messages that have identified girls' names. Can you look through
the message pads and tell me what the ones from say?
Thank you (so sorry)
Assistant U.S. Attorney
Original Message
From:
Sent: Frida Februar 15, 2008 10:36 AM
To: . (USAFLS)
Subject: Re: I am back with more questions
Only pbpd spoke with (She was 18 @ the time) but we will interview her and I
think she will be cooperative. We dont have time frame for II. and II went
betwn 10/03-05/04. last visit.
Original Message
From: . (USAFLS)
To:
Sent: Fri Feb 15 10:10:14 2008
Subject: RE: I am back with more questions
Did you ever talk to
Do we have any time frame, messages, or phone calls for .?
Thanks.
Assistant U.S. Attorney
1644
08-80736-CV-MARRA P-014594
EFTA00224576
(USAFLS)
From: . (USAFLS)
Sent: , 00810:31 AM
To:
Hi — Didn't you tell me that . estimated that she brought 100 girls? It isn't in the 302. And did she
explain what happened during that first massage with Epstein?
Thanks.
ssistant U.S. Attorney
1650
08-80736-CV-MARRA P-014597
EFTA00224577
From:
Sent:
To:
Subject: am with more ques tons
Did you ever talk to n
Do we have any time frame, messages, or phone calls for 7
Thanks.
Assistant U.S. Attorney
1654
08-80736-CV-MARRA P-014598
EFTA00224578
.(USAFLS)
From: . (USAFLS)
Sent:
To:
Subject: ra ve s
Hi guys — Here is the most recent draft. I have only looked at the overt acts sections for the girls we are keeping. Can you
go through those and chti•li• I c facts? Also, can you figure out which trips we can drop from the overt acts? I think I only
have 2 phone calls from, so if there are some calls I can add, please point those out, too.
I will turn to the new girls tomorrow.
Thanks.
080214 revised
IndIctmen .pdf
ssistant U.S. Attorney
1658
08-80736-CV-MARRA P-014599
EFTA00224579
.(USAFLS)
From: .(USAFLS)
Sent: , 2008 3:13 PM
To:
Subject: : is o names
I am having a really hard time e-mailing you guys. My e-mails are getting
bounced back so I have to re-send numerous times until it goes through. Do you
know if there is something wrong with the FBI's server?
Assistant U.S. Attorney
Original Message
From: . (USAFLS)
Sent: Thursday, February 14, 2008 3:11 PM
To:
Subject: RE: List of names
Assistant U.S. Attorney
Ori inal Messa e
From:
Sent: Thursday, February 14, 2008 3:10 PM
To: . (USAFLS)
Subject: Re: List of names
??? NYC or d.
Original Message
From: . (USAFLS) <
To: .;
Sent: Thu Feb 14 14:57:31 2008
Subject: RE: List of names
From: . (USAFLS)
Sent: Thursday, February 14, 2008 1:43 PM
To: •; •
Subject: List of names
Here are the names of people I am intending to keep in the indictment:
1660
08-80736-CV-MARRA P-014600
EFTA00224580
Not all will be in substantive counts, but they will be mentioned in the overt
acts.
Assistant U.S. Attorney
1661
08-80736-CV-MARRA P-014601
EFTA00224581
(USAFLS)
From: (USAFLS)
Sent:
To:
Subject: now you ate it w en is,
I always seem to notice something new when I go through these records. In Janusz's notes, he shows a payment to
Golden Cab on 6/17/05. Can you call and see if they have any records or any trips tosEl Brillo Way? Or a Dennis
working there? And that long string of unknown numbers on Sarah's cell phone. Could those be a group of lines for
Yellow Cab?
Thanks.
I am almost finished with the changes to the girls we are keeping. I will send that to you and then when I finish the new
girls, I will send that portion.
Assistant U.S. Attorney
1670
08-80736-CV-MARRA P-014605
EFTA00224582
. (USAFLS)
From: .(USAFLS)
Sent:
To:
Subject: 5
•
Hi guys — sorry to bother you. On some of the new girls I don't have dabs.
lave you guys ever talked to or-? Should I include them?
Assistant U.S. Attorney
1674
08-80736-CV-MARRA P-014607
EFTA00224583
.(USAFLS)
From: . (USAFLS)
Sent: , 2008 1:21 PM
To:
Subject: :Epstein n ictment
Eli Jason — I didn't send the indictment yet. I was just asking for input on who to include and who to exclude.
How old was when she went with
Assistant U.S. Attorney
From:
Set • 14, 2008 1:00 PM
To: (USAFLS)
Subject: RE: Epstein Indictment
Hey
IM
There was no indictment attached to your email. Can you send it again.
In addlbon to the two calls from o il at 1:35 pm and 5/2/04 at 10:32 am,
we have two telephone calls from to Syfriend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.
Message pads reflect 10 messages from Il beginning 03/11/2003 ending 03/01/2006. Individuals Identified as
taking the messages are Evelyne, Michae, Loue la, and Alfredo Rodriguez.
From: (USAFLS)
AM
To:
Subject: RE: Epstein Indictment
FYI — Tell me what you think. Also. can you pull the messages from and see if you can tell
what the dates arc and who took the messages? Thanks.
And am I correct that we have only two phone calls with ? 4/23/04 and 5/2/04
Assistant U.S. Attorney
From: (USAFLS)
Sen uary 14, 2008 11:22 AM
To:
Subject: Epstein Indictment
1678
08-80736-CV-MARRA P-014608
EFTA00224584
Hi — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted
to talk a bo irls we should drop.
and are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by , here are my thoughts. We c• n dro and
very easily. Both only gave I or 2 massages and did not disclose their ages. . is a good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its prim,
I think we should drop . because I don't believe she will ever be completely truthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation
day.")
That only leaves , the soccer player who cried for the entire interview. I think that she may be worth
keepin ,. We have such good documents evidence related to her — message pads, car rental records, 156 calls
with . and 2 calls with (we have very few phone calls with , so this is
key).
What do ou think?
Assistant U.S. Attorney
1679
08-80736-CV-MARRA P-014609
EFTA00224585
. (USAFLS)
From:
Sent: , 2008 1:00 PM
To: . (USAFLS)
Subject: : pstem ment
Hey
M,
C
There was no indictment attached to your email. Can you send it again.
In addition to the two calls from lao II /04 at 1:35 pm and 5/2/04 at 10:32 am,
we have two telephone calls from to boyfriend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.
Message pads reflect 10 niss from beginning 03/11/2003 ending 03/01/2006. Individuals Identified as
taking the messages are Michael, Louella, and Alfredo Rodriguez.
From: . (USAFLS)
Sen ru ki1 AM
To:
Subject: RE: Epstein Indictment
FYI - Tell me what you think. Also. can you pull the messages from and see if you can tell
what the dates are and who took the messages? Thanks.
And am I correct that we have only two phone calls with M? 4/23/04 and 5/2/04
Assistant U.S. Attorney
From: (USAFLS)
Sen ruary 14, 2008 11:22 AM
To:
Su n Indictment
Hi — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted
to talk about which irls we should drop.
and . are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by , here are my thoughts. We can dro and
very easily. Both only gave I or 2 massages and did not disclose their ages. . is a good witness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its pret
I think we should drop because I don't believe she will ever be completely truthful about the amount of
sexual activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation
day.")
That only leaves , the soccer player who cried for the entire interview. I think that she may be worth
keeping. We have such good documentary evidence related to her — message pads, car rental records, 156 calls
1686
08-80736-CV-MARRA P-014610
EFTA00224586
with , and 2 calls with (we have very few phone calls with , so this is
key).
What do ou think?
Assistant U.S. Attorney
1687
08-80736-CV-MARRA P-01461 I
EFTA00224587
(USAFLS)
a
From:
Sent: 2008 12:37 PM
To: mil,. (USAFLS)
Subject: : ps ein n ent
I'm not supposed to be involved in tantive decisions until I get word from son high". However, my general
thoughts are that you are correct. of th vidence and will be a good witness, although a
reluctant one. Am I correct to assume that . and A. are still in? Their past history of commitment will
have to be dealt with and it won't be easy, but agree that t ey s ould be I he fact that their commitments were
post-Epstein is good., ailmsysare going to try to destroy them. Is in as well? I thought that she was
truthful. What about ? ?
From: (USAFLS) [mallto
Sen uary 14, 2008 11:22 AM
To:
Subject: Epstein Indictment
iii — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted
to talk about which girls we should drop.
and are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by , here arc my thoughts. We can dro and
very easily. Both only gave I or 2 massages and did not disclose their ages. . is a good wt ness
because she shows that, if you aren't willing to do more sexual activity, Epstein stops t e massage and doesn't
want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
nature outweighs its prejudice.
I think we should drop . because I don't believe she will ever be completely truthful about the amount of
sexual activity that occurre . (She is the girl that one of the witnesses described as "a virgin on graduation
day.")
That only leaves the soccer player who cried for the entire interview. I think that she may be worth
keep such good docu ' elated to her — message pads, car rental records, 156 calls
with and 2 calls with (we have very few phone calls with , so this is
key).
What do you think?
Assistant U.S. Attorney
1690
08-80736-CV-MARRA P-014612
EFTA00224588
. (USAFLS)
From: (USAFLS)
Sent: M
To:
Subject: : pstemIndictment
FYI — Tell me what you think. Also, can you pull the messages from and see if you can tell what the
dates are and who took the messages? Thanks.
And am I correct that we have only two phone calls with ' 4/23/04 and 5/2/04
Assistant U.S. Atiorni.ty
(USAFLS)
ruary 2008 11:22 AM
Hi — Our server was down for a few hours this morning, so I am very behind on my revisions. 1 wanted to talk
about which girls we should drop.
N and . are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by , here are my th e can drop easily.
Both only gave 1 or 2 massages and did notdisclose their ages. wt nessbecause s e shows that, if
. is a good wi
you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
I think we should drop because I don't believe she will ever be completely truthful about the amount of sexual
activity that occurred. (She is the girl that one of the witnesses described as "a virgin on graduation day.")
That only leaves the soccer player who cried for the entire interview. I think that she may be worth kee in .
We have such g vidence related to her — message padomal records, 156 calls with
and 2 calls with (we have very few phone calls with so this is key).
What do you think?
Assistant U.S. Attorney
1702
08-80736-CV-MARRA P-014613
EFTA00224589
(USAFLS)
From: (USAFLS)
Sent: ry , 2008 4:33 PM
To:
Subject: e ep one num ers
Dr. Bard
Can you e-mail me your summary chart, too? The Excel spreadsheet.
Thanks.
Assistant U.S. Attorney
1713
08-80736-CV-MARRA P-014616
EFTA00224590
(USAFLS)
From: pgril. (USAFLS)
Sent: ry , 2008 3:19 PM
To:
Subject: e ep one c a s and phone records
Hi — get t tment package finalized. C o me the final telephone charts for all of
the girls and and ? Also, do you have all of records electronically? Maybe we can
search for phone numbers for some of the new girls, even though we don't have their phone records yet.
PI
Also, can you check on the lead to New York? Ideally, I would like to turn the package in on Thursday, so I need to know
if we can include any of those girls.
When you have a chance, please give me a call. I am in the U.S. Attorney's Office —
Assis ant U S Attorney
1717
08-80736-CV-MARRA P-014618
EFTA00224591
DataSet-10
Unknown
7 pages
From: ' y,
[=. y,
To: a. NY) (FBI)" <1
'' '' 1 II
Cc: ,
(USANYS)"
Subject: RE: Discovery questions
Date: Fri, 04 Sep 2020 02:49:28 +0000
Hi
Thanks again so much for getting these materials to us. I've got a few follow up questions on discovery issues below. Feel
free to give me a call to talk through these if that's easier.
• Any update on the status of the scanning and disc reviews?
• Any update from CART on the paperwork?
• I'm a bit confused about some of the files on the thumb drive you provided:
o None of the audio files in the folder entitled "Grand Jury Testimony 7.19.06" are playing for me. Are you
able to play them?
o In the folder entitled "Additional scans PBPD" and the folder entitled "Scans from reiter" — where did these
documents come from?
o In the folder entitled "Items from Reiter — disks" —There are a bunch of subfolders that seem empty or to
have files that have nothing to do with the Epstein investigation, or that won't open. Can you let me
know where these came from and what they are?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: (NY) (FBI) <1. >
Sent: Thursday, August 20, 2020 6:17 PM
To:
Cc:
(USANYS)
Subject: RE: Discovery questions
Hey all,
EFTA00073274
Just wanted to send a quick email to detail what is being given today. There is a box of media, including VHS, cassette,
and microcassettes, and newspaper articles that were provided by Reiter.
On the thumbdrive is a spreadsheet outlining what is included; items highlighted in blue are included. You will notice a
comment "see disk tracking spreadsheet" in items not highlighted; this spreadsheet will be included in the disk copies we
send over that will detail how many images total and how many removed.
There are loose disks which include 1B evidence scans, 1D1-1D5 evidence items, LSJ 3D imaging, and the FBI file.
Separately, we will keep you updated as we continue to work on the redactions and will let you know as soon as we finish
with the disks.
Let us know you have any questions.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
From:
Sent: Wednesday, August 19, 2020 8:43 PM
To:
Cc: . (NY) (FBI) < >;
(USANYS)
Subject: (EXTERNAL EMAIL) - Re: Discovery questions
I'll be in the office tomorrow.
Sent from my iPhone
On Aug 19, 2020, at 8:18 PM, > wrote:
Great, thanks very much. I'm not in the office right now, but hopefully someone from the team can grab these. If not, I
can find a paralegal to take them.
From: . (NY) (FBI)
Sent: Wednesday, August 19, 2020 7:24 PM
To:
Cc: .; (USANYS)
Subject: RE: Discovery questions
Sure no problem. I can bring those over tomorrow as well.
From: <
Sent: Wednesday, August 19, 2020 7:22 PM
To: (NY) (FBI) < >;
Cc: (USANYS)
EFTA00073275
Subject: (EXTERNAL EMAIL) - RE: Discovery questions
Perfect, thanks! Yes, I think we should take the vhs tapes and microcassettes to get them converted, if that's ok.
From: • (NY) (FBI) c l>
Sent: Wednesday, August 19, 2020 7:20 PM
To:
Cc: (USANYS)
Subject: RE: Discovery questions
That sounds great. Thank you. We are definitely open to them scheduling a time if need be.
I will check in with CART again and get back to you.
As far as the paper evidence and case file, we can drop that off to your office sometime tomorrow evening. Just working
on putting it all on a disk/thumbdrive for you. Also, FYI, included in the boxes from Reiter are vhs tapes and
microcassettes. Would you like us to turn these over to you as well? Let me know your thoughts on this.
Thanks!
From: <
Sent: Wednesday, August 19, 2020 7:01 PM
To: (NY) (FBI) cz >
Cc: (USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thank you so much for these —very helpful (and sorry I didn't realize the message pad scans also had the same pages
without post-its!)
On these:
• Yes, please send over the copy of the gj transcript disc when you can.
• Found the original scans from the FL file—thank you!
• Yes, please get us the paper evidence from NY, VI, and Reiter as soon as you can.
• We'll take the FBI file whenever you can get it to our office.
• My understanding from past FBI cases is that CART completes some sort of paperwork documenting the dates on
which they conduct data extractions. We need that for all of the extractions in this case, please (It may not be
302s).
• On the evidence from disks, understood. In order to give you more time, we are going to tell the defense
attorneys that the materials are available for them to review in-person if they want to schedule a time to come
down to the FBI office, but that in the meantime we are still working on getting copies of non-nude images to
produce to them.
EFTA00073276
From: . (NY) (FBI)
Sent: Wednesday, August 19, 2020 2:21 PM
To:
Cc: .; (USANYS)
Subject: RE: Discovery questions
Hey all, below is a summary of the discovery items you've requested.
Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page
without the post it note, so the pages are back to back.
Papers from Miami case file (grand jury testimony): This is a disk — I can copy it and send it over to you.
Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scans
last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from
the NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.
FBI file: We have that ready for you.
CART: There are no 302s regarding the extraction of devices.
Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This
is the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together,
that would be very helpful.
If it's helpful to talk through some of this via phone, we are happy to do that as well.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
From: <
Sent: Tuesday, August 18, 2020 6:41 PM
To: >;
Cc: (NY) (FBI)
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thanks so much, M. Really appreciate all the work you and are putting in on this. Let's touch base tomorrow
to figure out the timeline for the discovery issues.
From: <
Sent: Tuesday, August 18, 2020 6:40 PM
To:
Cc: (NY) (FBI) < >;
(USANYS)
Subject: Re: Discovery questions
EFTA00073277
Hey guys,
Apologies but today I was out In the field on surveillance and was also out of the office so we've not
been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into
this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to
get on this list. That being said I don't want to make you any promises that everything will be compiled by
tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you
like to square some of this away.
I did receive your "pages from Miami_case_docs" PDF.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From: <
Sent: Tuesday, August 18, 2020 6:03 PM
To:
Cc: (NY) (FBI) c ).*,
(USANYS) <
Subject: RE: Discovery questions
Hi'Nand =I
Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these
materials tomorrow or Thursday?
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:41 PM
To:
Cc: (NY) (FBI)
(USANYS)
Subject: RE: Discovery questions
Hi~ands
EFTA00073278
The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a
larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to
provide us with all of those scans this week?
With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on
them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:45 AM
To:
Cc: (NY) (FBI) ;
(USANYS)
Subject: RE: Discovery questions
Sorry, got a bounceback for too. I'm just attaching the one page I referenced in my email below. Hopefully that
will go through.
From:
Sent: Tuesday, August 18, 2020 4:40 AM
To:
Cc: (NY) (FBI) < >;
(USANYS)
Subject: FW: Discovery questions
I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went
through for so she can see it. If not, please let me know.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:33 AM
To: (NY) (FBI) < >
Cc: ) '`z )
(USANYS)
Subject: Discovery questions
and
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent
batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery dropped off a few days ago with requests for additional items:
• The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
• The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think
mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad—and those
EFTA00073279
copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad
scans" folder. Would you please get us a scans of these without post-its on them?
• It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant.
Would you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
• Full FBI sentinel file
• CART paperwork regarding the extraction of data from all devices seized during the investigation
• All 302s regarding the extraction of data from any seized devices and the review of images (both digital and
hard copy) seized during the investigation, including from Epstein's properties.
• Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
• Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been
scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any
nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how
many such images were scanned, where they were from, and where they are being stored.
• Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform
for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude
images. For nude or partially nude images, please provide us with a log detailing how many such images were
located, where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
Assistant United States Attorney
Southern District ofNew York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00073280
DataSet-10
Unknown
180 pages
Original Transcript
IN THE CIRCUIT COURT OF THE FIFrEENTII JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL, DIVISION
L.M.,
Plaintiff,
vs. CASE No.
502008CA0280513OOOCMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME H
October, 20, 2009
10:10 a.m.
515 N. Flagler Drive
Suite 200-P
West Palm Beach, Florida 33401
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
S Suite 600
4440 PGA Boulevard
ESQUIRE •n Al noel. Vall•Compny
Palm Beach Gardens, FL 33410
wvnv.esoulresolutIons.com
EFTA00182476
•
•
•
EFTA00182477
131
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE No.502008CA028051XXXXMB AB
L.M.,
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
Tuesday, October, 20, 2009
10:10 - 3:30 p.m.
D15 N. Flagler Drive, Suite 200-P
West Palm Beach, Florida 33401
Reported By:
Teresa Whalen, RPR, FPR
Notary Public, State of Florida
West Palm Beach Office Job #118991
Toll Free: 866.709.8777
• 0 Facsimile. 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
way.esquIresoludons.com
EFTA00182478
- Volume II October 20, 2009
132
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CV-80119-CIV-MARRA/JOHNSON
4 JANE DOE NO. 2,
Plaintiff,
-vs-
7 JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
10 08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
11 /
12
DEPOSITION OF
13 VOLUME II
14
Tuesday, October 20, 2009
15 10:10 - 3:30 p.m.
16
515 N. Flagler Drive, Suite 200-P
17
West Palm Beach, Florida 33401
18
19
20
21 Reported By:
Teresa Whalen, RPR, FPR
22 Notary Public, State of Florida
West Palm Beach Office Job 11118991
23 Phone:
24
25
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQLTLRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutlons.com
EFTA00182479
- Volume II October 20, 2009
133
• APPEARANCES:
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE
BURMAN CRITTON LUTTLER & COLEMAN, LLP
303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
Phone:
7 On behalf of Plaintiff L.M.:
BRADLEY J. EDWARDS, ESQUIRE
CARA L. HOLMES, ESQUIRE
ROTHSTEIN ROSENFELDT ADLER
401 E. Las Olas Boulevard, Suite 1650
10 Fort Lauderdale, Florida 33394
Phone:
11
12 On behalf of the Witness:
13 BRUCE E. REINHART, ESQUIRE
LAW OFFICE OF BRUCE E. REINHART
• 14 250 S. Australian Avenue, Suite 1400
West Palm Beach, Florida 33401
15 Phone:
16
17 On behalf of Defendants/Jane Does 2 - 8:
18 STUART S. MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
19 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
2C Phone:
21 On behalf of Plaintiff in related Case No. 08-80811
22 JACK HILL, ESQUIRE (Partially via speakerphone)
SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY
23 2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
24 Phone:
25
Toil Free: 866.709.8777
• 0 Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, FL 33410
www.esquIresolutions.corn
EFTA00182480
- Volume II October 20, 2009
134
1
2
3 INDEX
4
5
6 WITNESS: DIRECT CROSS REDIRECT RECROSS
7
8
9 BY MR. EDWARDS: 5 190
10 BY MR. MERMELSTEIN: 135 208
11 BY MR. HILL: 156
12 BY MR. CRITTON: 173
13
14
15 EXHIBITS
16
17
18 NUMBER DESCRIPTION PAGE
19 DEPENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103
20 DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
21 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162
22
23
24
25
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.corn
EFTA00182481
- Volume II October 20, 2009
135
• 1
2
PROCEEDINGS
- -
3 Deposition taken before Teresa Whalen,
4 Registered Professional Reporter, Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 (Mr. Hill joined the proceedings in person.)
9 CROSS (
10 BY MR. MERMELSTEIN:
11 O Good afternoon. Is it all right if I call you
12
13 A Yes.
• 14
15
Q Okay. My name is Stuart Mermelstein, I also
represent some plaintiffs in these cases, and it is my
16 turn to ask you some questions.
17 We were talking about when Mr. Epstein was in
18 jail, which was between June 30th of 2008 and July of
19 2009; correct?
20 A Yes.
21 Q Now, during that time you weal. Lu work your
22 regular schedule at 358 El Brillo Way; is that correct?
23 A Yes.
24 • So you were working basically --
25 MR. CRITTON: She's not finished.
• 0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 000
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
wurw.esquiresolutions.com
EFTA00182482
- Volume II October 20, 2009
136
1 BY MR. MERMELSTEIN:
2 Q I'm sorry. Go ahead.
3 MR. REINHART: Do you need to expand on your
4 answer?
5 BY MR. MERMELSTEIN:
6 Q Were you finished?
7 A I worked regular hours, but sometimes there
8 are times that I report eight, sometimes I report
9 nine o'clock.
10 Q And I believe
11 A It's flexible.
12 Q Okay. And it was after he left jail that you
13 started working at 6:00 a.m., correct?
14 A Yee.
15 Q So whether you start work at eight or nine is
16 your choice? When you say "it's flexible," it means you
17 can chose whether to come at eight or nine?
18 A Yes. When he was not there.
19 Q Okay. It didn't matter whether you there at
20 eight or nine when he was not there, correct?
21 A No.
22 Q And what kind of things did you do at the
23 house -- let me ask the question this way.
24 How were your duties different when he was not
25 there during the time he was in jail from when he would
Toll Free: 866.709.8777
CIO Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beath Gardens, FL 33410
www.esquiresolutions.com
EFTA00182483
- Volume II October 20, 2009
137
• 2
come there before he went to jail?
A When he was in jail?
3 • Yes.
4 A I clean the house.
5 Q You had less to clean, is that fair to say,
6 because Mr. Epstein, I assume, based on your testimony,
7 there were much fewer people in the house than before,
8 correct?
9 A Yes. I made inventory of the linens.
10 Q I'm sorry?
11 A Of the linens, I made inventory of the linens.
12 Oh. Inventory of the linens?
13 A Inventory.
• 14
15
Q Okay.
do to fill the time?
So you did that. And what else did you
16 A Wash the clothes that was in storage, you
17 know.
18 Q You washed clothes in storage?
19 A Yes. Because it was right there, so I just
20 wash it and then press if it needs pressing.
21 Q So he has clothes stored outside of Lhe house?
22 A No. In the house.
23 Q In the house. Okay. So even if they hadn't
24 been worn, you washed them, correct?
25 A And press them.
• 0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA00182484
- Volume II October 2C, 20C9
138
1 MR. CRITTON: Form.
2 THE WITNESS: Yes.
3 BY MR. MERMELSTE:N:
4 Q What other type of things did you do while he
wasn't there?
6 A If there are plants, I attend to the plants.
7 Q Okay. Is that something you didn't do before
8 he went to jail?
9 A I do that also when before he went to jail.
10 0 Okay.
11 A If there are orchids or plants in the house,
12 then I attend to it.
13 Q I guess my question is what kind of projects
14 did you work on when he was not there to fill your time
15 after he went to jail?
16 A Cleaning, tidying, just going around the
17 house. If I see something that needs painting, I tell
18 Janusz.
19 Q Now, are you paid on the basis of a yearly
20 salary, or are you paid weekly or monthly; how does that
21 work?
22 A We are paid twice a month.
23 Q Okay. That's when you receive your pay?
24 A Yes.
25 Q I guess my question is this: Say you have to
Toll Free: 866.709.8777
Facsimile: 561.394.2621
0
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquireSOlUtiOns.COm
EFTA00182485
- Volume II October 20, 2009
139
• 2
take a half a day of work off, do you get paid for that?
A Yes. In my situation.
3 Q I'm sorry. In your what?
4 A In my situation I was paid.
5 Q Okay. So you're on like a fixed salary, if
6 you miss some time you still get the same amount of
7 money, correct?
8 A Yes.
9 Q And I take it that during the period in which
10 Mr. Epstein was in jail, you continued to receive the
11 same salary, plus a raise, I assume, at the beginning of
12 the year; correct?
13 A Yes.
• 14
15
Q So you continued to receive the same salary
that you did before Mr. Epstein went to jail, correct?
16 A Yes, sir.
17 Q Did Mr. Epstein ever pay bonuses or any extra
18 money to you?
19 A Yes.
20 Q What kind of bonuses did you receive?
21 A Yearly bonus.
22 Q You get a yearly bonus. When is that paid, is
23 that paid at holiday time, Christmas time?
24 A After the year.
25 Q At the end of the year?
Toll Free: 866.709.8777
Facsimile: 561.394.2621
• Suite 600
ESQUIRE, 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA00182486
- Volume II October 20, 2009
140
1 A At the end of the year.
2 Q At New Years?
3 A New Years.
4 Q And this past year, when 2008 became 2009, how
5 much of a bonus did you receive?
6 A I did not receive any.
7 Q And what about before that, what kind of bonus
8 did you receive?
9 A The yearly bonus.
10 • Okay. What would be the amount of the yearly
11 bonus?
12 A Oh. For me? The last one I receive was
13 5,000.
14 • Okay. So this would be in addition to your
15 salary of $42,000?
16 A Yes.
17 Q And this $5,000 bonus you would have received
18 in or about January 2008; is that correct?
19 A Not eight.
20 Q Pardon?
21 A Not eight. We did not get any bonus in 2008.
22 Q Okay. So when was the last time you received
23 a $5,000 bonus?
24 A I think 2007.
25 Q So it's been two years since you've gotten a
0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.corn
EFTA00182487
- Volume II October 20, 2009
141
1 bonus; is that correct?
2 A Let me see. Yes.
3 Q Okay. Did Mr. Epstein explain to you why he
4 wasn't giving you a bonus in the last two years?
5 A He did not personally told us.
6 Q Did someone tell you why you were not getting
7 a bonus?
8 A Janusz was informed, and Janusz informed me.
9 Q Okay. Did Janusz give you a reason why you
10 weren't getting a bonus?
11 A Because of the economy, that's what he said.
12 • Any other reason that he gave?
13 A No, sir.
14 Q Did you receive a $5,000 bonus for 2006 and
15 2005?
16 A It was different, it gradually increased.
17 • Okay.
18 A It was not the same amount.
19 Q What was the bonus in 2006 and 2005?
20 A 2005 was 2,000.
21 Q Uh-huh.
22 A And then the next is 5,000 and 5,000.
23 • Okay. So correct me if I am wrong, but in
24 January 2005 you received a $2,000 bonus?
25 A Yes.
• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Sun& 600
ESQUIRE 4440 PGA Boulevard
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1 Q And at that point in time you had really just
2 started a month and a half before?
3 A No. I want to correct that. I receive a 500
4 after I started there November.
5 Q Yes. November of 2004 you started?
6 A At Christmas I receive, after Christmas I
7 receive $500.
8 Q Okay. So in January of 2005 you receive $500,
9 correct?
10 A Yes.
11 Q Then in January 2006 you received how much?
12 A 2,000.
13 Q And in January 2007 you received 5,000; is
14 that correct?
15 A Yes.
16 Q And in January 2008 you received no bonus?
17 A No.
18 Q Is that correct?
19 A Correct.
20 Q Correct, you received no bonus?
21 A No bonus.
22 Q And the same in January 2009, correct?
23 A Correct.
24 Q Has Mr. Epstein advised you, discussed with
25 you at all how much of a bonus you're going to receive
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• 1
2
after the holidays this year?
A No, sir.
3 Q Has anyone discussed with you what bonus you
4 will receive after the holidays this year?
A No.
6 0 Do you have any expectation as to what kind of
7 bonus you'll receive?
8 A I don't -- I did not expect anything.
9 Q You testified earlier about a who is the
10 housekeeper in New York, correct?
11 A Yes.
12 Q Now, when was the first time you met III in
13 person?
• 14
15
A
Q
In person? When I went to New York.
And when was the first time you went to
16 Now York?
17 A In 2006.
18 Q 2006. And was the reason you went to New York
19 in 2006 for Ms. Maxwell's party?
20 A No. It was III I think had a surgery.
21 Q Okay. And you were there to cover fur her
22 while she had surgery?
23 A Yes.
24 Q And how long were you there?
25 A I cannot remember, but after her surgery, then
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we left to Palm Beach.
2 Q Okay. You don't remember how long it was?
3 A I cannot remember, because I've been there
4 like four times, or more than four times.
5 Q More than four times?
6 A Yes.
7 Q Okay. So this first time when she had her
8 surgery, you were the housekeeper then in New York while
9 she was out, correct?
10 A Yes, sir.
11 Q But did she come into the house in New York
12 and that's how you met her while she was recovering, or
13 how was it that you met her at that time?
14 A We met her before her surgery, I met her
15 before her surgery.
16 see. Then she went and had her surgery.
17 Now, when you traveled to New York, did you go
18 on Mr. Epstein's plane?
19 A No, sir.
20 Q How did you travel to New York?
21 A Commercial.
22 Q So Mr. Epstein purchased you a ticket on an
23 airline to fly to New York?
24 MR. CRITTON: Form.
25 THE WITNESS: Yes, sir.
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• 2
BY MR. MERMELSTEIN:
O Now, let's talk about the other times that you
3 went, you traveled to New York. When was the next time
4 afLeL Lecover.ed fLum lies sulyety Uiat you went to
5 New York?
6 A I think when she went to the Philippines.
7 O Okay. She went for like a vacation to go to
8 visit her family?
9 A No. I'm not really good. There was time I
10 went there because I think I sometimes interchange, but
11 T went there one time herAuse to rover up for
12 Ms. Maxwell's housekeeper.
13 Q Okay.
• 14
15
A
Q
And when she was having a party.
Okay. So those are two separate times?
16 A Yes. Two separate times.
17 Q Both relating to Ms. Maxwell?
18 A No. The first one was -- first one to cover
19 up for III.
20 Q Right. I understood that. But after that,
21 when you came back --
22 A There was a time -- I don't know the sequence,
23 but you know, there was a time I have to cover up for
24 Ms. Maxwell's housekeeper.
25 Q I see. What's her name?
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1 A
2 Q And then there was another time where you went
3 to work for this party that she had, correct?
4 A Yes.
5 Q Okay. And the fourth time?
6 A When III went to the Philippines.
7 • Okay. About how long were these visits each
8 time?
9 A Sometimes a week, two weeks, then there was a
10 time I stayed there for like a month.
11 Q Which was that, when she had her surgery, III
12 had her surgery, or was this a different time?
13 A Oh, what's this? Let me see. I cannot
14 really, what's this?
15 Q Take your time, take your time.
16 A Oh. When, what's this, Ms. Maxwell's
17 housekeeper, I was to cover up for her because tor jury
18 duty. And then she was not part of the jury, so my stay
19 there was, like, extended. That's how I was able to
20 help with the party.
21 • She did not get on the jury?
22 A Yes. she was called.
23 • But you stayed anyway to help with the party?
24 A Yes.
25 Q I think I understand. Now, have you ever,
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• 2
while you've been employed by Mr. Epstein, traveled
anywhere else for work?
3 A No, sir.
4 Q Those trips to New York was the only time
5 you've traveled?
6 A Yes, sir.
Q You've never gone to New Mexico or to the
8 Virgin Islands for Mr. Epstein?
9 A No.
10 (Plaintiff's Exhibit No. 2 was marked for
11 identification.)
12 BY MR. MERMELSTEIN:
13 Q Let me show you what's been marked Exhibit 2.
• 14
15
Does it look like the paper that you were talking about
earlier where you wrote the names and the time?
16 A Yes, sir.
17 Q Okay. So this is kind of a notebook or a
18 message pad notebook that was I think you said located
19 by the pantry?
20 A Yes, sir.
41 Q Can you look through this and Lell me if any
22 of these, point out any of those that are in your
23 handwriting?
24 MR. REINHART: Take your time, look at each
25 one, and just tell him if you see any that you
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1 recognize your handwriting.
2 MR. CRITTON: You asked her to identify if she
3 sees anything in her writing?
4 MR. MERMELSTEIN: Yes.
5 THE WITNESS: (Shaking head.)
6 BY MR. MERMELSTEIN:
7 Q Okay. I understand your response is that you
B reviewed the various message slips included in Exhibit
9 No. 2 and none of them are your writing, correct?
10 A Yes, correct.
11 • But you do recall writing messages on this
12 type of pad for Mr. Epstein, correct?
13 A Correct.
14 MR. CRITTON: Stuart, that was exhibit what at
15 Mr. Rodriguez's deposition?
16 MR. MERMELSTEIN: Exhibit 1 at Mr. Rodriguez's
17 deposition.
18 MR. CRITTON: Okay.
19 BY MR. MERMELSTEIN:
20 O In the period 2004 to 2008 before Mr. Epstein
21 went to jail, do you recall whether there were females
22 who were sitting at the pool in the home at 358
23 El Brillo Way who were topless?
24 A There was one time.
25 • One time you remember. Tell me what happened
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that time.
2 A I was tidying the living room, then not
3 really -- there was like part of the wall, so I saw one
4 female there but not really, I saw it like this side
5 (indicating), so...
6 Q She was at the pool, or inside the house?
7 A This side, not really frontal, but on the side
8 I saw only -- I saw her side, not really like...
9 MR. REINHART: His question was, was she
10 inside the house or out by the pool when you saw
11 her from the side.
12 THE WITNESS: The question -- they were in the
13 pool.
14 BY MR. MERMELSTEIN:
15 Q Okay. So she was not wearing a bathing suit
16 top, correct?
17 A Yes.
18 Q Was she wearing a bathing suit bottom?
19 A I did not know.
20 Q And how did you -- did you do anything in
21 response to this?
22 A No. I went to, what's this, to kitchen and I
23 told Alfredo not to go to the pool.
24 Q And this was the only time you ever remember
25 seeing a girl who wasn't wearing a top at the pool?
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1 A Yes.
2 Q Were there frequently females at the pool to
3 the house?
4 A No. Not frequently.
5 Q Not frequently. Sometimes?
6 A Sometimes.
7 Q Mr. Epstein would travel with some females, I
8 think they would come on the plane with him to the
9 house; is that correct?
10 MR. CRITTON: Form.
11 BY MR. MERMELSTEIN:
12 Q You can answer.
13 A I cannot remember if they -- let me see.
14 remember . Because when Mr. Epstein arrives, most
15 of the time I'm already off.
16 • Let me ask the question this way: Were there
17 females other than who would come with Mr. Epstein
18 on the plane and stay at the house?
19 MR. CRITTON: Form, predicate.
20 BY MR. MERMELSTEIN:
21 Q Stay overnight at the house?
22 MR. CRITTON: Same.
23 THE WITNESS: I did not know if they came with
24 Mr. Epstein, I did not see.
25
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BY MR. MERMELSTEIN:
2 Q Okay. There were females who would stay
3 overnight at the house, but you're not sure how they got
4 Lu Lite house; is that fait to say?
5 A Yes.
6 Q Did any of the females who came to the kitchen
entrance to give a massage, did any of them stay
8 overnight?
9 A No, sir.
10 Q Never, correct?
11 A Yes, sir.
12 MR. CRITTON: Did you say correct and she said
13 yes?
• 14
15
MR. MERMELSTEIN:
MR. CRITTON: Okay.
Yes.
Thank you.
16 BY MR. MERMELSTEIN:
17 Q The girl at the pool who was topless, do you
18 recall what her name was?
19 A No.
20 • Do you recall how she got to the house or, you
21 know, what her purpose was in being there?
22 A I cannot remember.
23 • Was she a girl who had come to give
24 Mr. Epstein a massage?
25 MR. CRITTON: Form.
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1 THE WITNESS: No.
2 BY MR. MERMELSTEIN:
3 Q The females who came to give Mr. Epstein a
4 massage, did they ever use the pool?
5 MR. CRITTON: Form, predicate.
6 THE WITNESS: I did not see.
7 BY MR. MERMELSTEIN:
8 Q You don't know?
9 A I don't know.
10 Q And again, this girl you saw topless was the
11 only one you ever saw who was in any stage of undress in
12 the pool area at the house; is that fair?
13 A Yes.
14 Q You mentioned in your testimony earlier that
15 there was a back massager that was in Mr. Epstein's
16 bedroom, correct?
17 A In the massage room.
18 Q In the massage room. It was what, on the
19 floor, on the massage table, where did you find it?
20 A Sometimes on the, what's this, the table,
21 sometimes on the floor.
22 Q So this would be a regular thing, you would go
23 in the room to tidy up and you'd find this massager,
24 correct?
25 MR. CRITTON: Form.
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• 2
THE WITNESS:
BY MR. MERMELSTEIN:
Yes.
3 Q You referred to it as a back massager,
4 correct?
5 A Yes.
6 Q And did you do anything to this, did you put
7 strike that.
8 Did you put away this massager?
9 A I return it to the drawer.
10 Q Was that a drawer in the armoire?
11 A No. In the bathroom.
12 Q In the bathroom cabinet?
13 A Yes.
• 14
15
Q
A
Were there other items in the drawer?
Lotions.
16 Q So those wore maccagc itemo
17 MR. CRITTON: Form.
18 BY MR. MERMELSTEIN:
19 Q -- that were in the drawer?
20 MR. CRITTON: Sorry. Form.
21 THE WITNESS: From Bodyworks, aroma massage
22 therapy.
23 BY MR. MERMELSTEIN:
24 Q So there was Bodyworks lotions and this back
25 massager; is that correct, in the drawer?
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1 A Yes.
2 • Anything else in the drawer?
3 A That's all. And I put some, like, hand
4 towels.
5 Q In the drawer?
6 A Yeah. On the side.
7 Q Was there any -- was there just one drawer
8 that was used for these massage materials, or was there
9 more than one drawer?
10 A There is only one drawer.
11 Q Would you do anything to this massager before
12 ycu put it in the drawer?
13 A No. I just return it there.
14 • Did you ever clean it?
15 A There was one time I clean it.
16 Q One time you clean it. About how many times
17 did this happen that you picked up the massager and put
18 it in the drawer; did it happen many times?
19 A Yes.
20 Q So on this one occasion why did you clean it?
21 A Because I thought it was, like, dirty, so I
22 clean it.
23 • Explain to me how it was dirty.
24 A There is -- the color is -- like you know
25 when -- like there is stains or something, you know,
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• 2
when something is not clean.
cleanliness, so I...
So I very particular about
3 O Did you believe that there was a sexual fluid
4 on it and that's why you cleaned it?
5 A No.
6 MR. CRITTON: Form.
7 THE WITNESS: No.
8 BY MR. MERMELSTEIN:
9 Q Mr. Rodriguez testified that you disliked the
10 task of putting away the massage items because you had
11 to clean them of sexual fluids and that was unpleasant.
12 Is that not true?
13 MR. CRITTON: Form.
• 14
15
THE WITNESS:
BY MR. MERMELSTEIN:
Not true.
16 Q So Mr. Rodriguez would be lying about that,
17 correct?
18 A Yes.
19 Q The way I asked that question was sexual
20 fluids, and that may be an ambiguous term. What if I
21 used the term "body fluids," does that change your
22 answer at all?
23 A No.
24 Q It's the same, you never cleaned body fluids
25 off of a massager, correct?
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I A No.
MR. CRITTON: Wait. You said -- when he said
3 correct, you said no. Does that mean he's not
4 correct?
5 MR. REINHART: Did you ever clean body fluids
6 off of a massager?
7 THE WITNESS: I don't know if it's fluid,
8 so.. .
9 BY MR. MERMELSTEIN:
10 Q Did you ever clean body fluid off of any
11 massager?
12 MR. CRITTON: Form.
13 THE WITNESS: No.
14 MR. MERMELSTEIN: I pass the torch.
15 CROSS (
16 BY MR. HILL:
17 Q I'm the mysterious voice that was on the phone
18 before, and now you get the privilege of seeing me in
19 person. I'm teasing, the privilege is mine. I won't be
20 very long with you, I promi
DataSet-10
Unknown
5 pages
A
VICTIM WITNESS
DOB
H
Jane
a D. J
1 Jane Doe #6 Doe #7 Jane oe
AGE AT FIRST 17 17 17
2 CONTACT
3 HIGH SCHOOL Royal Palm Beach HS Lake Worth HS Royal Palm Beach HS
BROUGHT BY 'Shasdy e .
4
DATES OF 07/15/2004 - 09/01/2005 07/22/2004 - 11/02/2005 02/25/2005 - 10/03/2005
CONTACT/ SOURCE SK Telephone SK Telephone SK Telephone
5
GIRLS RECRUITED Julie N/A a., Angela T.(20)
B.(18)
6
NUMBER OF multiple times (Bstated Approx. 15 Approx. 15
MASSAGES hundreds of times
7
ENTICEMENT
8 Title 18 USC 2422(b)
Interstate Commerce Telephone Records Telephone Records Telephone Records
Connection
9
Phone calls with From SK - 90 From SK - 86 From SK - 42 Total
Total - Over 225 calls Total - Over 120 calls - Over 50 (70)
10 (233) (128)
Phone calls with From NM - 4 Total - 8 Total - 1 (NM calling
Total - 7/8 (one repeat)
11
Phone calls with Total 3 Total - 14 Total - 30
12
Under 18 at time of YES - 17 (Estated 16 YES YES - 17
sexual activity and 16/17)
13
Advised if asked to
state they were over
18/Advised by
whom?
14
:_374Nc DOESA(O - i Po9f 1 o
EFTA00234710
A H J
VICTIM WITNESS
DOB Jane
1 Jane Doe #6 Doe #7 Jane Doe #8
Knowledge or sold JE she was 18. toriginally told JE she atold JE she was 17
Discussion of Age JE responded that he was 18, but on her age and she stated he
with JE? knew she was not 18. JE eighteenth birthday JE was well aware of her
sent roses to RPBHS for gave her four tickets to age.
t or her performance in see David Copperfield in
a school play. • Fort Lauderdale, Florida.
provided JE with a school
transcript in hopes he
would help her financially
and obtain entry into NYU.
to NY for her
flown
18th Birthday.
15
Payment for YES/$200.00 1st time, YES/$200.00 YES/$200.00 for
services?/Amount $300.00 - $600.00 and massages, 5350.00 for
$1000.00 paid after penile intercourse.
16 penetration.
Payment for YES - nstated NO NO
17 recruitment recvd $200.00
Payments made by Epstein
18
Taken upstairs by
19
Clothing worn Panties only - first 1st time - Shorts and Bra, Thong panties only -
during massage massage/ Nude 3rd visit - Nude approx. two times nude
20
CAI DoeS ckb- —Q, pap 2 oF5
EFTA00234711
A { H 1 J
VICTIM WITNESS . B.
DOB Jane
Jane Doe #6 Doe #7 Jane Doe #8
1
Sexual activity JE digitally penetratedE. JE touched breast JE masturbated each time
JE would rub his penis on and vagina. 2-3 separate provided a masage.
her breast. JE used a occasions, JE touched JE began touching on
back massager/ vibrator vagina and fondled her buttocks and grabbed
on vagina. JE her breast. Approx. 4 her closer to him as he
performed oral sex on M. times JE placed a large masturbated. JE also
On one occasion, JE vibrating back massager grabbed breasts and
vaginal penetrated M, directly on vagina fondled her breast with his
NM witnessed the while he masturbated. On hands as she massaged
enetration. JE requested at least two occasions, him. JE frequently placed
to perform oral sex on JE's girlfriend/assistant a laifimassagerivibrator
NM, when she refused he Nada accompanied on vagina. JE
offered her an extra with providing massages. introduced NM during a
S200.00 for five minutes. Nada got naked and massage session with
All but once, but less than performed sexual acts NM and JE had sexual
five times, JE requested with JE, including the use intercourse while ■
and NM engage in of the massager and oral watched. NM touched JE
sexual activity, i.e. kissing, sex. Nada touched MI while and her kissed.
touching, and oral sex, in vagina, IN pulled Nada's NM and also touched
front of him and with him. hand away. On more each others breasts and
Additional sex toys were than one occasion, Nada buttocks. JE had sexual
introduced and used on placed the massager intercourse with El on
Ill by JE and NM during directly on vagina. one occasion prior to MI
the massages. 18th birthday.
21
Masturbation YES YES YES
22
Ejaculation YES YES
23
Statements made by On more than one JE asked El
to touch his
Epstein occasion, JE asked to penis, she declined. JE
have sex with him and asked about he
perform oral sex on him. attending college in the
future. JE rovided
advice on bad credit,
dealing with her parents
and school.
24
-JANE- DOES. - (c) — 5 Pot 3 of s
EFTA00234712
A H J
VICTIM WITNESS B. fala
DOB Jane
1 Jane Doe #6 Doe #7 Jane Doe #8
Asked to bring N/A
others/By whom?
25
Gifts YES - Multiple YES - Brazilian bathing YES - ...Secret
Secret underwear sets. suit, Western Union - Bra and Panties sets,
Bathing suit and Louis Cancun S350.00 Rec. Digital camera and
Vuitton purse. Movie 06/02/2005 Western photography book
tickets/show tickets ie. Union - San Diego
David Copperfield (FL) 5200.00 Rec
and Phantom of the 07/13/2005
Opera (NY). Plane ticket David Copperfield Tickets
to NY. 52000.00
Christmas bonus. 2005
Dodge Neon.
believed JE would pay for
26 her to attend NYU.
Physical Evidence MP - 6 MP - 10 TP MP - 7 TP
(i.e. Message Pads, SW-H.S. Transcript - 09/21/2005
Trash Pulls, Search JB's Petty Cash Receipt JB's Petty Cash Receipt
Warrant, Payment Photo Lineup-Nadia ID Brazilian bathing suit,
Documentation, etc.) Palm Beach PD report- Western Union - Cancun
taken when went to $350.00 Recvd
pick up Christmas bonus. 06/02/2005 Western
2005 Dodge Neon rental Union - San Diego
car. $200.00 Recvd
27 07/13/2005
28 Counts
29
TRAVEL Title
30 18 USC 2423(b)
Dates of
31 Travel/Aircraft
32
TRANSPORTATION
33 Title 18 USC 2421
Dates of
34 Travel/Aircraft
Sexual activit with Yes, kissing, touching and .Yes, Nada touched Yes, NM kissed S NM
oral sex. NM vaginally vagina, pulled Nada's touched breast.
penetrated El with hand away. On more
vibrator/sex toys. than one occasion. Nada
placed the massager
35 directly on IM vagina.
36 Counts
37
HUMAN SEX
TRAFFICKING
38 Title 18 USC 1591(a)
3 -AN E, DOES -14
pol 61 5
EFTA00234713
A H J
VICTIM WITNESS
DOB e B Jane
Jane Doe #6 Doe #7 Jane Doe #8
Who Scheduled SK, JE SK SK, AM(MessPd -4),
Appointments? NM(MessPd -1)
39
40 Counts
41
Interviewed by PBPD Yes No/Contact made Yes
42
43 Interviewed by FBI Yes Yes Yes
44 Miscellaneous
.wrote her cellular stated Ereceived
telephone number for JE $200.00 for bringing Et°
on a notepad described JE.
as having JE's name on
the bottom of the pad.
45
Siet-Oc Does 44 (O - 8 pact 5as
EFTA00234714
DataSet-10
Unknown
17 pages
KIRKLAND & ELLIS LLP
SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL
IN THE MATTER OF JEFFREY E. EPSTEIN
Jeffrey Epstein, a successful businessman and noted philanthropist with no prior criminal
record, has been investigated for potential violations of 18 U.S.C. §§ 1591, 2422(b) and 2423(b).
Since the limited review conducted by CEOS, two Supreme Court decisions—one authored by
Justice Scalia and the other by Justice Thomas—have revitalized the bedrock principles that
federal criminal statutes must be narrowly construed, that they may not be stretched to federalize
conduct not clearly covered by their prohibitions, and that whenever there are two plausible
constructions of a criminal statute, the narrower construction (hich safeguards liberty) rather than
the broader construction (which expands the federal prosecutor's arsenal) controls under the
venerable rule of lenity.
Mr. Epstein's conduct—including his misconduct—falls within the heartland of historic
state police and prosecutorial powers. Absent a significant federal nexus, matters involving
prostitution have always been treated as state-law crimes even when they involve minors. Mr.
Epstein's conduct lacks any of the hallmarks that would convert this quintessential state crime
into a federal one under any of the statutes prosecutors are considering.
Mr. Epstein lived in Palm Beach, and his interstate travel was merely to go home. My
sexual conduct that occurred after he arrived was incidental to the purposes for his travel. Even
CEOS admitted that applying § 2423(b) to a citizen traveling home would be "novel." In fact, it
would be both unprecedented and in conflict with Supreme Court cases that have withstood the
test of time for over 60 years.
Moreover, Mr. Epstein did not use the intemet (either via email or chatrooms) to
communicate with any of the witnesses in this investigation. Indeed, he did not use any other
facility of interstate commerce, including the phone, to knowingly persuade, entice, or induce
anyone to visit his home—the "local" locus of all the incidents under investigation—much less
to persuade, entice, or induce a known minor to engage in prohibited sex acts, as § 2422(b)
requires. Nor did anyone on his behalf "persuade" or "induce" or "entice" or "coerce" anyone as
these words are ordinarily understood and as the new Supreme Court decisions mandate they be
applied: narrowly, without stretching ordinary usage to conform to a prosecutor's case-specific
need for a broad (and in this case unprecedented) application. In addition, as will be shown
below, § 2422(b) requires that the object of the communication be a state law offense that "can
be charged." Yet because the state of Florida's statute of limitations is one year for the first
prostitution offense and three years for other targeted offenses, and because all or virtually all of
the offense conduct at issue in the federal investigation occurred prior to June 20, 2005, those
acts can not be charged by the State, and thus cannot meet this essential clement of federal law.
Finally, Mr. Epstein neither coerced, nor enslaved, nor trafficked, nor derived any profit
from his sexual conduct. He was an ordinary "John," not a pimp. But § 1591 is directed only
against those who engage in force or fraud or coercion or who are in the business of commercial
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sexual trafficking. The statute has never been applied to a "John," and only a highly and
impermissibly selective prosecution could stretch § 1591 to reach conduct like that at issue in
this case.
In short, without "novel" interpretive expansions—a description used by CEOS itself—it
cannot be shown that Mr. Epstein violated any of the three federal statutes identified by
prosecutors. As the Supreme Court's recent decisions in Santos and Cuellar make clear, federal
law may not be stretched in that manner, and the current federal investigation relies, as its
foundation, on impermissibly elastic stretches of each statute beyond any reported precedent;
beyond the essential elements of each statute; well outside the ordinary construction of each
statute's limitations; and on a selective, extraordinary, and unwarranted expansion of federal law
to cover conduct that has always been exclusively within the core of state powers.
At this point in time, the need for Departmental oversight is critical. We appreciate this
opportunity to submit our assessment of the key facts in this case and review of the pertinent
federal statutes, and respectfully request that the Office of the Deputy Attorney General end
federal involvement in this matter so that the State of Florida may resolve this case appropriately.
Summary of the Facts
Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While
there, he routinely conducted business, received medical attention, socialized with friends, and
helped care for his elderly mother. Mr. Epstein also had various women visit his home to
perform massages. He did not personally schedule the massage appointments or communicate
with the women over the phone or the Internet. Rather, Mr. Epstein's personal assistants
scheduled many types of appointments, personal trainers, chiropractors, business meetings and
massages. The phone message pad taken from his house and in the possession of the
government confirmed that in many cases, the women themselves contacted Mr. Epstein's
assistants to inquire about his availability—rather than vice versa.
The majority of the massages were just that and nothing else. Mr. Epstein often would be
on the telephone conducting business while he received his massage. At times, the masseuses
would be topless, and some sexual activity might occur—primarily self-masturbation on the part
of Mr. Epstein. On other occasions, no sexual activity would occur at all. There was no pattern
or practice regarding which masseuse would be scheduled on a particular day—if one would be
scheduled at all—or whether any sexual activity might occur. Indeed, Mr. Epstein almost never
knew which masseuse his assistants had scheduled until she arrived. See Tab 3, Toll
Records.
Mr. Epstein specifically requested that each masseuse be at least 18 years old. The vast
majority of the masseuses were in fact in their twenties, many accompanied to Mr. Epstein's
home by friends or even other family members. Furthermore, most of the women who have
testified that they were actually under 18 have specifically admitted tbrimatically lying to
Mr. Epstein about their age. See Tab 4 . at 38-39; Tab 5, Tr. at 16; Tab 6,
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FR Tr. at 6 8, 22, 45; Tab 7,
O, MI
Tr. 13; Tab 8 Robson Tr. at 8; Tab 9, Tr. at 5; and
Tr. at 14-15 (excerpts from these transcripts are included below). Furthermore,
the women who visited Mr. Epstein's home all visited voluntarily and many willingly returned
several times.
The State Attorney's Office (the "SAO") has vast experience prosecuting sex crimes and
conducted an exhaustive, 15-month investigation of Mr. Epstein. A Grand Jury has concluded
that Mr. Epstein was merely a local "John," guilty of soliciting prostitution in violation of state
law. Notably, Florida law distinguishes soliciting from procuring and compelling prostitution if
minors are involved. Indeed, soliciting is a misdemeanor except for the commission of a third
subsequent offense, turning it into a felony. The SAO, therefore, sought and obtained an
indictment charging Mr. Epstein with felony solicitation of prostitution. Mr. Epstein is prepared
to plead guilty and accept a sentence for that offense—a sentence that, notably, is far more
severe than that meted out to other "Johns" convicted of violating Florida's solicitation laws for
cases in which sexual activity was alleged.
Though CEOS points out its admirable goal of "protecting children," a moniker that
engenders high emotions, the conduct alleged here involves women over 16, which is the age of
consent in 38 states and supplies the effective federal age of consent. The young women were by
no means the target of high-school trolling; they were individuals who, with friends, visited Mr.
Epstein's house—a home full of friends and staff. The civil complaints filed against Mr. Epstein
reiterate the fact that the individuals who visited Mr. Epstein would visit with their friends. And
Mr. Epstein never spoke to or had any contact with these women before they arrived at his
house. And again, the State is handling this matter appropriately.
We respectfully submit that that should be the beginning and the end of this matter. As
you know, the Department's Petite Policy precludes successive federal prosecutions after a State
has acted: "[A] state judgment of conviction, plea agreement [here held in abeyance solely as a
result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent
federal prosecution for the same act or acts." U.S.A.M. § 9-2.031A (emphasis added).
Consistent with that principle, and of particular relevance to this case, the Department itself just
recently observed the following:
[P]rostitution-related offenses have historically been prosecuted at the state or
local level. This allocation between state and Federal enforcement authority does
not imply that these crimes arc less serious, but rather reflects important structural
allocations of responsibility between state and Federal governments.... [T]he
Department is not aware of any reasons why state and local authorities are not
currently able to pursue prostitution-related crimes such that Federal jurisdiction
is necessary.
See Tab 11, November 9, 2007 Letter from Justice Department Principal Deputy Assistant
Attorney General Brian Benczkowski to the House Committee on the Judiciary, p. 8-9.
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Summary of the Law
We have reviewed every reported case under 18 U.S.C. §§ 1591, 2422(b), and 2423(b),
and cannot find a single one that resulted in a conviction on facts akin to the ones here. In some
respects, it is not surprising that no precedent supports federal prosecution of a man who engaged
in consensual conduct, in his home, that amounts to solicitation under State law. After all,
prostitution, even when the allegations involve minors, is fundamentally a State concern, United
States v. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (noting that federal law "does not
criminalize all acts of prostitution (a vice traditionally governed by state regulation)"), and there
is no evidence that Palm Beach County authorities and Florida prosecutors cannot effectively
prosecute and punish the conduct. See also Batchelder v. Gonzalez, No. 4:07-cv-00330-SPM-
AK, 2007 WL 5022105 (N.D. Fla. Oct. 19, 2007). In fact, the opposite is true—the state-elected
officials, cognizant of the local mores of the community, have a lauded history of just such
prosecutions.
In any event, and as set forth below, none of the federal statutes in this case remotely
supports a prosecution on the facts of this case without each and every element being stretched in
a novel way to encompass the behavior at issue. We begin with first principles. Courts in this
country have "traditionally exercised restraint in assessing the reach of federal criminal statutes,
both out of deference to the prerogatives of Congress, Dowling v. United States, 473 U.S. 207
(1985), and out of concern that `a fair warning should be given to the world in language that the
common world will understand, of what the law intends to do if a certain line is passed!" Arthur
Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283
U.S. 25, 27 (1931)) (citation omitted).
Two recent Supreme Court decisions dramatically underscore these principles and help to
highlight why federal prosecution in this case would be improper as a matter of both law and
policy. See United States v. Santos, No. 06-1005 (June 2, 2008); Cuellar v. United States, No.
06-1456 (June 2, 2008). Though they both address the interpretation and application of the
federal money laundering statute, 18 U.S.C. § 1956, the principles they set forth are equally
applicable here. In Santos, the Court held that the statutory term "proceeds" means "profits"
rather than "receipts," and thus gave the statute a significantly narrower interpretation than what
the government had urged. In his plurality opinion, Justice Scalia emphasized that where a
statutory term in a criminal statute could support either a narrow or broad application, the narrow
interpretation must be adopted because "[A/c interpret ambiguous criminal statutes in favor of
defendants, not prosecutors." Slip op. at 12. As his opinion explained, the rule of lenity "not
only vindicates the fundamental principle that no citizen should be held accountable for a
violation of a statute whose commands are uncertain, or subjected to punishment that is not
clearly proscribed. It also places the weight of inertia upon the party that can best induce
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Congress to speak more clearly and keeps courts from making criminal law in Congress's stead."
Slip op. at 6.'
In Cuellar, the Court examined the link between the money-laundering statute's mere rea
requirement and the underlying elements of the offense. After a careful textual analysis of the
statute and its structure, the Court ruled that the defendant's conviction could be sustained only if
he knew that the transportation of funds to Mexico was designed to conceal their nature,
location, source, ownership or control—not merely that the defendant knew that the funds had
been hidden during their transportation to Mexico. Slip op. at 10-17.
Both decisions relied on the ordinary meaning of the statutory terms Congress chose.
And both rejected attempts to broaden those words to cover conduct not clearly targeted by
Congress. Taken together, these decisions reject the notion that prosecutors can take language
from a narrowly drawn federal statute—especially one that itself federalizes the prosecution of
conduct traditionally within the heartland of State police powers—and convert it into a license to
reach additional conduct by ignoring, rewriting or expansively interpreting the law. Both cases
additionally rejected the notion that statutes should be broadly construed in order to facilitate
prosecutions or to in anyway diminish the burden on prosecutors to prove each essential element
of a federal charge in conformity with Congress's determinations as to what is within the federal
criminal law and what is not. The conflict between the Santos and Cuellar decisions and
CEOS's grant of effectively unlimited discretionary authority to the USAO to take federal law to
"novel" places where they have never reached before could not be starker.
These lessons have no less force in the context of Executive Branch decision-making
than they do in the context of Judicial interpretation. As you are aware, when federal prosecutors
exercise their discretion, they bear an independent constitutional obligation to faithfully interpret
the law as written—not to broaden its scope beyond the limits endorsed by both Congress and
the President. There is no support for CEOS's view that the courts or a jury should ultimately
decide whether a "novel" construction of the law is correct. Instead, the Executive Branch itself
has a non-delegable obligation not to exceed its authority; the power of other branches to check
or remedy such usurpation does not legitimize executive action that exceeds its bounds. See Tab
12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the
Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To
Execute Unconstitutional Statutes, available at http://www.usdoj.gov/olc/nonexcut.htm.
In this case, the text, structure, and history of the relevant federal statutes unambiguously
indicate that these statutes were designed to address problems of a national and international
Justice Stevens, in his concurring opinion, also acknowledged the rule of lenity, calling the plurality opinion's
discussion of that rule "surely persuasive." United States v. Santos, No. 06-1005, slip op. at 5 (June 2, 2008)
(Stevens, J., concurring).
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scope—not the local conduct that is alleged here—and each of these statutes requires proof of
the defendant's actual knowledge that simply is not present in this case. Any attempt to stretch
the language of these statutes to cover this case would be a misuse of the law and contrary to
express legislative intent. In short, the elements under each federal statute-18 U.S.C. §§ 1591,
2422(b) and 2423(b)—are not satisfied here.
1. 18 U.S.C. & 2422(b1
18 U.S.C. § 2422(b) requires the government to prove beyond a reasonable doubt that the
defendant engaged in communications over an interstate facility (e.g., the Internet or phone) with
four concurrent intentions: (I) to knowingly (2) persuade, induce, entice or coerce, or attempt to
persuade, induce, entice, or coerce (3) a minor (4) to engage in prostitution or criminal sexual
activity for which the person can be charged. Mr. Epstein's conduct does not satisfy the
elements of § 2422(b). Each element must be individually stretched, and then conflated in a
tenuous chain to encompass the alleged conduct with any individual woman.
As the statute makes clear, the essence of this crime is the communication itself—not the
resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point:
The defendant in Bailey contended that attempt under § 2422(b) `requires the
specific intent to commit illegal sexual acts rather than just the intent to persuade
or solicit the minor victim to commit sexual acts.' Id. at 638. In response, the
court held `[w]hile it may be rare for there to be a separation between the intent to
persuade and the follow-up intent to perform the act after persuasion, they are two
clearly separate and different intents and the Congress has made a clear choice to
criminalize persuasion and the attempt to persuade, not the performance of the
sexual acts themselves. Hence, a conviction under the statute only requires a
finding that the defendant had an intent to persuade or to attempt to persuade.'
United States v. Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States v. Bailey,
228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must occur through
the interstate facility, not thereafter, and the scienter element must be present at the time of the
call or Internet contact.
In this case, however, Mr. Epstein did not use an interstate facility to communicate any
illegal intention in this case; the phone calls were made by his assistants in the course of setting
up many other appointments. Neither a conspiracy charge nor a charge of aiding and abetting
can fulfill the mens rea requirement here. Indeed, neither Mr. Epstein nor his assistants knew
whether sexual activity would necessarily result from a scheduled massage. And certainly, no
such activity was ever discussed on the phone by either Mr. Epstein or his assistants. Instead, as
the record in this case makes clear, many appointments resulted in no illegal sexual activity, and
often, as confirmed by the masseuses' own testimony, several individuals who were contacted by
phone visited Mr. Epstein's house and did not perform a massage at all. Where sexual activity
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did result, it was mainly self-pleasuring masturbation and not necessarily illegal, but spontaneous
and resulted from face-to-face conversations during the massage. Thus, the fact that Mr. Epstein
later may have persuaded any particular masseuse to engage in unlawful activity during the
massage does not work retroactively to render the earlier scheduling phone call an offense under
§ 2422(b). Nor is there any evidence that women who returned to Mr. Epstein's home time and
again were somehow coerced or induced over a facility of interstate commerce to do so.
The first essential element of § 2422(b) that "[w]hoever, using the mail or any facility or
means of interstate or foreign commerce," by its plain language, requires that the
communication, which is the essence of the crime and its actus reus, take place during the use of
the facility of interstate commerce (in this case, unlike the vast majority of Internet chat room
sting operations, a telephone). The statute is not ambiguous. It requires that the criminal
conduct occur while the defendant is "using" (i.e. engaged in the communication), not thereafter.
Given the utter lack of direct evidence against Mr. Epstein, prosecutors have signaled that
they intend to offer a purely circumstantial case if this matter proceeds to trial—essentially
arguing that "routine and habit" evidence could substitute for actual proof that an interstate
facility was used to solicit sex from minors. Thus, despite the fact that the calls themselves were
not made by Mr. Epstein and did not contain the necessary explicit communication to knowingly
induce minors to provide sexual favors for money, prosecutors are seeking to turn the phrase "are
you available"—the same phrase used with friends, chiropractors, and trainers—into a ten-year
mandatory prison sentence. In any case, the prosecution's attenuated argument regarding
"routine and habit" will also not fit the facts of this case. The witness testimony at issue makes
clear that there was no clear "routine or habit" with respect to the interactions at issue. And in
those unpredictable instances where sexual contact resulted, it was a product of what occurred
after the benign phone communication, not during the call itself.
The prosecution's theory of liability—that a call to a person merely to schedule a visit to
the defendant's residence followed by a decision made at the residence to engage in prohibited
sexual activity is sufficient—cannot survive either a "plain language" test or the rule of lenity as
they have been authoritatively construed in the recent Santos and Cuellar cases. The statute
cannot be read otherwise. As the Cuellar decision makes clear, a proper interpretation of a
federal criminal statute is guided "by the words of the operative statutory provision," not by
outside objectives, such as those facilitating successful prosecution. See Cuellar, supra, Slip op.
at 7. As Justice Alito stated in his concurring opinion, the government must prove not just the
"effect" of the secretive transportation, but also that "petitioner knew that achieving one of these
effects was a design (i.e. purpose) of the transportation" of currency. Cuellar v. United States,
supra, 553 U.S., Slip op. At 1 (Alito, J. concurring). Similarly, it is not enough that one effect of
a communication scheduling a visit between Mr. Epstein and a minor was that there might be
subsequent face-to-face inducement. Instead, the statute, as drafted, defines the crime as the
communication and demands that far more be proven than that the use of an interstate facility
resulted in a later meeting where even an inducement (as opposed to a solicitation) was made.
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The prosecution has never represented to counsel that they have evidence that would
prove that the inducement or enticement to engage in illegal sexual acts occurred over the phone
(or Internet). The prosecution's references to "routine and habit" evidence that would substitute
for the explicit communications usually found in the transcripts from chat rooms or sting
operations is tenuous at best. In essence, the prosecution would be alleging communications
understood, but not spoken, by two people, one of whom was usually a secretary or assistant.
Separating the actus reus and the mens rea, however, and premising criminal liability on
persuasion that might occur after the communication, or on the existence of a specific intent to
engage in illegal sex with a minor that arises after the communication would violate the bedrock
principle of criminal law that predicates liability on the concurrence of the act and the criminal
state of mind. Even if, arguendo, the communication and mens rea could be separated (a
premise which is at odds with the requirement of concurrence), Mr. Epstein denies that the
factual proof demonstrates such a pattern or practice. Instead, the evidence compellingly proves
that there was no regularity or predictability to the content of the communication or in what
occurred at meetings that were telephonically scheduled (including those that are the subject of
this investigation).
A second essential element of 2422(6) requires that the defendant "knowingly" induce,
persuade, entice or coerce a person believed to be a minor. " .. . [K]knowingly . . . induces . .."
requires the Court to define inducement so it is consistent with its ordinary usage and so the term
is not so broad that it subsumes the separate statutory terms of "entices" and "persuades."
Inducement has a common legal meaning that has been endorsed by the government when it
operates to narrow the affirmative defense of entrapment. Inducement must be more than "mere
solicitation;" it must be more than an offer or the providing of an opportunity to engage in
prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (ls' Cir.
2005); United States v. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly,
or consistent with the rule of lenity, advocate a broader definition of the same term when it
expands a citizen's exposure to criminal liability than when it limits the ambit of an affirmative
defense to criminal conduct. If the term is ambiguous, absent clear Congressional intent on the
issue, the Court's decision in Santos requires that the narrower rather than the broader definition
be used.
The facts simply do not prove Mr. Epstein's culpability for knowingly inducing or
persuading minors. First, in the case of masseuses who agreed or even sought to return to see
Mr. Epstein on successive occasions, there is no evidence that there was any inducement,
persuasion, enticement or coercion over the phone. And, for masseuses seeing Mr. Epstein for
the first time, there was generally no telephone contact with Mr. Epstein and there was no
knowledge that any third party at Mr. Epstein's specific direction was inviting them to Mr.
Epstein's home over the phone rather than in face-to-face meetings. The women who visited Mr.
Epstein's home were all friends of friends. Contrary to the facts in this case, § 2422(b)'s
knowing inducement element is essential to federal liability and, given its hefty minimum
mandatory punishment, it should not be interpreted as a strict liability statute.
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There is insufficient evidence that Mr. Epstein targeted minors, as required. The
evidentiary pattern does not even establish willful blindness since Mr. Epstein took steps to
ensure his visitors were over 18—and certainly took none to avoid knowing. But, even if the
government contends that it possesses evidence that could demonstrate that Mr. Epstein knew or
should have known or suspected that a small number of the masseuses were underage, that would
still not make this an appropriate case for federal, rather than state prosecution. The federal
statutes were not intended to supersede state prosecutions involving isolated instances of
underage sex. Instead, the federal statutes were intended for large-scale rings or for an
individual who was engaged, while using interstate facilities such as the Internet, with the willful
targeting of minors.
The government's evidence, even when stretched to the limit, will not show a pattern of
targeting underage persons for illegal sexual activity. A federal prosecution should not become a
contest between the prosecution and defense over whether the defendant knew, suspected or
should have known whether a particular person was or was not over age. The history of cases
brought under this statute make crystal clear that knowledge of the defendant regarding the age
of the women is required—either by admission or by incontrovertible transcripts of
conversations (i.e. stings operations which require repeated acknowledgment of the defendant's
awareness of the victims' age). Even states with absolute liability about mistake regarding age
rarely prosecute cases where definitive proof is lacking (Palm Beach County rarely does and
when it does, it imposes house arrest sentences). This is a matter for the exercise of state
prosecutorial discretion and not federal mandatory minimum statutes that were not intended to
cover such conduct.
A third essential element of § 2422(b) is the requirement that the government prove that
the defendant actually believed that the person being persuaded (coerced, etc.) was a minor at the
time of the communication. See e.g., Offense Instruction 80, Eleventh Circuit Pattern Jury
Instructions-Criminal (2003) ("The defendant can be found guilty of that offense only if...the
defendant believed that such individual was less than (18) years of age..."); United States v.
Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) (§ 2422(b) requires that the defendant knowingly
target a minor). Importantly, then, all the elements must be proven with respect to a specific
person. However, we arc told that the majority of proof is no more than toll records, not
recorded conversations or Internet chat transcripts, but toll re-cords and perhaps a memory of
what was said years ago on a particular call for a particular request from a particular person
acting at Mr. Epstein's direction.
Two final points bear special emphasis here. The statute, which according to Santos and
Cuellar must be narrowly construed, also requires that the inducement be to engage in
prostitution or sexual activity "for which [the defendant] can be charged." 18 U.S.C. § 2422(b).
However, simple prostitution is not defined (or made punishable) in the U.S. Code, and state law
thus supplies the appropriate reference point. Under Florida law, "prostitution" entails the
"giving or receiving of the body for sexual activity for hire," Fla. Stat. § 796.07(1)(a), and the
term "sexual activity" is limited to "oral, anal, or vaginal penetration by, or union with, the
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sexual organ of another; anal or vaginal penetration of another by any other object; or the
handling or fondling of the sexual organ of another for the purpose of masturbation." Fla. Stat. §
796.01(1Xd). Also, the Florida Supreme Court jury instructions define prostitution as involving
"sexual intercourse." As a result, topless massages—even ones for hire that include self-
masturbation—fall outside the ambit of the state-law definition of prostitution. Absent proof
beyond a reasonable doubt that, at the critical time of the communication, Mr. Epstein had a
specific intent to persuade another to engage in prostitution or "sexual activity," as defined by
Florida law, he cannot be guilty of an offense under § 2422(b).
As important, the plain language of the phrase "for which any person can be charged"
necessarily excludes acts as to which the state's statute of limitations has run. Under Florida
law, prostitution and prostitution-related offenses are misdemeanors in the second degree for a
first violation.2 See Fla. Stat.. § 796.07(4)(a). The limitations period for a misdemeanor in the
second degree is one year, and there is no tolling provision based upon the victim's age. See Fla.
Stat. § 775.15(6). Even as to allegations of third degree felonies, the statute of limitations is
three years. Thus, any conduct alleged to have occurred before mid-June 2005 cannot be
charged as a matter of state law and thus cannot be a predicate for a § 2422(b) offense—even if
the federal statute of limitations has not run on any given § 2422(b) offense because of the
lengthier statute codified in 18 U.S.C. § 3282. Thus, no prosecution under § 2422(b) can be
brought based upon inducement of prostitution or sexual activity for which Florida's statute of
limitation has run. Furthermore, in Florida, the statute of limitations does not simply give rise to
an affirmative defense. On the contrary, statute of limitations "creates a substantive right which
prevents prosecution and conviction of an individual after the statute has run." See State v. King,
282 So. 2d 162 (Fla. 1973); Tucker v. State, 417 So. 2d 1006 (Fla. 3d D.C.A. 1982) (citing
cases).
Given the one-year statute of limitations, any conduct that might amount to prostitution
or other chargeable sexual activity that occurred before one year from today is not conduct for
which any person can be charged with a criminal offense. Also, given the three year statute of
limitations for third degree felonies, any allegations of illegal state criminal conduct that is
classified as a third degree felony cannot be charged in the state and, concomitantly, cannot be
the basis for a federal charge und the extent that it occurred—as did almost all of
the pivotal allegations (e.g., the allegation which was made in March of 2005)
prior to mid-June of 2005.
2. 18 U.S.C. 4 1591
2 The offense is a felony of the third degree only for a third or subsequent violation. Fla. Stat. § 796.07(4)( c).
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18 U.S.C. § 1591, a sex trafficking statute, provides up to 40 years' imprisonment for
anyone (1) who recruits or obtains by any means a person in interstate commerce (ii) knowing
that the person is under 18 and (iii) knowing that the person will be caused to engage in a
commercial sex act. The most heinous of crimes, described on the CEOS website, fall within
this statute and include the buying and selling of children and the forced servitude of third-world
immigrants brought to this country to be enslaved. Mr. Epstein's behavior is nowhere near the
heartland of this statute. This statute has also been previously reserved for prostitution rings
involving violence, drugs and force. In stark contrast, there is no jurisdictional hook that brings
Mr. Epstein's conduct within the ambit of the statute, and securing a prosecution on these facts
would require a court to set aside both reason and precedent to convict a local `John' with a sex-
slavery crime. It can not be said that Mr. Epstein engaged in trafficking and slavery nor did he
knowingly recruit or obtain underage women with knowledge that they would be caused to
engage in a commercial sex act. Thus, prosecuting him under this statute would expand the law
far beyond its scope.
To the extent there are cases where prosecutors think that Mr. Epstein should have known
that certain women were underage, there is no evidence that Mr. Epstein "caused [them] to
engage in a commercial sex act." The term "cause" naturally implies the application of some
sort of force, coercion, or undue pressure, but there is no evidence that Mr. Epstein's interactions
with the women were anything but consensual. Again, many of the women phoned Mr.
Epstein's assistant themselves in order to determine whether he wanted a massage. Nor can the
cause requirement be proved simply by the fact that Mr. Epstein compensated the women. After
all, the statute elsewhere requires that the women "engage in a commercial sex act," which by
definition means that they would have received something of value in exchange for sexual
services. Interpreting the statute to authorize prosecution whenever a commercial sex act results
from solicitation thus would render the term "caused" superfluous, and would make every `John'
who interacts with an underage prostitute guilty of a federal crime—even where the transaction
is entirely local. Read in context, then, there is no doubt that the statute targets pimps and sex-
traffickers who knowingly obtain underage girls and direct them to engage in prostitution. There
is not a shred of evidence that Mr. Epstein (or his assistants) did any such thing, and he cannot be
prosecuted under this statute.
The Cuellar and Santos decisions also foreclose a prosecution under § 1591. Just as the
federal money laundering statute did not come down to a proscription against transportation of
criminal proceeds that are hidden, the sex trafficking of children statute cannot be boiled down
and expanded to a federal proscription of commercial sexual activity with persons who turn out
to be below the age of 18.
3. 18 U.S.C. 4 2423
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18 U.S.C. § 2423(b), a statute enacted to prevent sex tourism, provides up to 30 years of
imprisonment for anyone who travels across state lines (i) for the purpose of engaging in (ii)
illicit sexual conduct with a minor. Neither of those elements is satisfied here.
Mr. Epstein did not travel to Palm Beach for the purpose of engaging in sexual activity
with a minor, within the meaning of the statute. The evidence is indisputable that Palm Beach
was where Mr. Epstein spent most of his discretionary time, and that his travels to Palm Beach
were merely trips returning often to his home of twenty years—not the escapades of a sex tourist
off to some destination inextricably intertwined with the required significant or dominant
purpose of that trip to be to have "illicit sexual conduct." Epstein's trips to Palm Beach were
simply those of a businessperson traveling home for weekends or stopping over on his way to or
from New York and St. Thomas or to visit his sick and dying mother in the hospital for months
on end. He certainly did not travel to his home in Florida for the dominant purpose of engaging
in sexual conduct with a person who he knew was under 18 when he did not know, at the time he
decided to travel, from whom he was to receive a massage, if he were to receive one at all.
In Cuellar, the unanimous Supreme Court linked the term "design" in the money-
laundering statute to the terms "purpose" and "plan," and stressed that those terms all required
the defendant to "formulate a plan for; devise"; "[t]o create or contrive for a particular purpose or
effect"; [carry out] "[a] plan or scheme"; or "to conceive and plan out in the mind." Slip. op. at
12 (citing dictionary definitions). The same link is present here, and it simply cannot be said that
Mr. Epstein's design, plan, or purpose in traveling to Palm Beach was to engage in illicit sexual
conduct with minors; his design or plan or purpose was simply to return to his home.
Any construction of § 2423(b)'s "for the purpose of language to include purposes
beyond the dominant purpose of the travel would run afoul of the rule of lenity and due process
principles discussed earlier. Any attempted prosecution of Mr. Epstein under a more expansive
construction of the "for the purpose of language would also violate the separation of powers
doctrine. Congress, which selected the "for the purpose of language signaled no clear intention
to make it a federal crime whenever an actor has engaged in illicit sexual conduct following his
crossing of state lines as long as it might be said that sexual activity at his destination was among
the activities he pursued there. Congress well knows how to write a statute in this field which
eliminates a purpose requirement. See 18 U.S.C. § 2423(c)("Any United States citizen or alien
admitted for permanent residence who travels in foreign commerce, and engages in any illicit
sexual conduct with another person ..."). § 2423(b) is not such a statute.
Federal court decisions watering down the "for the purpose of " requirement fly in the
face of the two Supreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S.
559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly
and clearly against prosecutors seeing such elasticity in federal criminal statutes, including those
enacted to protect important federal interests. In cases involving the federalization of activity
that is within the States' historic police power, Congress must speak with particular clarity. See,
e.g., Will v. Michigan Dep't of State Police, 491 U.S. 58, 65 (1989).
12
EFTA00210085
KIRKLAND & ELLIS LLP
Relevant Past Cases
We have not been able to find a single federal prosecution based on facts like these—but
have voluminous evidence of federal prosecutors routinely declining to bring charges in cases far
more egregious than this one. To take just one obvious example, federal prosecutors have self-
consciously refrained from involvement in the literally dozens of sexual cases of former priests,
opting instead to allow seasoned state prosecutors (like the ones in this case) to pursue the
accused former clergymen. That is so despite (1) the large number of victims, (2) the vast
geographic diversity of the cases, and (3) the fact that some of these cases involve allegations
that the defendant forcibly molested, abused, or raped literally dozens of children—including
some as young as five years old—over a period of years. Nonetheless, federal prosecutors have
not hesitated to let their state counterparts pursue these cases free from federal interference—
even though the sentences meted out vary greatly on account of the fact that "[c]riminal penalties
are specific to localities or jurisdictions."3 The facts of this case, which involve the solicitation
of consensual topless massages and some sexual contact, entirely in the privacy of his home and
almost entirely by women over the age of 18, pale in comparison to the outright sexual abuse and
degradation of preteen minors in many of the priest cases.
Nor does this case bear any of the hallmarks that typify the cases that federal prosecutors
have pursued under the federal statutes at issue here. When asked, the closest case suggested by
the prosecutors was United States v. Boehm—and it hardly could differ more from Mr. Epstein's
case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine
base to minors, in violation of 21 U.S.C. §§ 846, 84I(a)(1), and 859(a); being a felon in
possession of a firearm, in violation of 18 U.S.C. § 922(g)(I); and sex trafficking of children in
violation of 18 U.S.C. §§ 371 and 1591. United States v. Boehm, Case No. 3:04CR00003 (11
Alaska 2004). Boehm's actions, unlike Mr. Epstein's, also had a strong interstate nexus: Boehm
purchased and distributed large quantities of crack cocaine and cocaine that traveled in interstate
commerce, and he used his home and hotels (which were used by interstate travelers) to purchase
drugs and distribute them to minors while also arranging for these minors to have sex with him
and others. Indeed, Boehm not only (1) purchased cocaine in large quantities; (2) distributed the
drugs to minors; (3) possessed illegal firearms; (4) and arranged for the minors to have sex with
other members of the conspiracy in exchange for drugs; but (5) admitted to knowing the ages of
the individuals involved.4 Here, by contrast, as previous stated, all of the conduct took place in
Mr. Epstein's private home in Palm Beach; there was no for-profit enterprise; no interstate
component; no use by Mr. Epstein of an instrumentality of interstate commerce; no violence; no
force; no alcohol; no drugs; no guns; and no child pornography.
See http://www.bishop-accountability.org/reports/2004_02_27johnJay/2004_02_27_Terry_Johniay_3.htrn
#cleric7.
4 In fact, Boehm and his co-defendants distributed drugs to approximately 12 persons between the ages of 13 and
21. Boehm also had a prior criminal history—and one that clearly showed he was a danger to society: he
previously had been convicted of raping both a thirteen year-old girl and a fifteen year-old girl. (Day 7 of
Sentencing hearing p. 32).
13
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KIRKLAND & ELLIS LLP
To the extent there is a similar, but more egregious, local Florida case on the books, it is
that of Barry Kutun, a former North Miami city attorney accused of having sex with underage
prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami-
Dade County courtroom as part of an agreement with State prosecutors and he received five
years probation and a withholding of adjudication with no requirement to register as a sex
offender—all without a shred of involvement by federal prosecutors, who declined to prosecute
him. Indeed, given the wide use of the telephone in today's society, it gives a rogue prosecutor
carte blanche to turn any local crime into a federal offense. Given the federal government's
decision to abstain from prosecuting that case, it is hard to understand how the federal
prosecutors responsible for this case think that the State's treatment of Mr. Epstein somehow
leaves federal interests substantially unvindicated. There is simply no basis for the federal
prosecutors' disparate treatment of Mr. Epstein.
Summary of the Evidence
Finally, we wish to share new evidence—obtained through discovery in connection with
the civil lawsuits filed in this matter—which confirms that further federal involvement in this
matter would be inappropriate. This testimony taken to date categorically confirms that (i) Mr.
Epstein did not target minors; (ii) women under 18 often lied to Mr. Epstein about their ages; (iii)
Mr. Epstein did not travel in interstate commerce for the purpose of engaging in illegal sexual
activity; (iv) Mr. Epstein did not use the Internet, telephone or any other means of interstate
communication to coerce or entice alleged victims; (v) Mr. Epstein did not apply force or
coercion to obtain sexual favors; and (vi) all sexual activity that occurred was unplanned and
purely consensual. The women's own statements—made under oath—demonstrate the absence
of a legitimate federal concern in this matter, and highlight the serious practical difficulties an
attempted federal prosecution would face.
• Mr. Epstein did not recruit or obtain these women in interstate commerce (necessary
for a conviction under § 1591).
confirmed that she did not know Mr. Epstein and had
absolutely no contact with him—be it through Internet, chat rooms email,
or phone—prior to their arrival at his home. See Tab 13,
(deposition), p. 30.
has stated that like man other women) she first met Mr.
Epstein w
DataSet-10
Unknown
65 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-CIV-Marra/Matthewman
JANE DOE # I and JANE DOE #2,
Petitioners,
I
UNITED STATES OF AMERICA,
Respondent.
UNITED STATES' RESPONSE TO
PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT
The United States (hereinafter the "government") hereby responds to Jane Doe #1 and
Jane Doe #2's First Requestfor Admissions to the Government Regarding Questions Relevant to
Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for
Admissions"), and states as follows:'
I. The government admits that the FBI and the U.S. Attorney's Office for the Southern
District of Florida ("USAO") conducted an investigation into Jeffrey Epstein
("Epstein") and developed evidence and information in contemplation of a potential
federal prosecution against Epstein for many federal sex offenses. Except as
otherwise admitted above, the government denies Request No. I.
The government's response is confined to Request No. I through Request No. 26 in the
"Discovery Requested" section of the Request for Admissions and does not intend to respond to
assertions in any other section of the Request for Admissions (including the "Background"
section), none of which appear to separately state any matter calling for an admission.
Nonetheless, the government denies the assertion that the government has declined the request of
Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case.
EFTA00191199
2. (a) The government admits that, after Epstein's attorneys learned of the notification
that the government planned to provide to Jane Doe #2, who claimed that she was
not a victim, Epstein's attorneys contacted the USAO and objected to the
procedures for notification and the legal bases therefor. The government further
admits that the USAO considered those objections when evaluating what
notification to provide to victims. Except as otherwise admitted above, the
government denies Request No. 2(a).
(b) Admitted.
(c) The government admits that, as a result of objections lodged by Epstein's
attorneys, the government reevaluated the notifications that it had intended to
provide to victims and, as a result of that reevaluation, the USAO altered the
scope, nature, and timing of notifications that it had contemplated providing to
victims. With regard to Jane Doe #2, the government further admits that, as a
result of representations made by Jane Doe #2 that she was not a victim and
objections lodged by Epstein's attorneys, the USAO stopped making notifications
to Jane Doe #2. Except as otherwise admitted above, the government denies
Request No. 2(c).
(d) The government admits that, after the USAO received objections to victim
notifications from Epstein's counsel and reevaluated its victim notification
obligations, the USAO altered the language that was ultimately contained in the
July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards.
Except as otherwise admitted above, the government denies Request No. 2(d).
2
EFTA00191200
(e) The government admits that, at least in part as a result of objections lodged by
Epstein's lawyers to victim notifications, the USAO reevaluated its obligations to
provide notifications to victims, and Jane Doe #1 was thus not told that the USA(?)
had entered into a non-prosecution agreement with Epstein until after the
agreement was signed. The government further admits that Jane Doe #2 was not
told that the USAO had entered into a non-prosecution agreement with Epstein
until after the agreement was signed, but denies that the USA() did not inform
Jane Doe #2 as a result of any negotiations involving Epstein or any objections
lodged by Epstein's lawyers; the USAO did not consider Jane Doe #2 a victim
after she informed the USAO and the FBI that she was not a victim of any offense
committed by Epstein, and, as a result, the USAO did not consider informing Jane
Doe #2 about the non-prosecution agreement. Except as otherwise admitted
above, the government denies Request No. 2(e).
3. Denied.
4. Denied.
5. The government admits that, during the negotiations with Jeffrey Epstein regarding
the non-prosecution agreement, at least one experienced attorney within the USAO
subscribed to the position that the CVRA required notifications to the victims in this
case and that position was communicated to Epstein's counsel. To the extent that
Request No. 5 seeks admissions regarding the positions held by attorneys within the
USAO that were not communicated to non-government personnel regarding whether
or not the CVRA ultimately required notifications to the victims in this case, the
government objects to Request No. 5 as violative of the deliberative process privilege.
3
EFTA00191201
6. (a) Denied.
(b) Denied.
(c) Admitted.
(d) Admitted.
(e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer
to Lilly Ann Sanchez.
(0 Admitted.
(g) Admitted.
7. The government admits that, on about January 10, 2008, when Jane Doe # I and Jane
Doe #2 were sent letters advising them that "this case is currently under
investigation," the U.S. Attorney's Office had already signed a non-prosecution
agreement with Jeffrey Epstein, but that, on that date, the non-prosecution agreement
nonetheless remained in a state of some flux and was subject to being set aside as
Epstein was challenging the propriety of the non-prosecution agreement and seeking
further review from the Department of Justice.
8. Denied.
9. (a) The government admits that, at Epstein's insistence, the USAO agreed to a
provision in the non-prosecution agreement that provided as follows: "The parties
anticipate that this agreement will not be made part of any public record. If the
United States receives a freedom of Information Act request or any compulsory
process commanding the disclosure of the agreement, it will provide notice to
Epstein before making that disclosure." Except as otherwise admitted above, the
government denies Request No. 9(a).
4
EFTA00191202
(b) Admitted.
(c) Denied.
(d) Denied.
(e) The government admits that, during the period from September 24, 2007 through
June 2008, the USAO did not notify Jane Doe #2 of the existence of the non-
prosecution agreement. The government further admits that, although FBI agents
notified Jane Doe #1 of the existence and substance of the agreement at the
request of the USAO on or about October 27, 2007, no employee of the USAO
personally notified Jane Doe #1 of the existence of the non-prosecution agreement
during the period from September 24, 2007 through June 2008. Except as
otherwise admitted above, the government denies Request No. 9(c).
10. (a) Admitted. Because Request No. 10 appears directed solely to the communica-
tions between FBI agents and Jane Doe #1 during their meeting on or about
October 26, 2007, the government responses to Requests No. 10(b) through 10(g)
address only that meeting.
(b) The government admits that, on or about October 26, 2007, FBI agents explained
to Jane Doe #1 that Epstein would plead guilty to state charges for procuring
minors to engage in prostitution; that Epstein would be required to register as a
sex offender; that Jane Doe #1 would be entitled to seek damages from Epstein;
and that, if she desired, Jane Doc //I would be entitled to use the services of an
attorney at no expense to her in seeking those damages from Epstein. The
government denies that the FBI agents explained that the state charges
"involv[ed] another victim."
5
EFTA00191203
(c) The government denies that the FBI agents did not explain to Jane Doc #1 that an
agreement had already been signed; denies that the FBI agents did not explain to
Jane Doe #1 that the agreement resolved the investigation of the federal case
involving Jane Doe #1; and denies that the FBI agents did not explain to Jane Doe
other terms of that agreement Except as otherwise admitted above, the
government denies Request No. 10(c).
(d) Denied.
(e) Denied.
(f) Denied.
(g) Denied.
I I. The government admits that, on or about November 28, 2007, A. Marie Villafalia of
the USAO sent a draft of a crime victim notification letter to Jay Lefkowitz, counsel
for Jeffrey Epstein, and that the draft notification letter stated, in part: "I am writing
to inform you that the federal investigation of Jeffrey Epstein has been completed,
and Mr. Epstein and the U.S. Attorney's Office have reached an agreement
containing the following terms . . . ." The government further admits that, in part as a
result of objections lodged by Epstein's lawyers, the USAO reevaluated its
obligations to provide notifications to victims, and, as a result of that reevaluation and
other considerations and developments, the USAO never sent victims the draft
notification letter that was sent to Jay Lefkowitz on or about November 28, 2007.
Except as otherwise admitted above, the government denies Request No. I I.
12. The government admits that, prior to July 3, 2008, the USAO had already entered a
binding non-prosecution agreement with Jeffrey Epstein. The government is without
6
EFTA00191204
knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S.
Attorney's Office concerning the need to federally prosecute Epstein for sex offenses
committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government
denies the assertion that Edwards worked on that letter on July 3, 2008. Except as
otherwise admitted above, the government denies Request No. 12.
13. (a) The government admits that, when Epstein pled guilty to state charges on June 30,
2008, Jane Doe #2 had not been informed by the USAO of the existence of the
non-prosecution agreement. The government further admits that, although the
USAO, through FBI agents, had notified Jane Doe ill of the existence of the non-
prosecution agreement prior to Epstein's June 30, 2008 guilty plea, no employee
of the USAO had personally notified Jane Doe #1 at that time of the existence of
the non-prosecution agreement. Except as otherwise admitted above, the
government denies Request No. I3(a).
(b) The government denies that, by the time of Epstein's June 30, 2008 guilty plea, an
attorney for the government working at the USAO had not already conferred with
Jane Doe #1 and Jane Doe #2 about their opinions regarding how the federal
investigation and potential prosecution of Epstein should proceed. The
government admits that the USAO had not conferred with Jane Doe #2 about the
non-prosecution agreement prior to Epstein's June 30, 2008 guilty plea. The
government further admits that, although the USAO had communicated with Jane
Doe #1 about the non-prosecution agreement through FBI agents prior to
Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally
conferred with Jane Doe #1 about the non-prosecution agreement prior to
7
EFTA00191205
Epstein's guilty plea. Except as otherwise admitted above, the government denies
Request No. I3(b).
(c) Although the government was aware that Jane Doe #2 had been represented by
counsel paid for by Epstein, the government is unaware of the extent of Epstein's
defense attorneys' awareness of the USAO's communications with Jane Doe #1
and Jane Doe #2 about the agreement, as described in the responses to Requests
No. 13(a) and 13(b), and therefore can neither deny nor admit Request No. 13(c).
Except as otherwise admitted above and in the responses to Requests No. 13(a)
and 13(b), the government denies Request No. I3(c).
(d) The government admits that Epstein's attorneys negotiated with the USAO for a
provision in the non-prosecution agreement that ultimately provided as follows:
"The parties anticipate that this agreement will not be made part of any public
record. If the United States receives a Freedom of Information Act request or any
compulsory process commanding the disclosure of the agreement, it will provide
notice to Epstein before making that disclosure." Except as otherwise admitted
above, the government denies Request No. 13(d).
14. The government admits that, when Epstein was pleading guilty to the state charges
discussed in the non-prosecution agreement, the USAO and Epstein's defense
attorneys sought to keep the document memorializing the non-prosecution agreement
confidential, but denies that they sought at that time to keep the existence of the non-
prosecution agreement confidential. Except as otherwise admitted above, the
government denies Request No. 14.
8
EFTA00191206
IS. (a) The government admits that, while Bruce E. Reinhart was an Assistant U.S.
Attorney, he learned confidential, non-public information about the Epstein
matter.
(b) The government admits that, while Bruce E. Reinhart was an Assistant U.S.
Attorney, he discussed the Epstein matter with another Assistant U.S. Attorney
working on the Epstein matter.
(c) Denied.
16. Admitted.
17. Admitted.
18. (a) Denied.
(b) Denied.
19. To the extent that Request No. 19 is directed to the business or personal relationships
of the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys serving across this
country, or the countless individuals who have formerly served as U.S. Attorneys and
Assistant U.S. Attorneys throughout this nation, the government objects to Request
No. 19 as overly broad and burdensome and not calculated to lead to or involve
information relevant to the instant matter. The government denies possessing or
having any knowledge or information about a personal or business relationship
between Jeffrey Epstein and either the U.S. Attorney or any Assistant U.S. Attorney
serving in the Southern District of Florida. Except as otherwise admitted above, the
government denies Request No. 19.
20. Admitted.
21. Denied.
9
EFTA00191207
22. (a) Admitted.
(b) Admitted.
(c) Admitted.
23. The government admits that the non-prosecution agreement signed by the USAO and
Jeffrey Epstein currently blocks the USA() from prosecuting sex offenses committed
by Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida
from in or around 2001 through in or around September 2007, provided that those
offenses are set out on pages I and 2 of the non-prosecution agreement, were the
subject of the joint investigation by the FBI and the USAO, or arose from the federal
grand jury investigation. Except as otherwise admitted above, the government denies
Request No. 23.
24. Admitted; Jeffrey Epstein provided valuable consideration to the federal government
through the non-prosecution agreement he entered with the USAO.
25. Denied.
26. The government objects to Request No. 26 because it seeks information protected
from disclosure by the law enforcement investigative privilege.
/II
I0
EFTA00191208
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By: Is Dexter A. Lee
Dexter A. Lee
Assistant United States Attorney
Florida Bar No. 0936693
99 N.E. 4th Street
Miami, Florida 33132
Tel: (305) 961-9320; Fax: (305) 530-7139
Email: dexter.lee®usdoj.gov
A. Marie Villafana
Assistant United States Attorney
Florida Bar No. 0018255
500 S. Australian Avenue, Suite 400
West Palm Beach, FL 33401
Tel: (561) 820-8711; Fax: (561) 820-8777
Email: ann.marie.c.villafana®usdoj.gov
Eduardo I. Sanchez
Assistant United States Attorney
Florida Bar No. 877875
99 N.E. 4th Street
Miami, Florida 33132
Tel: (305) 961-9057; Fax: (305) 536-4676
Email: eduardo.i.sanchez@usdoj.gov
Attorneys for United States
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing United States' Response to
Petitioners' First Request for Admissions to the Government was served via CM/ECF on this
19th day of July, 2013, on the parties and counsel appearing on the attached service list.
/s Dexter A. Lee
Assistant United States Attorney
II
EFTA00191209
SERVICE LIST
Jane Does 1and 4 United States,
Case No. 08-80736-CIV-MARRA/MATTHEWMAN
United States District Court, Southern District of Florida
Brad Edwards, Esq., Roy Black, Esq.
Farmer, Jaffe, Weissing, Jackie Perczek, Esq.
Edwards, Fistos & Lehrman, P.L. Black, Srebnick, Kornspan & Stumpf, P.A.
425 North Andrews Avenue, Suite 2 201 South Biscayne Boulevard, Suite 1300
Fort Lauderdale, Florida 33301 Miami, FL 33131
(954)524-2820 (305) 371-6421
Fax: (954) 524-2822 Fax: (305)358-2006
E-mail: brad@pathtojustice.com E-mail: pleading@iroyblack.com
Paul G. Cassell Martin G. Weinberg
S.J. Quinney College of Law at the MARTIN G. WEINBERG, P.C.
University ofUtah 20 Park Plaza
332 S. 1400 E. Suite 1000
Salt Lake City, Utah 84112 Boston, MA 02116
(801) 585-5202 Office: (617) 227-3700
Fax: (801) 585-6833 Fax: (617) 338-9538
E-mail: casselp®law.utah.edu Email: owlmgw@attnet
Attorneys for Jane Doe # 1 and Jane Doe # 2
Jay P. Letkowitz
Kirkland &Ellis, LLP
601 Lexington Avenue
New York. NY 10022
Fax:
Email: lefkowitz@kirkland.com
12
EFTA00191210
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425 N AndreWs Ave Ste 2
Fort Lauderdale, FL 33301-3268
brad©pathtojustice.com
954-524-2820
Fax: 954-524-2822
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
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Fax: (801) 585-6833
E-mail: casselpialaw.utah.edu
t>") CA.)-recd
EFTA00191213
PRIVILEGE LOG
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "CORR RE GJ 6(e)
P-000001 SUBPOENAS" containing correspondence Work Product
thru related to various grand jury subpoenas and
P-000039 attorney (Villafada) handwritten notes
Box #1 Operation Leap Year Grand Jury Log 6(e)
P-000040 containing subpoenas OLY-01 through OLY-81, Work Product
thru correspondence and research related to Contains documents subject
P-000549 enforcement of same, documents produced in to investigative privilege
response to some subpoenas; and attorney Also contains documents
(Villafafla) handwritten notes subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies of a sealed search warrant Contains information subject
thru application, warrant, and supporting documents to investigative privilege
P-000621 Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "PNY Technologies Compact 6(e)
P-000622 Flash SW" containing copies of a sealed search Contains information subject
thru warrant application, warrant, and supporting to investigative privilege
P-000693 documents Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "JE Corporations" containing Work Product
P-000694 attorney research on Epstein-owned corporations Contains information subject
thru and prior litigation to investigative privilege
P-000781
Box #1 File folder entitled "Capital One" 6(e)
P-000782 containing subpoena and correspondence
thru
P-000803
Box #1 File folder entitled "DTG Operations/Dollar 6(e)
P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and
thru documents information subject to
P-000854 investigative privilege
Also contains documents and
information subject to privacy
rights of victims who are not
parties to this litigation
Page 1 of 23
EFTA00191214
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "JP Morgan Chase" 6(e)
P-000855 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000937 investigative privilege
Box #1 File folder entitled "Washington Mutual" 6(e)
P-000938 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000947 investigative privilege
Box #1 File folder entitled "Computer Search &" Work Product
P-000948 containing legal research on computer search and Attorney-Client
thru handwritten notes on indictment preparation Contains information subject
P-000982 to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Attorney Notes from Work product
P-000983 Document Review" containing typed and 6(e)
thru handwritten attorney (Villafada) notes, target Contains information subject
P-001007 letters, correspondence re grand jury subpoena to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Notes from Fed Ex Records" Work Product
P-001008 containing handwritten and typed attorney 6(e)
thru (Villafafia) notes and screen shots of FedEx Contains information subject
P-001056 subpoena response electronic file to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Colonial Bank Records" 6(e)
P-001057 containing records received in response to grand Contains information subject
thru jury subpoena to investigative privilege
P-001959
Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e)
P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject
Thru numbered OLY-51 through OLY-81 with related to investigative privilege.
P-002089 correspondence Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Page 2 of 23
EFTA00191215
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Epstein Corporate Records: 6(e)
P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and
Thru subpoenas, records received in response to documents subject to
P-002169 subpoenas, and related correspondence investigative privilege
Box #1 File folder entitled "Colonial Bank" containing 6(e)
P-002170 subpoenas, correspondence related to subpoenas, Contains information and
Thru records received in response to subpoenas documents subject to
P-002246 investigative privilege
Box #1 File folder entitled "JEGE & Hyperion from 6(e)
P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and
Thru documents received in response to subpoenas documents subject to
P-002265 investigative privilege
Box #1 Indictment preparation binder containing: Work product
P-002266 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002386 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, of individuals listed as contains information and
"Additional victims" documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Indictment preparation binder containing: Work product
P-002387 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P402769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #15, 16, 17, 18,
19, Past Employees, Misc. Witnesses
Box #1 Indictment preparation binder containing: Work product
P-002770 witness/victim list with identifying information, 6(e)
Thrti sexual activity summary, telephone call summary Contains information and
P-00321 I chart, attorney (Villafafia) handwritten notes, documents subject to
302s, portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
8
Page 3 of 23
EFTA00191216
Bates Range Description Privilege(s) Asserted
Box #1 Indictment preparation binder containing meta- Work product
P-003212 analysis charts of telephone/flight/grand jury 6(e)
Thru information for a number of victim/witnesses, Contains information and
P-003545 Nadia Marcinkova, and Adriana Mucinska documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 FBI Reports of March 2008 interviews of Work product
P-003546 additional witness/victim located in New York 6(e) .
Thru Contains information and
P-003552 documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box 141 Printout of filenames from Federal Express Work product
P-003553 subpoena response with Attorney notations 6(e)
Thru
P-003555B
Box #1 Document entitled "Identified Numbers" with Work product
P-003556 accompanying handwritten attorney list compiled 6(e)
Thru from grand jury materials and attorney analysis of Contains information subject
P-003562 records to investigative privilege
Box #1 Folder entitled "Flight Manifests" containing 6(e)
P-003563 manifests received pursuant to grand jury Contains information and
Thru subpoena documents subject to
P-003629 investigative privilege
Box #1 File folder entitled "Recent Attorney Notes" Work product
P-003630 containing handwritten attorney (Villafada) notes 6(e)
Thru regarding document review and case strategy Investigative privilege
P-003633 Deliberative process
Box #1 File folder bearing victim name containing FBI Work product
P-003634 interview report from May 2008, telephone Attorney-client privilege
Thru activity report with attorney (Villafanana) 6(e)
P-003646 handwritten notes, related grand jury material Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 4 of 23
EFTA00191217
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Summary of Sexual Activity" Work product
P-003647 containing chart bearing handwritten title "Sexual 6(e)
Thru Activity — Summary" with meta-analysis of Investigative privilege
P-003651 information, sorted by name of each Deliberative process
victim/witness, including name and identifying Also contains information and
information of each victim/witness documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Victim Civil Suits" Not privileged.
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research re JE Websites" Work product
P-003664 containing attorney research
Thru
P-003678
Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product
P-003679 containing attorney (Villafafla) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. Anna Salter" containing Work product
P-003681 attorney (Villafafia) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 la
File folder entitled GO Interview" containing Work product
P-003688 attorney handwritten notes of interview, and Investigative privilege
Thru attorney handwritten notes regarding potential Also contains information
P-003693 charges subject to privacy rights of
victims who are not parties to
this litigation
Box #I File folder entitled "Research re Travel for Work product
P-003694 Prostitution" containing attorney (Villafafia) 6(e)
Thru handwritten notes regarding grand jury Investigative privilege
P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and
House" with handwritten notes, Message Pad documents subject to privacy
meta-analysis chart, summary of evidence related rights of victims who are not
to one victim/witness, and relevant grand jury parties to this litigation
information
Box #1 Empty file folder bearing name of victim/witness Investigative privilege
P-003712 Also contains information
subject to privacy rights of
victim who is not a party to
this litigation
Page 5 of 23
EFTA00191218
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "T(] M(]" containing grand 6(e)
P-003713 jury subpoenas, motion and order to compel Documents under seal
Thru testimony, and correspondence regarding same pursuant to court order
P-003746
Box #1 File folder entitled "Adrian Ross" containing 6(e)
P-003747 subpoena and correspondence regarding same
Thru
P-003751
Box #1 File folder entitled "PBPD Investigative File" 6(e)
P-003752 obtained via subpoena Investigative privilege
Thru Also contains information and
P-004295 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 of
File folder bearing name victim/witness Work product
P-004296 containing meta-analysis chart showing telephone 6(e)
Thru calls, travel, and grand jury materials relevant to Investigative privilege
P-004350 possible charges Also contains information and
documents subject to privacy
rights of victims who are not
parties to this liti tion
Box #1 File folder entitled "Daniel Documents Work product
P-004351 53909-004" containing attorney research related
Thru to bias issue
P-004381
Box #1 File Folder entitled "FEDEX" containing 6(e)
P-004382 documents obtained via subpoena Investigative privilege
Thru
P-004478
Box #1 File Folder entitled "State of Delaware Records" 6(e)
P-004479 containing documents obtained in preparation for Investigative privilege
Thru indictment Work product
P-004551
Box #1 File folder entitled "Jet Blue Records" containing 6(e)
P-004552 documents obtained via subpoena Work product
Thru Investigative privilege
P-004555 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege
P-004556 RECORDS" containing FDLE records on targets Work product
Thru
DataSet-10
Unknown
25 pages
Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Matthewman
JANE DOES #1 AND #2,
Petitioners,
I
UNITED STATES OF AMERICA,
Respondent,
UNITED STATES' NOTICE OF FILING PRIVILEGE LOG
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
States of America, by and through the undersigned Assistant United States Attorney, hereby gives
notice of its filing of its Privilege Log, which is attached hereto.
The documents referenced in the Privilege Log are being delivered today to the Chambers
of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's
Omnibus Order.
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By: s/A. Marie Villa/aim
A. MARIE VILLAFANA
Assistant United States Attorney
Florida Bar No. 0018255
500 South Australian Ave, Suite 400
West Palm Beach, FL 33401
Telephone: 561-820-8711
Facsimile: 561-820-8777
ann.marie.c.villafana@usdoj.gov
EFTA00211385
Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 19, 2013, I electronically filed the foregoing document
with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties
are able to receive notice via the CM/ECF system.
s/A. Marie Villafaiia
A. MARIE VILLAFAIZIA
Assistant United States Attorney
SERVICE LIST
Jane Does 1 and 2 v. United States,
Case No. 08-80736-CIV-MARRA/MATTHEWMAN
United States District Court, Southern District of Florida
Brad Edwards, Esq.,
Farmer Jaffe Weissing Edwards Fistos Lehrman
425 N Andrews Ave Ste 2
Fort Lauderdale, FL 33301-3268
brad@pathtojustice.com
954-524-2820
Fax: 954-524-2822
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
332 S. 1400 E.
Salt Lake City, Utah 84112
(801) 585-5202
Fax: (801) 585-6833
E-mail: casselp@law.utah.edu
Attorneys for Jane Doe # 1 and Jane Doe # 2
2
EFTA00211386
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23
PRIVILEGE LOG
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "CORR RE GJ 6(e)
P-000001 SUBPOENAS" containing correspondence Work Product
thru related to various grand jury subpoenas and
P-000039 attorney (Villafafia) handwritten notes
Box #1 Operation Leap Year Grand Jury Log 6(e)
P-000040 containing subpoenas OLY-01 through OLY-81, Work Product
thru correspondence and research related to Contains documents subject
P-000549 enforcement of same, documents produced in to investigative privilege
response to some subpoenas; and attorney Also contains documents
(Villafafia) handwritten notes subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies of a sealed search warrant Contains information subject
thru application, warrant, and supporting documents to investigative privilege
P-000621 Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "PNY Technologies Compact 6(e)
P-000622 Flash SW" containing copies of a sealed search Contains information subject
thru warrant application, warrant, and supporting to investigative privilege
P-000693 documents Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "JE Corporations" containing Work Product
P-000694 attorney research on Epstein-owned corporations Contains information subject
thru and prior litigation to investigative privilege
P-000781
Box #1 File folder entitled "Capital One" 6(e)
P-000782 containing subpoena and correspondence
thru
P-000803
Box #1 File folder entitled "DTG Operations/Dollar 6(e)
P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and
thru documents information subject to
P-000854 investigative privilege
Also contains documents and
information subject to privacy
rights of victims who are not
parties to this litigation
Page 1 of 23
EFTA00211387
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 2 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "JP Morgan Chase" 6(e)
P-000855 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000937 investigative privilege
Box #1 File folder entitled "Washington Mutual" 6(e)
P-000938 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000947 investigative privilege
Box #1 File folder entitled "Computer Search &" Work Product
P-000948 containing legal research on computer search and Attorney-Client
thru handwritten notes on indictment preparation Contains information subject
P-000982 to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Attorney Notes from Work product
P-000983 Document Review" containing typed and 6(e)
thru handwritten attorney (Villafafia) notes, target Contains information subject
P-001007 letters, correspondence re grand jury subpoena to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Notes from Fed Ex Records" Work Product
P-001008 containing handwritten and typed attorney 6(e)
thru (Villafafia) notes and screen shots of FedEx Contains information subject
P-001056 subpoena response electronic file to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Colonial Bank Records" 6(e)
P-001057 containing records received in response to grand Contains information subject
thru jury subpoena to investigative privilege
P-001959
Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e)
P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject
Thru numbered OLY-51 through OLY-81 with related to investigative privilege.
P-002089 correspondence Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Page 2 of 23
EFTA00211388
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Epstein Corporate Records: 6(e)
P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and
Thru subpoenas, records received in response to documents subject to
P-002169 subpoenas, and related correspondence investigative privilege
Box #1 File folder entitled "Colonial Bank" containing 6(e)
P-002170 subpoenas, correspondence related to subpoenas, Contains information and
Thru records received in response to subpoenas documents subject to
P-002246 investigative privilege
Box #1 File folder entitled "JEGE & Hyperion from 6(e)
P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and
Thru documents received in response to subpoenas documents subject to
P-002265 investigative privilege
Box #1 Indictment preparation binder containing: Work product
P-002266 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002386 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, of individuals listed as contains information and
"Additional victims" documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Indictment preparation binder containing: Work product
P-002387 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #15, 16, 17, 18,
19, Past Employees, Misc. Witnesses
Box #1 Indictment preparation binder containing: Work product
P-002770 witness/victim list with identifying information, 6(e)
Thru sexual activity summary, telephone call summary Contains information and
P-003211 chart, attorney (Villafafia) handwritten notes, documents subject to
302s, portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
8
Page 3 of 23
EFTA00211389
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23
Bates Range Description Privilege(s) Asserted
Box #1 Indictment preparation binder containing meta- Work product
P-003212 analysis charts of telephone/flight/grand jury 6(e)
Thru information for a number of victim/witnesses, Contains information and
P-003545 -• and documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 FBI Reports of March 2008 interviews of Work product
P-003546 additional witness/victim located in New York 6(e)
Thru Contains information and
P-003552 documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Printout of filenames from Federal Express Work product
P-003553 subpoena response with Attorney notations 6(e)
Thru
P-003555B
Box #1 Document entitled "Identified Numbers" with Work product
P-003556 accompanying handwritten attorney list compiled 6(e)
Thru from grand jury materials and attorney analysis of Contains information subject
P-003562 records to investigative privilege
Box #1 Folder entitled "Flight Manifests" containing 6(e)
P-003563 manifests received pursuant to grand jury Contains information and
Thru subpoena documents subject to
P-003629 investigative privilege
Box #1 File folder entitled "Recent Attorney Notes" Work product
P-003630 containing handwritten attorney (Villafafia) notes 6(e)
Thru regarding document review and case strategy Investigative privilege
P-003633 Deliberative process
Box #1 File folder bearing victim name containing FBI Work product
P-003634 interview report from May 2008, telephone Attorney-client privilege
Thru activity report with attorney (Villafanafia) 6(e)
P-003646 handwritten notes, related grand jury material Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 4 of 23
EFTA00211390
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Summary of Sexual Activity" Work product
P-003647 containing chart bearing handwritten title "Sexual 6(e)
Thru Activity — Summary" with meta-analysis of Investigative privilege
P-003651 information, sorted by name of each Deliberative process
victim/witness, including name and identifying Also contains information and
information of each victim/witness documents subject to privacy
rights of victims who are not
arties to this liti ation
Box #1 File folder entitled "Victim Civil Suits" Not privileged.
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research re JE Websites" Work product
P-003664 containing attorney research
Thru
P-003678
Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product
P-003679 containing attorney (Villafafia) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. Anna Salter" containing Work product
P-003681 attorney (Villafafia) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 File folder entitled "I[] G[] Interview" containing Work product
P-003688 attorney handwritten notes of interview, and Investigative privilege
Thru attorney handwritten notes regarding potential Also contains information
P-003693 charges subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Research re Travel for Work product
P-003694 Prostitution" containing attorney (Villafafia) 6(e)
Thru handwritten notes regarding grand jury Investigative privilege
P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and
House" with handwritten notes, Message Pad documents subject to privacy
meta-analysis chart, summary of evidence related rights of victims who are not
to one victim/witness, and relevant grand jury parties to this litigation
information
Box #1 Empty file folder bearing name of victim/witness Investigative privilege
P-003712 Also contains information
subject to privacy rights of
victim who is not a party to
this liti ation
Page 5 of 23
EFTA00211391
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "T[] M[]" containing grand 6(e)
P-003713 jury subpoenas, motion and order to compel Documents under seal
Thru testimony, and correspondence regarding same pursuant to court order
P-003746
Box #1 File folder entitled' M'' containing 6(e)
P-003747 subpoena and correspondence regarding same
Thru
P-003751
Box #1 File folder entitled "PBPD Investigative File" 6(e)
P-003752 obtained via subpoena Investigative privilege
Thru Also contains information and
P-004295 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work product
P-004296 containing meta-analysis chart showing telephone 6(e)
Thru calls, travel, and grand jury materials relevant to Investigative privilege
P-004350 possible charges Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Daniel Gonzalez Documents Work product
P-004351 53909-004" containing attorney research related
Thru to bias issue
P-004381
Box #1 File Folder entitled "FEDEX" containing 6(e)
P-004382 documents obtained via subpoena Investigative privilege
Thru
P-004478
Box #1 File Folder entitled "State of Delaware Records" 6(e)
P-004479 containing documents obtained in preparation for Investigative privilege
Thru indictment Work product
P-004551
Box #1 File folder entitled "Jet Blue Records" containing 6(e)
P-004552 documents obtained via subpoena Work product
Thru Investigative privilege
P-004555 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege
P-004556 RECORDS" containing FDLE records on targets Work product
Thru and witnesses obtained at attorney request
P-004560
Page 6 of 23
EFTA00211392
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23
Bates Range Description Privilege(s) Asserted
Box #1 Filed folder entitled "JANUSZ BANASIAK" Work product
P-004561 containing attorney (Villafafia) handwritten notes Investigative privilege
Thru of interview
P-004565
Box #1 File folder entitled "JANUSZ BANASIAK 6(e)
P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product
Thru documents obtained via subpoena Investigative privilege
P-004716 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "IGOR ZINOVIEV" Work product
P-004717 containing attorney research regarding witness Investigative privilege
Thru
P-004722
Box #1 File folder entitled "BEAR STEARNS Work Product
P-004723 RESEARCH" containing attorney research Investigative privilege
Thru regarding potential witness and subpoena
P-004725 recipient
Box #1 File folder entitled "LAWSUITS INVOLVING Work Product
P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege
Thru regarding Epstein's past personal and business
P-004819 litigative practices
Box #1 Filed folder entitled "SEC RECORDS" Work Product
P-004820 containing attorney research regarding Epstein Investigative privilege
Thru financial relationships
P-004959
Box #1 File folder entitled "Message Pads" containing Work Product
P-004960 selected items from evidence obtained via 6(e)
Thru subpoena Investigative privilege
P-005059 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work Product
P-005060 containing correspondence with counsel for 6(e)
Thru victim/witness, attorney witness outline with Investigative privilege
P-005081 attorney handwritten notes, attorney handwritten Also contains information and
notes regarding witness reports and case documents subject to privacy
preparation rights of victims who are not
parties to this litigation
Box #1 File folder entitled "New York Trip" containing Work product
P-005082 attorney notes re witness interview Investigative privilege
Thru
P-005083
Page 7 of 23
EFTA00211393
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23
Bates Range Description Privilege(s) Asserted
P-005084 thru P-005107 are non responsive
documents and have been removed
Box #1 File folder entitled "ANNA SALTER" containing Work product
P-005108 attorney research on select expert, use of experts Investigative privilege
Thru at trials in child exploitation cases, and additional
P-005193 research materials on offenders and victims
Box #1 File folder entitled "Extra Copies" containing Work product
P-005194 meta-analysis chart and 302's of victim/witnesses 6(e)
Thru used in preparing indictment package Investigative privilege
P-005300 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "JUAN ALESSI 6(e)
P-005301 STATEMENT' containing transcript obtained via Investigative privilege
Thru subpoena
P-005331
Box #1 File folder entitled "KEN LANNING" containing Work product
P-005332 attorney research on select expert, including Investigative privilege
Thru attorney handwritten notes
P-005341
Box #1 File folder entitled "Info re Planes" containing 6(e)
P-005342 correspondence regarding subpoenas and Investigative privilege
Thru documents received in response to subpoenas
P-005387
Box #1 File folder entitled "Police Reports & PC Work product
P-005388 Affidavit" containing portions of police reports 6(e)
Thru with attorney notes, related phone records, a list Investigative privilege
P-005442 entitled "Victims" with identifying information Also contains information and
and attorney handwritten notes, photographs and documents subject to privacy
DAVID information, and additional attorney rights of victims who are not
research regarding Epstein sexual activity parties to this litigation
Box #1 File folder entitled "[Victim name] Transcript of 6(e)
P-005443 Interview & GJ Transcript" Investigative privilege
Thru Also contains information and
P-005496 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Bear Stearns Subpoena 6(e)
P-005497 Resp." containing material received in response Investigative privilege
Thru to subpoena
P-005556
Page 8 of 23
EFTA00211394
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23
Bates Range Description Privilege(s) Asserted
Box #1 U.S. Attorney's Office Criminal Case File Jacket Work product
P-005557 containing file opening documents, expert Deliberative process
Thru witness payment documents
P-005576
Box #1 U.S. Attorney's Office Asset Forfeiture Case File Work product
P-005578 Jacket containing file opening and file closing Deliberative process
Thru documents
P-005583
Box #1 File folder entitled "6001 Immunity Request" 6(e)
P-005584 containing internal memoranda seeking witness Work product and
Thru immunity and correspondence with counsel for deliberative process (as to
P-005606 witness regarding same internal memoranda)
Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "MASTER PHONE Work product
P-005607 RECORDS" containing meta-analysis of all 6(e)
Thru phone, travel, and grand jury data for all Investigative privilege
P-005914 victim/witnesses for indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-005915 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-005977 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-005978 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-006050 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-006051 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-006065 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 9 of 23
EFTA00211395
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 10 of
23
Bates Range Description Privilege(s) Asserted
Box #2 File folder entitled "JANE DOE #4" containing Work product
P-006066 meta-analysis of all phone, travel, and grand jury 6(e)
Thru data related to that victim/witness for indictment Investigative privilege
P-006220 preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled 'JANE DOE #12" containing Work product
P-006221 meta-analysis of all phone, travel, and grand jury 6(e)
Thru data related to that victim/witness for indictment Investigative privilege
P-006222 preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "CORRECTED PHONE Work product
P-006223 RECORDS 5/31/07" containing meta-analysis of 6(e)
Thru all phone, travel, and grand jury data related to all Investigative privilege
P-006522 victims/witnesses for indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "[Victim Name] Phone Work product
P-006523 Records" containing telephone records received 6(e)
Thru in response to subpoena Investigative privilege
P-006802 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "Lists of Identified Phone Work product
P-006803 Numbers" containing charts of information culled 6(e)
Thru from grand jury materials, interviews, and other Investigative privilege
P-006860 investigation, with attorney handwritten notes, Also contains information and
and information to issue follow-up grand jury documents subject to privacy
subpoena rights of victims who are not
arties to this liti ation
Box #2 File folder entitled' CELL Work product
P-006861 PHONE RECORDS" containing documents 6(e)
Thru received via subpoena with attorney handwritten Investigative privilege
P-007785 notes and highlighting Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 10 of 23
EFTA00211396
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 11 of
23
Bates Range Description Privilege(s) Asserted
Box #2 Folder entitled "OLY GRAND JURY LOG: Work product
P-007786 OLY-01 THROUGH OLY-50" containing 6(e)
Thru subpoenas, correspondence regarding same, 6(e) Investigative privilege
P-008120 letters, attorney handwritten notes regarding Also contains information and
records received in response to subpoenas documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 Handwritten flight logs received in response to 6(e)
P-008121 subpoena Investigative privilege
Thru
P-008139
Box #2 Grand jury presentation folder containing Work product
P-008140 attorney handwritten notes, typed outline with 6(e)
Thru additional handwritten notes, complete indictment Investigative privilege
P-008298 package dated 2/19/2008, victim list with Also contains information and
identifying information, photographs, and documents subject to privacy
summary of activity rights of victims who are not
parties to this litigation
Box #2 File folder entitled "FINAL AGREEMENTS"
P-008299 containing subfolder entitled "Agrmts Filed in
Thru State Court" (P-008300-P-008327 [not being
P-008363 withheld as privileged — have been produced to
opposing counsel]); signed Non-Prosecution
Agreement, Addendum, and operative portion of
12/19/2007 Sanchez-Acosta letter (P-008328-P-
008343 [not being withheld as privileged — have
been produced to opposing counsel]); subfolder
entitled "12/19/07 Acosta-Sanchez Ltr"
containing unredacted copies of that letter (P-
008344-P-008363 [pursuant to Court's Order, not
being withheld as privileged — will be produced
to opposing counsel upon lift of stay by 11th
Circuit])
Box #2 File folder entitled "Lacerda Immunity Request" 6(e)
P-008364 containing internal memoranda, Justice Work Product
Thru Department documentation, and subpoena Deliberative Process
P-008382 regarding immunity request Investigative privilege
Box #2 File folder containing March 18, 2008 grand jury Work product
P-008383 presentation materials, including "Operation Leap 6(e)
Thru Year Revised Indictment Summary Chart (by Investigative privilege
P-008516 victim)," grand jury materials, draft indictments, Deliberative process
victim reference list, grand jury subpoena log Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 11 of 23
EFTA00211397
Case 9:08-cv-80736-KAM Document 212
DataSet-10
Unknown
65 pages
1 UNITED STATES DISTRICT COURT
2 SOUTHERN DISTRICT OF FLORIDA
3
4
5
6
UNITED STATES OF AMERICA,
Plaintiff, COPY
7 vs.
8 JEFFREY EPSTEIN, SARAH KELLEN,
ADRIANA ROSS, a/k/a Adriana Mucinska,
9 and NADIA MARCINKOVA,
10 Defendants.
11
12
13 TESTIMONY
14 OF
15 SPECIAL AGENT
16
17
18 Federal Grand Jury 07-103
Federal Building
19 U.S. Courthouse
West Palm Beach, Florida
20 Tuesday, March 18, 2008
21
22 APPEARANCES:
23
Assistant United States Attorney
24
25 Foreperson
OFFICIAL REPORTING SERVICE, LLC
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/
1 The sworn testimony of SPECIAL AGENT
2 I. was taken before the
3 Federal Grand Jury, West Palm Beach Division,
4 Federal Building, U.S. Courthouse, Palm Beach
5 County, State of Florida, on Tuesday, March 18,
6 2008.
7 , Certified Court
8 Reporter and Notary Public, State of Florida,
9 Official Reporting Service, LLC, 524 South Andrews
10 Avenue, Suite 302N, Fort Lauderdale, Florida,
11 33301 , was authorized to and did report the sworn
12 testimony.
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 (Witness enters the Grand Jury Room.)
2 THE FOREPERSON: You do solemnly swear
3 that the testimony you give will be the
4 truth, the whole truth, and nothing but the
5 truth, so help you God?
6 THE WITNESS: I do.
7 THE FOREPERSON: Thank you. Please be
8 seated.
9 EXAMINATION
10 BY
11 Q Good afternoon, Special Agent
12 Would you just remind the grand jury
13 of your name and for whom you work?
14 A I am My official name is
15 and I work for the FBI here
16 in West Palm Beach.
17 Q All right. And you are still one of the
18 case agents on Operation Leap Year?
19 A Yes, I am.
20 Q Have additional subpoenas been issued on
21 behalf of this grand jury regarding Leap Year?
22 A Yes, they have.
23 Q And have documents been received in
24 response to those subpoenas?
25 A Yes, they have.
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1 Q What subpoenas were issued and what
2 items were received?
3 A The items that are received are in this
4 box for your review at a later time, but starting
5 with the first subpoena that we had received
6 documents back for would be from American Express.
7 The subpoena was issued and we received
8 credit card account information.
9 Q Okay.
10 A Do you want me just to --
11 Q You can just go through them.
12 A A subpoena was issued to J. Epstein
13 Virgin Island Foundation, Inc., J. Epstein and
14 Company, Epstein Interests, Financial Trust
15 Company, Inc., and we received documents on all
16 three of those except for -- all four of those
17 except for Jeffrey Epstein and Company --
18 J. Epstein and Company, which we received a letter
19 of no response.
20 The next subpoena was issued to the Palm
21 Beach County School Board and we received
22 transcript request forms. The next grand jury
23 subpoena was issued to Dan Tishler, Airport
24 Executive, Town Car Services. We received a
25 verbal that there were no records from Mr.
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1 Tishler.
2 We issued a grand jury subpoena to the
3 custodian of records for Majestic Theater, which
4 we received ticketing records for.
5 We issued a grand jury subpoena or you
6 issued a grand jury subpoena for the custodian of
7 records at the Broward Center for the Performing
8 Arts and we received ticketing records.
9 We issued a subpoena for the custodian
10 of records for the Kravis Center for the
11 Performing Arts and received a letter of no
12 records response.
13 We issued a subpoena for the custodian
14 of records for Live Nation Theatrical Broadway
15 Across America. Again, received a response letter
16 of no records.
17 We issued another subpoena for the
18 custodian of records from Live Nation Theatrical
19 Broadway Across America and that we did receive
20 some ticketing records.
21 We issued a subpoena to Bear Sterns and
22 Company, Inc., and we received personnel files and
23 account information. We issued a grand jury
24 subpoena for Wolf Camera and we received
25 transaction records.
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1 We have issued a grand jury subpoena to
2 Amazon.com and received order records. We issued
3 a grand jury subpoena to Federal Express and
4 received shipping records, and all that is
5 contained in this box.
6 Q All right.
7 And at the end of our
8 preservation, you will be welcome to look
9 through any of those records and we also will
10 bring them to the next session.
11 A GRAND JUROR: I have a question.
12 Yes.
13 A GRAND JUROR: We subpoenaed
14 information from theaters. I heard you say
15 ticketing information or records from a few
16 of them.
17 Did we subpoena that information to
18 establish location of the defendant or I
19 guess he's not a defendant yet?
20 THE WITNESS: Just as corroborating
21 evidence of testimony provided by the girls.
22 Their statements provided to us.
23 A GRAND JUROR: Okay.
24 BY
25 Q Okay. Special Agent , each
OFFICIAL REPORTING SERVICE, LLC
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1 member of the grand jury has before them a copy of
2 a chart. Do you also have a copy of this chart
3 entitled Revised Indictment Summary Chart
4 (by victim)?
5 A Yes.
6 Q And then you also provided to everyone a
7 list of Jane Does with photographs?
8 A Yes, I did.
9 Q Okay. Can you just explain to the grand
10 jury how -- which Jane Does we are going to be
11 talking about today?
12 A We are going to talk about Jane Does One
13 through Six and Nine and Ten, and what you have
14 here is a Jane Doe list of One through 19. We
15 will be going through the first Six and Nine and
16 Ten.
17 As you can see, if you look at these two
18 columns you'll see in the indictment we have
19 before you is going to have the new Jane Doe
20 numbers and the column to the right of that shows
21 you what their Jane Doe number used to be.
22 So Jane Does Nine and Ten, when we spoke
23 about those two before, and we will go through
24 that a little bit later, we referred to those as
25 Jane Does Six and Seven. From here on out, we
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1 will refer to them as Jane Does Nine and Ten.
2 A GRAND JUROR: I have a question about
3 Jane Doe Number One, and Amy pointed this
4 out. The date of birth is August 1983. The
5 range of activity dates is 1988 to 2003?
6 THE WITNESS: That's a typo. That
7 should be 1998.
8 Thank you for catching
9 that.
10 A GRAND JUROR: I was about ready to
11 have a problem here. I was having a real
12 problem. Yeah.
13 Okay. Thank you.
14 A GRAND JUROR: I was about to take the
15 law into my own hands.
16 THE WITNESS: Let there be noted on the
17 summary chart, there is a typo correction for
18 Jane Doe Number One. The range of activity
19 for her is 1998 to 2003.
20 This chart is a chart that we put
21 together because I have testified in the past
22 as well as you may have heard other testimony
23 regarding some of the Jane Does, and we are
24 going to be talking about them today and in a
25 later session.
OFFICIAL REPORTING SERVICE, LLC
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1 We want -- we provided this to you sort
2 of as an aid so that you can go back and
3 access the grand jury transcripts and go to
4 the date that the testimony was provided.
5 If you look at the last column where it
6 says, Grand Jury Transcript Pages, on this
7 form it will tell you the date of the grand
8 jury, who provided that testimony, and the
9 page number where you can find testimony
10 related to those specific Overt Acts and
11 substantive counts.
12 So the two columns next to that -- let's
13 just take Jane Doe Number Two and run through
14 that real quick. Jane Doe Number Two, we
15 have not testified about before. So that is
16 her number and will always remain her number.
17 Her date of birth is January of 1987.
18 The range of activity and that reflects the
19 range of activity that we have her connected
20 to Mr. Epstein and his assistants.
21 The next two columns are the Overt Acts
22 and the associated substantive counts. The
23 Overt Acts support those substantive counts
24 and again the last column you would at that
25 point go to my testimony on May 8th, 2007,
OFFICIAL REPORTING SERVICE, LLC
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1 and look on the transcript on Pages Six and
2 Seven, and that would be my testimony for the
3 Overt Acts, the supporting evidence and
4 testimony for Overt Acts One
5 through 18.
6 BY
7 Q But, Special Agent just so
8 that it is clear, when you testified back in May,
9 you weren't testifying specifically about Jane Doe
10 Number Two, but her name came up in with
11 respect to one of the other Jane Does?
12 A Exactly.
13 Q Okay. So any information related to
14 those Jane Does would be in the transcript pages?
15 A Yes.
16 Does that make sense to
17 everyone how we have organized that?
18 BY
19 Q Now Special Agent , if you
20 could look at the proposed indictment, and I'm
21 looking at the Background section of the
22 indictment specifically Paragraphs One through
23 Nine, which deal with Mr. Epstein's background and
24 who he employed.
25 Have you testified about that material.
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1 in the past?
2 A Yes, I have.
3 Q And let me just direct you to Overt Two,
4 which is at the top of Page Two. There is a
5 reference to L.G., and I don't believe we have
6 talked about L.G. before.
7 Can you tell the grand jury who that is?
8 A L.G. is Lesley Groff and she is a
9 personal assistant or an assistant for Mr. Epstein
10 in his New York office.
11 Q All right. And just for the court
12 reporter, Lesley is L-I-S-L-M-Y, and Groff is
13 G-R -O-F-F; is that correct?
14 A Yes, it is.
15 Q Then Paragraph Three talks about three
16 individuals, ., and . Can you tell
17 the grand jury who those persons are?
18 A is Tatum Miller. . is
19 is Anthony Figueroa.
20 Q And if you look at the summary chart on
21 the second page, there are columns for . and
22 Do you see those at the bottom of Page Two?
23 A Yes, I see them.
24 Q And those refer to Tatum Miller and
25 Anthony Figueroa where you have testified about
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1 them before or where III. was who
2 testified about them?
3 A Yes.
4 Q I know that you have testified about
5 Mr. Epstein's residence here in Palm Beach, but if
6 you could look at Paragraph Five of that
7 introductory section, which is on Page Two.
8 Are you -- can you provide the grand
9 jury with the location of Mr. Epstein's New York
10 residence?
11 A Mr. Epstein currently has a property
12 located at 9 East 71st Street, New York, New York.
13 Q If I could direct you to Page Five of
14 the proposed indictment in Paragraphs 18 through
15 25 of the introductory section.
16 Can you tell the grand jury about where
17 the various victims in this case attended high
18 school?
19 A I can. Starting with Paragraph 18.
20 Would you like me to just run through them?
21 Q Sure.
22 A Jane Doe Number Four attended Wellington
23 High School and Palm Beach Central High School.
24 Jane Doe Number Five attended Wellington High
25 School. Jane Doe Numbers Six, Eight, and 12,
OFFICIAL REPORTING SERVICE, LLC
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13
1 attended Palm Beach Central High School.
2 I should state that all of these high
3 schools are located in Palm Beach County. Jane
4 Doe Number Seven attended William T. Dwyer High
5 School in Palm Beach County.
6 Jane Doe Numbers Nine, 14, 15, 16, 17,
7 18, and 19 attended Royal Palm Beach High School
8 in Palm Beach County. Jane Doe Number Ten
9 attended Lake Worth High School in Palm Beach
10 County.
11 Jane Doe Number 11 attended the
12 Professional Performing Arts School, a public high
13 school located in the New York area; New York, New
14 York. Jane Doe Number 13 attended John I. Leonard
15 High School in Palm Beach County, and the Jane
16 Does attended these high schools during some point
17 of the contact with Mr. Epstein.
18 Q Now Special Agent , I know
19 that not each and everyone of the Jane Does is
20 listed in this. Did some of the Jane Does leave
21 school before they began their relationship with
22 Mr. Epstein?
23 A Yes, they did.
24 Q Now everyone was handed a copy of a
25 document entitled, Merged Flight Manifests. If I
OFFICIAL REPORTING SERVICE, LLC
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EFTA00179313
14
1 could ask you to take a look at that, and in the
2 proposed indictment if you could turn to Page 32.
3 Special Agent , I'm going to
4 ask you about Overt Acts 191 through 225. Can
5 you tell the grand jury what the basis is for the
6 allegations set forth in 191 through 225?
7 A We received through the issuance of a
8 grand jury subpoena the flight manifest from Mr.
9 Epstein's pilot and that is our evidence to show
10 the travel that Mr. Epstein did, which is
11 displayed in Overt Acts 191 through 225.
12 Q And the chart that is entitled Merged
13 Flight Manifests, what does that include?
14 A This chart will show the grand jury that
15 in January 2004 through -- basically, Mr.
16 Epstein's travel in '04 and '05 on his two
17 personal aircrafts, which would be the Boeing 727
18 and the*Gulfstream.
19 If you look at this chart, the first
20 column is the date of departure, the date that he
21 left, and you'll see airport codes in the next
22 column that tells you the airport that he left and
23 what time he left would be the next time, the
24 departure time.
25 It will tell you what airport he was
OFFICIAL REPORTING SERVICE, LLC
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15
1 arriving in and what time he arrived at that
2 airport, and the last would be the actual
3 aircraft itself, which aircraft he was traveling
4 on, and just to remind the grand jury, Hyperion
5 is the Gulfstream and JEGE is the Boeing 727.
6 Q And who created this chart, the Merged
7 Flight Manifests Chart?
8 A The FBI.
9 Q And where did they gather this
10 information from?
11 A We subpoenaed or the grand jury issued a
12 subpoena to the pilot and pilots of Mr. Epstein
13 and through counsel the pilots gave us a copy of
14. the flight manifest for those two years and I have
15 here a set of the flight manifests that were
16 provided to us by the grand jury subpoena and have
17 marked each of the Overt Acts from 191 to 225.
18 So that if any time the grand jury would
19 like to come and look at the actual manifest the
20 pilots gave us, you'll be able to see the data
21 that this form was taken from.
22 Q Okay. Thank you.
23 : Before I go on, does
24 anyone have any questions about those Overt
25 Acts and where this information came from?
OFFICIAL REPORTING SERVICE, LLC
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1 Yes, sir.
2 A GRAND JUROR: Is there something that
3 ties in these travel itineraries to the
4 actual fact that there was a meeting or
5 something planned? I mean, where does that
6 tie together? Traveling is not against the
7 law.
8 Right. The way that we
9 had the indictment organized before was an
10 attempt to do this in chronological order,
11 which seems to be more confusing rather than
12 less confusing.
13 So when you look at the -- when you hear
14 the testimony from Special Agent
15 and when you look at the Overt Acts related
16 to the victims and when he went to see them,
17 you'll see that the dates of travel relate to
18 the dates of his meeting with the victims.
19 Does that make sense?
20 A GRAND JUROR: Yes.
21 BY
22 Q Is there anything else, Special Agent
23 , that I should add to that?
24 A No. It will become clear once we
25 testify about the travel count.
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1 A GRAND JUROR: Can I just ask which
2 airport is ISM?
3 THE WITNESS: You know, I can in the
4 next session, I would be happy to bring the
5 airport codes.
6 A GRAND JUROR: Okay.
7 THE WITNESS: Obviously, we focused in
8 on his times when he traveled into the Palm
9 Beach County area and that would be PBIA Ol
10 PBI, but I can certainly provide all the
11 airport codes at our next session.
12 BY
13 Q All right. Now throughout the Overt
14 Acts portion where there are discussions of
15 various Jane Does, there will be mentioned a
16 telephone call.
17 So, for example, if you look at Page
18 Ten, Paragraph 17, it says on or about April 23rd,
19 2004, Defendant .Sarah Kellen placed a telephone
20 call to a telephone used by Jane Doe Number Two.
21 Do you see that?
22 A Yes.
23 Q And Special Agent , what is
24 the evidence that we have related to the telephone
25 calls that are mentioned in the Overt Acts?
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1 A We have issued administrative subpoenas
2 to telecommunication companies for cell phone
3 records for Mr. Epstein's assistants as well as
4 many of the Jane Does.
5 These specific Overt Acts are reflected
6 in those telephone records and we have also
7 prepared for the grand jury -- I brought with me
8 today, and I will bring with me next time, all of
9 the telephone records for -- that we have received
10 via administrative subpoenas.
11 Today I brought the ones pertaining to
12 the Overt Acts and what we have done is we have
13 taken those cell phone records and we have marked
14 for the grand jury all the Overt Acts that are
15 listed in the indictment.
16 You'll note when you go to that page,
17 there will be a little mark by the telephone call
18 that we are specifically talking about in the
19 Overt Acts.
20 Q And can ydu just remind the grand jury
21 what information will be on those records?
22 A It will be telephonic contact between
23 Sarah Kellen, Nadia Marcinkova, Adriana Ross or
24 Mucinska, telephonic contact between his
25 assistants and the Jane Does.
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1 Q It will show the telephone number that
2 was called and the dates and time and length of
3 the call?
4 A Yes, it will.
5 Q All right.
6 Any questions before we
7 start talking about the sexual activity
8 between the defendant and the victims? Okay.
9 No questions.
10 BY
11 Q Let's talk first about Jane Does One and
12 Two. They are grouped together in Overt Acts One
13 through 18. Who is Jane Doe Number One?
14 A Jane Doe Number One is a white female.
15 Her name is Virginia. She was born in August of
16 1983 and she lived in the Palm Beach County area
17 during the time that she had contact with Mr.
18 Epstein.
19 Q Has she been interviewed?
20 A Statements have been provided to the FBI
21 by Jane Doe Number One.
22 Q In addition to her statements, who else
23 has provided information regarding Jane Doe Number
24 One?
25 A Jane Doe Number Two and Jane Doe Number
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1 One's boyfriend at the time she had contact with
2 Mr. Epstein, which is Anthony Figueroa.
3 Q Who is referred to as in the
4 indictment?
5 A Yes.
6 Q During what period of time, did Jane Doe
7 Number One have contact with Mr. Epstein?
8 A Jane Doe Number One met Mr. Epstein when
9 she was 15. So that would be in the last half of
10 1998 until 2003 that we are aware of.
11 Q How did she meet Jeffrey Epstein?
12 A She met Mr. Epstein at age 15 and
13 according to her boyfriend when she was 20, Mr.
14 Epstein sent her to Thailand for massage therapy
15 school.
16 So she -- the time frame that she was
17 with Mr. Epstein was from the age of 15 until we
18 are aware of is age 20. Anthony Figueroa never
19 saw Jane Doe Number One again after she went to
20 Thailand.
21 She would contact him by telephone, but
22 she never returned back. He stated he inherited
23 her dog. She never came back that he is aware of.
24 So the time frame that we had Jane Doe Number One
25 with Mr. Epstein is from age 15 to 20.
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1 I'm sorry, the question you asked me
2 was: How did they meet? They met by a friend of
3 Mr. Epstein's. Jane Doe Number One was working at
4 Mar-a-Lago and a friend of Mr. Epstein's,
5 Ghislaine Maxwell.
6 Would you like the spelling?
7 THE REPORTER: Yes, please.
8 THE WITNESS: G-H-I-S-L-A-I-N -I,
9 Maxwell, who was a friend of Mr. Epstein, met
10 Jane Doe Number One at Mar-a-Lago and Jane
11 Doe Number One soon after began working and
12 providing massages for Mr. Epstein.
13 BY
14 Q What sexual activity was Jane Doe Number
15 One involved in with Jeffrey Epstein?
16 A Through the statements provided by Jane
17 Doe Number Two, when Jane Doe Number Two was 14
18 years of age, she saw Jane Doe Number One naked
19 and engaged in what she believed to be sexual
20 intercourse with Mr. Epstein.
21 Q Now did Jane Doe Number One recruit any
22 one else to go to Jeffrey Epstein's home?
23 A At this time, the only Jane Doe that we
24 are aware of is Jane Doe Number Two or the only
25 individual we are aware of is Jane Doe Number Two.
OFFICIAL REPORTING SERVICE, LLC
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1 Q Okay. So let's talk about Jane Doe
2 Number Two. Who is she?
3 A Jane Doe Number Two is a white feinale
4 named Carolyn. She was born in January of 1987.
5 She lived in Palm Beach County, Florida, at the
6 time she had contact with Mr. Epstein.
7 Q And how -- has she been interviewed?
8 A Yes.
9 Q During -- how old was she during the
10 time frame that Jane Doe Number Two was involved
11 with Mr. Epstein?
12 A She was 14 at the time that she first
13 met Mr. Epstein.
14 Q And she was involved with him until she
15 was 17?
16 A We have in or about the beginning of
17 2001, which would make her 14 up until 2004.
18 Q And how did she come to meet Mr.
19 Epstein?
20 A Jane Doe Number One brought Jane Doe
21 Number Two to Mr. Epstein's residence for the
22 first time. Mr. Epstein was introduced to Jane
23 Doe Number Two by Jane Doe Number One.
24 There was a massage that took place with
25 the two of them and then Jane Doe Number One
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1 engaged in sexual activity that I mentioned
2 earlier where Jane Doe Number Two informed us that
3 she sat on the couch and observed what she
4 believed the two of them to engage in sexual
5 intercourse.
6 Q And at the time, Jane Doe Number One was
7 17 and Jane Doe Number Two was 14?
8 A Yes.
9 Q All right.
10 A And I'm not sure if that was actually
11 the first or second visit that she went. So it
12 was either the first visit or the second that the
13 sexual activity that I described took place.
14 They may have gone there the first time
15 and just performed a massage for Mr. Epstein, but
16 on the second occasion the sexual activity that I
17 described took place.
18 Jane Doe Number Two stated that, you
19 know, the three years that we discussed from 2001
20 to 2004, she provided Mr. Epstein with over, in
21 that three-year period, over 100 massages and all
22 but three of the massages were sexually in nature.
23 Q How much was she paid for performing
24 sexual massages for Epstein?
25 A She was paid between 200 and $400.
OFFICIAL REPORTING SERVICE, LLC
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1 Originally, she was paid $300 when she starting
2 performing massages for Mr. Epstein. On at least
3 two occasions, Mr. Epstein offered her $100 more
4 if she would take off her underwear, which she
5 did, and on those two occasions she was paid
6 $400.
7 When Jane Doe Number Two expressed to
8 Mr. Epstein that she did not want him touching her
9 vagina, Jane Doe Number Two informed us that he
10 dropped the amount to $200.
11 She would also receive $100 for bringing
12 any girls.
13 Q All right. Now you said that on all but
14 three occasions with Jane Doe Number Two, the
15 massages were sexual. Did Jeffrey Epstein
16 masturbate during those massages?
17 A Yes, he did.
18 Q Did he instruct Jane Doe Number Two to
19 do anything while he was masturbating?
20 A Yes. He asked her to rub and pinch h
21 nipples.
22 Q And these started when she was still 14?
23 A Yes.
24 Q What was the involvement of Sarah Kellen
25 with Jane Doe Number Two?
OFFICIAL REPORTING SERVICE, LLC
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1 A Sarah would schedule Jane Doe Number Two
2 and sometimes Sarah would be out of town and be in
3 New York and scheduled her to come and work, but
4 Sarah Kellen's primary role was to schedule or I
5 guess she was the one that would schedule Jane Doe
6 Number Two to come and perform the massages.
7 Q Did Sarah Kellen ever actually lead Jane
8 Doe Number Two upstairs up to the bedroom?
9 A Yes. After Jane Doe Number One took
10 Jane Doe Number Two, Jane Doe Number Two started
11 going by herself. The first time that Jane Doe
12 Number Two arrived at Mr. Epstein's by herself,
13 Sarah Kellen took Jane Doe Number Two from the
14 kitchen and took her upstairs for the massage that
15 was to be performed for Mr. Epstein.
16 Q Now you mentioned the sexual activity
17 that Jane Doe Number two observed between Jane Doe
18 Number One and Mr. Epstein. Was there ever any
19 other females involved in the sexual activity?
20 A Yes. Mr. Epstein introduced an
21 unidentified female who performed oral sex on Jane
22 Doe Number One -- I'm sorry, on Jane Doe Number
23 Two while Mr. Epstein had sexual intercourse with
24 the unidentified female.
25 Q Now you mentioned that at some point,
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1 Mr. Epstein asked Jane Doe Number Two to start
2 bringing girls; is that correct?
3 A Yes.
4 Q And did he describe what exactly he
5 wants, the type of person that he wanted her to
6 bring? Did she report that he asked her if she
7 had any younger friends that would be interested
8 in performing massages?
9 A Yes. He asked her -- can I just have a
10 moment?
11 Q Of course, yes.
12 A I'm sorry. Jane Doe Number Two, Mr.
13 Epstein asked her if she had any friends that
14 would be interested in performing these massages
15 and then he also inquired if she had any younger
16 friends that would -- that she could bring to him
17 and then he offered to pay her $100 for each
18 person that she brought.
19 Q In addition to the sexual activity with
20 Mr. Epstein, did Sarah Kellen ever involve Jane
21 Doe Number Two in any specific activity?
22 A Yes. Sarah Kellen contacted Jane Doe
23 Number Two by telephone and asked her to come to
24 Mr. Epstein's residence that Mr. Epstein wanted
25 Sarah to take pictures of Jane Doe Number Two.
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1 Sarah paid Jane Doe Number Two $500 to
2 take naked photographs of Jane Doe Number Two at
3 Mr. Epstein's residence in and around the house
4 and pool area at the request of Mr. Epstein.
5 Q And approximately how old or how old
6 does Jane Doe Number Two believe she was at the
7 time?
8 A Jane Doe Number Two informed us that she
9 was 16 years old when Sarah Kellen took the
10 photographs of her naked.
11 Q What did Jane Doe Number Two say about
12 whether Jeffrey Epstein knew her true age?
13 A Jane Doe Number Two was informed by Jane
14 Doe Number One to say if asked her age that she
15 was -- she should respond that she was 17. When
16 they went -- and went to Mr. Epstein's residence
17 and were upstairs performing massages, Mr. Epstein
18 asked Jane Doe Number Two her age.
19 She responded four --. And then he
20 said, so you're 14? And Mr. Epstein informed Jane
21 Doe Number Two that they would just keep that
22 between them.
23 Q So in other words, he knew that she was
24 14 when she started seeing him?
25 A Yes. She did not remember to say 17 and
OFFICIAL REPORTING SERVICE, LLC
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2 P,
1 just naturally came out four --. And then he
2 finished that statement for her, so you're 14?
3 And then stated that they would keep that between
4 them.
5 Q Now is the -- can you summarize -- does
6 .cover the evidence supporting the
your testimony.
7 allegations in Overt Acts One through 18?
8 A Yes, it does.
9 Q And if I could ask you to refer to Count
10 Two, which appears on Page 38. Is the evidence
11 that you have just summarized the basis for the
12 allegation that Jeffrey Epstein and Sarah Kellen
13 procured Jane Doe Number Two to engage in
14 commercial sex acts knowing that she was under 18?
15 A Yes.
16 Q So is there anything else that you
17 wanted to mention with respect to either Jane Doe
18 Numbers One or Two?
19 A The only other thing I didn't bring up
20 was the gifts that Mr. Epstein provided to Jane
21 Doe Number Two and Mr. Epstein would provide her
22 with lingerie.
23 He gave her tickets to a concert, a
24 local concert. He would also send her via FedEx
25 packages to her residence, and in one of those
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1 packages Jane Doe Number Two informed us that
2 there was a Massage for Dummies book that she
3 received by FedEx from Mr. Epstein.
4 And the grand jury should know that we
5 have received records from FedEx which corroborate
6 Mr. Epstein's address and packages going to Jane
7 Doe Number Two's residence.
8 Q And those records relate to Mr.
9 Epstein's personal Federal Express account?
10 A Yes.
11 A GRAND JUROR: Jane Doe Number Two, do
12 we know how old she was when Mr. Epstein
13 asked her to bring younger friends? Was she
14 already in his eyes up there and he wanted
15 them younger?
16 THE WITNESS: When Jane Doe Number Two
17 was 16, about midway through her 16th year,
18 she became pregnant and at that point she did
19 not provide Mr. Epstein with anymore
20 massages.
21 So I know she went away for a time
22 period and when she came back, you know, she
23 had a son and did not want to do massages
24 anymore. So at that point, she may have
25 brought her friends as well as prior to that.
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1 BY
2 Q Do you know exactly when she started
3 bringing other girls?
4 A I don't know that I want to say that it
5 was before or after. We just know that she was
6 asked by Mr. Epstein to bring other females and he
7 would pay $100.
8 The only other thing we haven't talked
9 about is we have message pads that were recovered
10 in the execution of the state search warrant on
11 Mr. Epstein's residence, and I think the grand
12 jury has seen copies of some of those message
13 pads.
14 We do have a message pad for Jane Doe
15 Number Two that gives you an example of -- and I
16 can pull that out and read that to the grand jury,
17 if you would like?
18 Q Sure.
19 A This particular message pad is
20 basically -- it's a carbon copy message that again
21 was recovered during the execution of the state
22 search warrant at Mr. Epstein's residence and this
23 shows that this was dated on March 11 , 2003.
24 It's from Carolyn with her phone number
25 and it's marked that she telephoned and it's
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1 marked, please call, and it was signed by one of
2 Mr. Epstein's employees. So again the date that
3 the contact here is March 11 , 2003.
4 Q And Jane Doe Number Two was still under
5 the age of 18 at that time?
6 A Yes, she was.
7 Q Okay. Now if we could turn to Jane Doe
8 Number Three and who is she?
9 A Jane Doe Number Three is a white female
10 named Cortney. She was born October 1987 and she
11 lived in the Palm Beach County area.
12 Q Has she been interviewed?
13 A Yes.
14 Q And during what period of time did Jane
15 Doe Number Three have contact with Jeffrey
16 Epstein?
17 A Beginning in or around 2003 to up 2005.
18 Q And how old was she during that time
19 frame?
20 A She was 15 when she first met Mr.
21 Epstein.
22 Q And how did she meet him?
23 A Jane Doe Number Two brought Jane Doe
24 Number Three to Mr. Epstein's house. They
25 traveled by taxi there. Jane Doe Number Two took
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1 Jane Doe Number. Three upstairs to meet Mr.
2 Epstein.
3 They provided Mr. Epstein a massage in
4 their underwear. Mr. Epstein asked Jane Doe
5 Number Two to leave and Jane Doe Number Three
6 finished the massage.
7 Mr. Epstein masturbated in front of Jane
8 Doe Number Three on that first occasion, and Jane
9 Doe Number Three, after the massage, she was paid
10 $200 and she left the residence.
11 Q All right.
12 A On other occasions after that, Sarah
13 Kellen would be the one to contact Jane Doe Number
14 Three to come to the residence to provide massages
15 for Mr. Epstein.
16 Q And you have phone records showing calls
17 from Sarah Kellen's phone to Jane Doe Number
18 Three's phone?
19 A Yes, I do.
20 Q In addition to that, the masturbation
21 during that massage, was there other sexual
22 activity that occurred between the two of them?
23 A Yes, there was. Mr. Epstein requested
24 that Jane Doe Number Three rub his chest and
25 nipples while he masturbated. He also used a
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1 massager slash vibrator on Jane Doe Number Three's
2 vagina.
3 He touched Jane Doe Number Three's
4 vagina. He also instructed Jane Doe Number Three
5 to straddle an unidentified female and fondle the
6 unidentified female as he used she believed it was
7 a vibrator or a massaging device on the
a unidentified female's vagina.
9 Q And on each of those occasions was she
10 paid?
11 A Yes, she was.
12 Q And did she tell you about the range of
13 of money that she would receive for each visit?
14 A She received $200 for the time period
15 when she would provide Mr. Epstein during the
16 massages.
17 Q Did Jane Doe Number Three recruit anyone
18 to go Mr. Epstein's house?
19 A Yes.
20 Q And did she tell you anything about what
21 Epstein's requests were in terms of who she should
22 bring?
23 A Yes. Mr. Epstein asked her to bring
24 other females. Jane Doe Number Three stated that
25 Mr. Epstein's preferences were short little white
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1 girls. Jane Doe Number Three brought girls ages
2 15 to 25 years of age.
3 Q Were there girls whom Jane Doe Number
4 Three brought to Mr. Epstein's home whom he did
5 not like?
6 A Yes. Mr. Epstein informed Jane Doe
7 Number Three that he didn't want girls with
8 tattoos, older girls, or black girls.
9 He also expressed frustration with Jane
10 Doe Number Three when she didn't have new females
11 for him.
12 Q And how would he express that
13 frustration?
14 A He hung up on her. He telephoned her.
15 He also would telephone her. Sarah Kellen and Mr.
16 Epstein would call Jane Doe Number Three and on
17 this particular occasion when she didn't have a
18 female for him, he hung up.
19 Q Now if we could go back to the girls
20 whom Mr. Epstein didn't like. You said older
21 girls, girls with tattoos, and black girls. When
22 Jane Doe Number Three brought those girls to his
23 home, did he allow them to massage him?
24 A No.
25 Q So those girls were just sent away?
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1 A They were, but they were paid for
2 coming.
3 Q Now if I could just refer you to Overt
4 Acts 29 and 31 , which are on Page 12. There is a
5 reference to two written telephone messages and
6 could you just remind the grand jury of where that
7 information comes from?
8 A I actually have copies. Overt Acts 29
9 and 31 are message pads or carbon copy messages
10 that were found at Mr. Epstein's residence when
1 1 the Town of Palm Beach Police Department executed
12 a state search warrant on his residence.
13 The first one, Overt Act 29, is a
14 message dated November 8, 2004. It was taken at
15 1 :15 p.m. The message is for Mr. Epstein from
16 Cortney with her cell phone number and in
17 quotations it says, I have a female for him. At
18 the bottom is an employee of Mr. Epstein, the
19 house manager, Alfredo Rodriguez.
20 Overt Act 31 is a message for Mr.
21 Epstein dated January 29, 2005. It looks like the
22 time was 4:10 p.m. It is from*Cortney with her
23. phone number on it and in quotations, I have a
24 female for him. Again, initialed by Mr. Epstein's
25 house manager, Alfredo Rodriguez.
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1 Q Now does your testimony today summarize
2 the evidence supporting the allegations in Overt
3 Acts 19 through 31?
4 A Yes.
5 Q And if I could just refer you to Count
6 12, which appears on Pages 40 and 41 of the
7 proposed indictment. Is this the evidence that
8 you just summarized the basis for the allegations
9 that Jeffrey Epstein and Sarah Kellen used a
10 facility of interstate commerce to persuade,
11 induce, and entice Jane Doe Number Three to engage
12 in prostitution and in sexual activity for which a
13 person can be charged with a criminal offense?
14 A Yes.
15 Q Was Jane Doe Number Three under the age
16 of 16 during part of her
DataSet-10
Unknown
16 pages
020/.01-M40O)
FEDERAL BUREAU OF INVESTIGATION
Precedence: ROUTINE Date: 11/28/2007
To: Miami Attn: Pal
SA
SA
Prom: Criminal Investigative
Violent Crimes Section (VCS)/Crimes Against Children Unit
(CACU)/Room 3999
Contact: IA
Approved By:
Drafted By:
Case ID #: 31E-MM-108062-0(Pending) -30
31E-HO-C1461258 (Pending)-'25-5
Title: EIN;
•
GHISLANE MAXWELL;
WSTA - CHILD PROSTITUTION
GRAND JURY MATERIAL - DISSEMINATE PURSUANT TO RULE 6(e)
Synopsis: Details analysis conducted on captioned child exploitation
investigation.
Enclosure(s): One (1) CD containing the following items: Sixteen
Microsoft Excel spreadsheets detailing all pertinent calls
between the individual victims and the subjects, as well as calls
between victims; four timelines detailing individual trips to
the Palm Beach Area by the subjects and the calls/events which
occurred during those trips; one I2 Analyst Notebook chart
depicting the calls to and from the subjects and victims; and one
I2 Analyst Notebook chart detailing all of the victims and what
additional victims each one brought to subject's house.
Details: From March 2005 through May 2006, the Palm Beach Police
Department (PBPD) Palm Beach, FL conducted an investigation
involving ' airs Jeffrey Enstei al
assistant and has since
been named a victim in captioned investigation. u iple
underage females were recruited and brought to Epstein's
residence for the purpose of engaging in sexual activity with
Jeffrey Epstein. FBI Miami, Palm Beach RA (PBRA) opened a White
afteisn
- 1414 (OW(02 -6-5-
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Slave Trafficking Act - Child Prostitution investigation after
PBPD requested an FBI investigation.
Once the underage females arrived at the Epstein
residence at 358 El Brillo way, Palm Beach, Florida, they were
taken to Epstein's bedroom where they were instructed by Epstein
to remove all or most of their clothing and provide him with a
massage. In some cases, as the minor provided the massage,
Epstein fondled the minor either on their breasts or vagina.
Epstein would on occasion introduce a vibrator/massager and used
it to rub the minor's vagina. On numerous occasions, Epstein
digitally penetrated the minor's vaginas. Epstein engaged in
sexual intercourse with at least three underage females. At the
conclusion of the sexual activity, the minors were paid cash sums
ranging from $200.00 - $1,000.00.
Epstein sometimes provided gifts to the minors for
special occasions, such as birthdays. These gifts included bra
and panty sets from Victoria's Secret, vibrators, tickets to
shows, books, and cash, among other things.
The extent of Epstein's wealth can only be estimated,
however he does own two private jets, the largest single family
home in Manhattan-New York City, NY, a ranch in New Mexico, a
private Island in the U.S. Virgin Islands, as well as his house
in Palm Beach, Florida.
amed as subjects of captioned investigation are
another live-in assistant of Epstein's,
ti fl ane Maxwell. Epstein's supposed socialite girlfriend, and
a model and former assistant to Epstein.
Through the course of the FBI investigation, case
agents identified over 30 minor females who provided Jeffrey
Epstein with a massage at his Palm Beach residence. Case agents
obtained phone records for at least 13 victims for the times they
were allegedly at the Epstein residence, t 's • e
along cords for
The PBRA also obtained, through their investigation,
copies of the flight manifests from Jeffrey Epstein's two private
2
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jets. Over the course of the two year period for which this
investigation covers, Jeffrey Epstein made 127 trips in and out
of the West Palm Beach Airport (PBIA), using his two personal
aircraft. The two aircraft Epstein owns are a Boeing 727, and a
Gulfstream G-1159B. Overall, most of the flights were between
West Palm Beach Airport and the New York Metropolitan area,
however there were a number of flights to the U.S. Virgin
Islands; Paris, France; London, UK; as well as several other U.S.
and International destinations. Jeffrey Epstein was on every
flight documented on the manifests, with the exception 15 regular
flights and 27 repositioning/maint ' ing flights. Of
oand out of PRIA, was on 80 flights,
'ghts, is wale axwell was on 16
g s, an was on at least eight flights,
although the spe ing o er name varies according to whomever
wrote it down. Also present on one of the flight manifests was
the name of Alan Derschowitz, and a separate manifest with an
individual with the name "Barok" who traveled with two body
guards.
During a search of Epstein's residence, the
investigating Police Department obtained several books of message
pad carbon copies. According to the house manager, who was
interviewed by PBRA Agents, Epstein required all phone calls to
the Palm Beach residence to be documented. There were multiple
carbon copy message pads obtained during the search. Of the
carbon copy message pads, over 120 messages were from the victims
previously mentioned. A good portion of the message pads were
date and time stamped by the message taker. Of particular
interest on the message pads were calls from notable celebrities
and public figures such as Donald Trump, David Copperfield, Sarah
- Duchess of York, and Halle Barry, indicating the social status
of Jeffrey Epstein.
During the initial investigation there were several
trash pulls conducted by the Palm Beach Police Department on the
Epstein residence on El Brillo Way in Palm Beach. These trash
pulls yielded several pieces of scratch paper, along with Jeffrey
Epstein and Ghislaine Maxwell stationery with handwritten notes
pertaining to the victims. The trash pulls started in April of
2005, and continued through September 2005. of the
pertinent notes from .- =sh pulls are: " on Friday
II II
cannot co rrow at 7 of
, Tues - 0 9 PM, lila 12".
high school transcript was also ound in
o e rey •stein's residence.
Western Union was sent an administrative subpoena for
all transactions concerning Jeffrey Epstein. There were three
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Western Union transactions between Epstein and the victims. The
fir e was in December, 2004 from Jeffrey Epstein to
for $200.00. The se .' d transactions were
P rom Jeffrey , one for $350.00 and
one for $200.00. a er con irmed that she received
a Western Union Trans er rom pstein when she was on vacation in
Cancun, MX Diego, CA. According to the Western Union
receipts, received her money in Cancun, MX and San Diego,
CA.
Writer completed Microsoft Excel chronological charts
to show the call activity in relation to the message pad carbon
copies, trash pulls, Western Union transactions, and the travel
of Jeffrey Epstein and associates. One chart was completed for
each of the 13 victims whose phone records were obtained by PBRA.
The PBRA obtained toll records for from
12/15/2003 through 10/03/2005. During that time peri ,
made over 21,360 calls. Of the 21,360 total calls made, X962 were
ween othe bjects of capti investigation.
called three times. rec s
ix text messages rom, and placed s to .
main st contact with of any o e o er
victims. first contacted on 07/15/2004, when
was -years- on t ig t manifests, most of
t illicalls between and were placed at a time
when Epstein was in e a m each area. e is a high
concentration of calls between in the two days
prior to Epstein's arrival at thee PBIA. ere are also several
instances of phone calls which occur one or two days after
Epstein rted the Palm Beach area. The average call time
between and the subjects was 1.25 minutes, with a longest
call of ive minutes.
had seven message carbon copies
pertaining to ner. Tne first instance dated 12/04/2004. one day
after Epstein arrived at PBIA. The message states
scheduled for 5:00 today". The next message concerning
occurs on 5/2005 at 12:45 PM, five minutes after there Is a
call from to the Epstein residence, and two days before
Epstein departs PBIA. The message states thillighe called again
about working t " he message was from " " and left the
phone number of cell phone. The next two messages occur
on Wednesday, 01 05, one day before tein departs PBIA.
The first message is at 12:00 am, from " " with the text: "She
is asking if you want her to work today? e best time will be
4
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•
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2pm or 9:45 pm" The second message, dated 01/26/2005, occurs at
1:20 pm from " " with the text: "She said that instead of
1:45, she'll be ere at 2:00pm." The next message pad occurred
o day, 02 05, one day before Epstein departs PBIA, from
, with cell phone number, with the text: "She is
wondering if 2:30is ok cuz she needs to stay in school." The
next two messages both occur on 09/04/2005, o er Epstein
arrived at PBIA. Both messages simply state
telephoned. The ssage pertaining to occurred on
09/111105 from " " to "J.E." with the ext: "I got a car
for
There were five different pieces of paper
E stein's trash with handwritten notes pertaining to
i in
II high school transcript was also found at Epstein s
rest ence. Of the five pieces of paper found in Epstein's trash,
the two most pertin contained a sketch with a handwritten
notation "Drawn by 1, the second contained the text '
tomorrow o y". e remaining pieces of paper just
mentioned name. Since it is impossible to determine when
the notes oun n the trash were actually written, they are
inserted into the spreadsheets on the day the Palm Beach Police
Department found them.
The PBRA obtained phone records for
12/12/2004 through 09/14/2005. During that tiep riod,
made 8,490 total calls. Of the 8,490 calls made, 768 calls were
en either subjects or victims of captioned investigation.
only called one time, however t were
tree text messages and 29 calls to
alltSifirst contacted on 02/ , w
was years o . Most of the ca a between and
occurred at a time when Jeffrey Epstein was in t e Palm eac
area. Of the calls that didn't occur after an Epstein flight
landed and before an Epstein flight departed, most were in the
day or two leadingl o Epstein arriving at PBIA. The average
call time between and the subjects was 1.12 minutes, with a
longest call of three minutes.
From 08/19/2005 t 005, there were six
message pads pertaining to The first message pad
occurred on 08/19/2005 from o nJ.E.n with the text
will be here tomorrow at :00am". The
message ' :55pm, approximately one hour after
called at 5- The second message pad occurs on
08/21/2 rom " r. J. Epstein" with the text Milli
cannot work today an will be here at 4:00pm". This
5
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00 105458
EFTA01246281
To:
•
Miami From: Criminal Investigative
•
Re: 31E-MM-108062, 11/28/2007
message red at 11:39am, three minutes after
called at 11:36am on the same day. The nex wo message
pads on 9/3/2005 and 9/4/2005. Both message pads were
from " " "J.E.". The first message "I text
message or to confirm for 110 d for 4:30pm",
the n xt message on 9/4/2005 stated " armed at 11:00am
4:30pm". Coinc' three phone
ca s occurred between and The last two
message pada pertaining o occurre on 10/01/2005
and 10/03/2005. Both me were rom "IIIII" to "J " The
first message text was " confirmed a am a
0/1/2005 message occurred at 9:50 am. ca led
on 09/30iiiiilat 7:06pm. The second message pad
states " will be 1/2 hour late". This message
c AA 4:10 pm, nine minutes after a call from
la to at 4:01 pm on 10/03/2005.
ere were three separate pieces of paper pertaining to
pulled from trash at the Epstein residence. The
ars per inent trash pull occurred on 04 005 with the text
dI ve left messages this morning for - confirm 100-
The next trash pull pertaining to occurred on
005. The text contained multiple gir s names, along with
The trash pull occ 09/23/2005 with the text
1pm 4:30pm/Tues - ..". All of the
a orementione , message pa s, and trash pulls,
occurred when was 17-years-old.
The PBRA obtained phone records for om
01/01/2004 through 12/31/2005. During that time peri ,
made 18,059 calls. Of the 18,059 calls made, 199 calls were
er subjects or victims of captioned investigation.
led 50 nd sent five text messages to
called 48 times. There were 34 calls
e pstein residence; fi
; and seven calls from
Most of e ca s coincided with Epstei , rave in o an ou of
PBIA. The average call length between ill and the target
numbers was one minute, with the longest ca l of 4 minutes.
From 10/09/2005 through 09 005, there were nine
message carbon copies • ' g to l Four o messages
were simply to return call, wit either cell or
home h number reference . On 12/04/2004, there was a message
f to Jeffrey with the first part of the text stated
would like to work e4 iiil if possible...". Ili
message pad on 08/20/2005 from to J.E. stated " a
6
3501.103-108
Page 6 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00105459
EFTA01246282
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
confirmed at 4 PM Who is scheduled for Morning?". The day,
08 21 2005, at 11:39 AM (one to after a call from to
a message pad from Mr. J. Epstein sta es
cannot work today an wi ere at 4:00 PM".
On 09/04/2005, there was a message rom to J.H. with the
text "she would like to resche time . emaining
message is on 09/10/2005 from o J.E. will be at
11 AM Do you want me to change ?".
There were five separate pieces of paper pertaining to
pulled from the trash at the Epstein residence.
e irs pe ull occurred on 04/01/2005 with the
"10:30 on Fri around 2 O'clock". The next
ash as on 13/2005 with the pertinent text of
or ..". The next trash pull was on 04/15/2005
confining mu ip e girls' names, along with "*Brit".
07/23/2005 was another trash pull pertaining to , the
text red " - off at 5 pm". Coincidental n /2005
a call was a from the Epstein esidence to at 9:58 am.
The final trash pull occurred on 09/23/20 with the text
1
In addition_to one calls, message pada, and trash
pulls connecting to the targets, there were two
Western Union transactions, obtained th ubpoena, in which
money was wired from Jeffrey Epstein to T e first Western
Union transaction was on 6/1/2005 for $ to
who was ncun, MX. The second transaction or S200.00 to
in San Diego. 07/13/2005. mentioned to
viewing agents that had wired er money while
was in San Diego vie t ng r ends.
Epstein mandated his hired housekeeper to keep detailed
and accurate records pertaining to the petty cash fund at the
Palm Beach residence There were two payment records in the
petty cash fund to , one on 05/07/2005 for $200.00
and one on 06/20/2005 tor $100.00.
The PBRA obtained phone records for
01/01/2004 through 12/30/2005. During that time peri ,
made a total of 15,284 phone calls. Of the 15,284 calls ma e,
1476 calls were between e' jects or ms of
capt investig , called 59 times,
and called cal s were placed from
the ps ein residence to called the residence
7
3501.103-108
Page 7 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00105460
EFTA01246283
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
times. only called •.e time.
first on 04/25/2004 wh w s 16-
years-old. s a e• in her interview would
call to e massages for Epstein mos o e ime,
however (LNU) call once to arrange for a massage.
Most of e ca is between and the subjects occurred at a
time when Epstein was in town, or one or two days to his
arrival at PBIA. The average call length between and the
subjects was 1 minute and 30 seconds, with a longest ca 1 of four
minutes.
There was only one message pad pertaining to
IFT from 01/0
2005 from
4 to 12/30/2005. The message is on
to Jeffrey at 4:21 PM. The message
occurred on the same dayl ein landed at PBIA. The text of the
message is "Is it ok if will come at 5?"
There were three trash pulls with name on them.
The trash pulls occurred on 04/12/2005, 04/11'11111 and
04/15/2005. The 04/12/2005 trash pulls fined the text "I
have left a messages this morning for - to confiiiiiif0".
The 04/13/2005 and 04/15/2005 trash pulls simply have "
along with several other girls' names.
The PBRA obtained phone records for om
05/27/2004 through 12/30/2005. During that time perio ,
made a total of 12,990 calls, 828 of which were betty
the subjects or victims of captioned investigation.
76 • and sent he :i)31.eicr
e c , t eEpstein
res ence, and 7 , three times
respectively. irs contacted on 12/06/2004 when
she was 17-years-o . As with all e other victims, most of
the calls between the subjects and occurred at a time in
which Epstein was either in the Palm each area or on the day or
two leadi p to his arrival at PBIA. The average call time
b and the subjects was 1.36 minutes with a longest
call of six minutes.
There were thr ssage pads found at the Epstein
residence pertaining to e first message pad was dated
09/03/2005 a PM from to J.E. wit ext "I text
message for to confirm or 1100 am and il for 4:30
PM". Twenty- ive minutes after 8:50 at 9:15
PM, there is a phone call from Oil to here
is an her phone call at 9:23 P again from o
. The next message pad was dated 09 005 a AM
8
3501.103-108
Page 8 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00105461
EFTA01246284
to: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
fro to J.S. with the text " - confirmed at 11:00
AM • PM". The final message on 10/01/2005 at
9:5 to J.E. with the text " confirmed at 11
AM and ". ' r he 9 message pad there was
me from to 56 from
to at 9: an a call rom to at 9:35
IN!
..t
There were seven trash pulls with name
written on pieces of paper found in Ep • ' ras . The first
is on 04/01/2005 with the " 0:30 ", the next is on
07/23/2005 with the text " i ll :00 PM", then two
- Tues
separate pieces of paper o /2005 with the text "3
time c -3454 , cell number) 'heart'
and " cannot come at 7pm tomorrow b/c o
e ansl. ras pulls occurred on 09/23/2005 wit
"Tues - 9pm", " 8pm", and "Cancelled
The PBRA obtained phone records for
fr m 27/2004 through 05/03/2005. During that time period
made 3,409 calls, of which 194 were between either the
SUD s or other victim tione igation.
lls to and made 31 calls to
rom E stein residence
an seven c s rom . called
an
during the perio or w c her rec ere ob sine .
first made telephonic contact with on 11/12/2004
was 17-years-old. Most of the call activity between
and the subjects took place when Epstein was in the Palm
eac area or in the days leading up to Epstein's arrival in Palm
th several exceptions. The average call time between
and the subjects was under one minute, with a longest
ca o 4.85 minutes.
There were two pads found at the Epstein
residence pertaining to irst message pad was
dated 01/26/2005 at 1:30 PM rom with the text
"She is confirming for 5. " subsequently
made two phone calls to uo rsafter the
aforementioned message pa at 4:11 PM and 4:26 11.1 other
message pad is dated 04/08/2005 at 8:20 Pm from to J.E.
with no message.
There were three separate pieces.of scratch paper found
in the trash at the Epstein residence. Two of sh pulls
were recovered on 04/08/2005 with the text of " onfirmed
at 5:30" and "I have left messages for - (sic) to
9
3501.103-108
Page 9 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00105462
EFTA01246285
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/20/2007
confirm 5:30 PM (it went straight to voicemail). The third trash
pull was recovered on 04/15/2005 with several girls' names, most
notably " Friday 5:30 Pm".
The PBRA also obtained all Western Union transactions
with Jeffrey Epstein's name on them. There was one Western Union
transaction on 1,/rA/70044 At 17:05 PM from "Jeffrey Epstein (New
York, NY)" to "IIIIIIIIIIIIIIII (West Palm Beach, FIB
$20 ere were coincidentally two calls from
to on the evening of 12/22/2004 around 6:00 . stein
was a so not in the Palm Beach area during the time of the
Western Union transaction.
The PBRA obtained phone records for m
08/01/2004 through 10/21/2005. During that time pert
made 14,855 calls, of which en subje or victims
in c oned inv ' tion. 16 tiiii
and called 31 tim called
six Imes, all on 9/ a so ca e Epstein
residence seven times. i st contacted on 08/21/2004
when she was 17-years-ol . phone bill does not show
incoming calls, so it is unknown whether the calls were placed
from the Epstein residence. As is the patter all of the
other victims, most of the calls to and from and to the
Epstein residence occurred while Epstein was n the Palm Beach
area. The remainder of the calls occurred one to three days
prior to arrival of Epstein to PBIA. The average call time
between and the subjects was 1.13 minutes with a longest
call of wo minutes.
There was only one message pad pertaining to IRE
The mess stated on 08/02/2004 at 12:45 rom
robably , a previously identified victim) and
IIIIIii:tol Jeffrey via e text "They are available all weekend
an may e too".
The PBRA obtained phone records for
26/2004 through 09/01/2005. During that time period,
made 14968 calls, of which 144 were bet ' he
s Sec s or victims of captio stigation. and
the Epstein res alled d 11 tames
respectively. calle 14 times and called
the Epstei nce 0 times. first telephonically
contacted on 08/19/2004 w en s e was 17-years-old.
10
3501.103-108
Page 10 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00105463
EFTA01246286
To: Miami From: Criminal Investigative
Re: 3IE-MM-108062, 11/28/2007
There are three message pads pertaining to
found in the Epstein residenc he • ad is datelliiiii
08/02/2004 at 12:45 PM from " + " t ffrey with the
text "They are available all wee end an maybe too". The
second message pad is dated 01/06/2005 at 8:30 rom "Ms.
" to "Mr. J.E." with the text "Please call her
r listed on the aforementioned message pad
is cell phone. final me p
pad is
date :45 AM from
rom " to " " with the
text "Please call her".
The PBRA obtained phone records for from
05 through 04/01/2005, when she was 14-years-old.
is only believed to have visited the Epstein residence
during this time only pertinent phone calls
and from which there were 21 calls.
never direc y con acted or w ted by the
!MTITT! Qf ned investigation. stated
arranged to provide Epstein wi
1111"
0 massages. AIo t e
calls to r d in close proximity to calls between
an or the Epstein residence.
There are two separate pieces o ulled from the
Epstein residence trash which pertain to Both pieces
of paper w re four Friday, 04/08/200 , with t e text on the
first "with on Satu at 10:30" and the text on the
second on Sa ur ay with at 10:30".
The PBRA obtained phone records f
for the month of July, 2004. According to e provi ed
Epstein with three massages, all during the 20 'me
There are hone calls bet
, fi and three from irst
con acted I on 07 04/2004 when she was I -years-o d. Five
of the cal s occurred during the day prior and the day of
Epstein's arrival at PBIA, with three calls occurr i er
ts
time
call
arrival.
average
The
between and
mit was 1.3 minutes, with a longest call of two minutes.
There were two message pads pertaining to found
at the Epstein • . Thel t pad is dated 07/3..4 at
6:45 PM from " " to " or Mr. Epstein" with the text
"Was in a car acct en on her way so cannot come. She just got
11
3501.103-108
Page 11 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00105464
EFTA01246287
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
back ( )•. The s message pad is also dated on
07/17/ : PM from " " to "Mr. Ep " with the text
can come tomorrow any time or alone".
a a e• to interviewing agents that her r end had
n r uced her to Epstein and also persuaded her not to ca 1
police when she felt violated after giving Epstein a massage.
One trash pull mentions "IIIIII", date 005,
it is unknown if the paper is re erring to
as there is another potential victim name
associated with captioned case.
The PBRA obtained phone records for
01/01/2005 through 05. During that time
made 2,927 calls. stated to interviewi
never gave her phone nu er to either Epstein or as
such there are no phone records indicating she r in
contact with the subjects of captioned case. further
as brought to the Epstein residence y er friend
, with whom she had 419 c e
a oremen coned time period. As with , several
uences of calls occurred in which alked t
, which was followed by a cal y either
or the Epstein reside ere were a ar
sequences of 'ch talked to
who brought to ei wed by calling
or the pstein residence. state s e had only
prove ed Epstein with two massages aroun the time of her 17th
birthday. There were no message pads or trash pulls pertaining
to found at the Epstein residence.
has been considered both a subject and
victim in cap case. During an interview with the Palm
Beach Police, comment was "like a Heidi Fleiss"
providing girls to Epstein. has since been identified as
a victim by the FBI and U.S. orney's office, since she too
prow' assages to Epstein. The PBRA obtained phone records
for m 01/01/2004 through 04/05/2005. During that time
perio made 8,203 calls, of which 767 were bet
subjects or o her victi ed investigation.
from ree calls from
made ca s to to fie
yp res d three calls to from her
cell phone ( home phone has a n
communication w subjects and victims, however records could
12
3501.103-108
Page 12 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00 105465
EFTA01246288
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
not be located). first contacted on 03/12/2004
when she was 17-years-o 'th e other victims,
most of the calls betwee and occurred in the time
leading up to Epstein's arrive at PBIA or after he had already
landed. The average call time between and the subjects
was 1.25 minutes, with a longest call o ree minutes.
There were fiv found at the Epstein
residence pertaining to The first message pad was
dated 2/14/2004 a o Jeffrey with the text
called ph: cell #)". Concurrently,
t ere was a phone ca e Epstein Residence on
12/14/2004 at 3: message pad was dated 02/20/2005
—'th
wi
om with the text "Left her
e next pa was date
the text "Left her cell #
2005 from imito
The fins two
message pads occur on 05/30/2005 and at 6i ir and
12:35 PM respectively. Both pads are from to with
the first pad's text of "Please call" and no text onmPP!misecond.
There were also five pieces ofailian the
Epstein residence trash which pertain to The first
three separate pieces of paper were all oun on /2005, two
on Jeffrey E. Epstein stationery, and one on Ghislaine Maxwell
' ery. text for the first (Epstein stationery )is
with Saturday at 10:30" second (also Epstein
s a ionery) is on Saturday wit at 10:30", an
third (Maxwell s a ionery) "[Friday] tomorrow or Sun.
- 11 Am". Another piece of paper was oun stein's train
04/15/2007 with multiple names and times, ' appears next to
"Shas Thur + Mon". The final piece of paper was pulled from
Epstein's trash on 09/23/2005 and was.a two sided notepad page
with r girls' names and were crossed
U .
out. appeared next to "
was added as a victim later in the
investigation, main y ue to her cell phone records being
unav ' . PBRA was able to obtain the long dis
from house, wh all o calls to
New or cell phone. called 1 times ram 5
10/02/2005, during w ich time was 1 - -old.
long distance records indicate s e calls 11 times
uring the months of January-Febuary, 2005. As wi t of the
other victims, most of the call activity was at a time when
Epstein was in the Palm Beach area. The exceptions were either
one to two days before Epstein arrived or one or two days after
13
3501.103-108
Page 13 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00 105466
EFTA01246289
To: Miami Prom: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
he departed. The average call length between and was
1.31 minutes, with a longest call of three minu es.
There were nine messages pertaining to
found at the Epstein residence (Since there are two
named as victims, writer only attributed messages to
if their was an accompanying phone number or if a as
name was written o message). Seven of the messages were
simply either that °telephoned", "would like to speak with
you", or to "call er ack (as soon as possible)". The remaining
two message pads, taken on 01/29/2005 and an unknown date state:
"I have a female for him" and "She has a female friend for you.
Please call back as soon as possible" respectively.
Conclusion
The telephone ducted for captioned case
yielded the pattern of calling one or more of the
victims one to three days ore effrey Epstein was set to
arrive i Beach, as well as during his stay. Call activity
between iiiiilLand the victims significantly decreased or did not
occur during e times when Epstein was known to not be in the
Palm Beach area. Most of the victims interviewed by
investigating Agents stated they were brought to Epstein's El
Brillo Way house in Palm Beach by friend and were introduced to
a female they later identified as The victims
further stated they gave their phone numbers to either or
Epstein himself at the conclusion of the massage/sexual ac lvity.
Another patt be ascer ined fr m the
telephone analysis is call
Palm the day
before or day of Epsteln s in Palm eac . ccording to
interviews of the victims, ly brought eight victims
to Epstein. Of the eight victims introduced to Epstein,
ten mor "ms were brought to pstein through the original
eight. has advised local investigators that slial like
eiss , arranging vict Epstein. Thus,
as' could have been calling in order to line up
appointments for Epstein.
made a total of 418 calls and 15 text messages
from her crilone to the victims. The three numbers belonging
to the Epstein residence combined for a total of 105 calls to the
victims. Of note, the calls from the Epstein residence were
calculated from the four victim's cell phone records which show
incoming calls, thus there may have keen mnre matt from the
Epstein residence to the victims. made a total
14
3501.103-108
Page 14 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00105467
EFTA01246290
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
of 46 calls, and made seven calls to the
victims.
In October 2007 a non-prosecution agreement was signed
by the U.S. Attorney for the Southern District of Florida and
Jeffrey Epstein's attorneys. As part of the agreement, Epstein
will plead guilty to one count of solicitation of prostitution.
Epstein will have to serve 18 months in state prison, one year
supervised release, and lifetime registration as a convicted sex
offender. Epstein is expected to appear in court in late
December 2007.
15
3501.103-108
Page 15 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00 105468
EFTA01246291
To: Miami From: Criminal Investigative
Re: 31E-MM-108062, 11/28/2007
LEAD(e):
Set Lead 1: (Info)
Hata
AT PALM BEACH COUNTY RA
Read and Clear.
••
16
a id
3501.103-108
Page 16 of 16
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00105469
EFTA01246292
DataSet-10
Unknown
136 pages
Case Number: 50D-NY-3027571
Case Summary:
EFTA01684466
Evidence Report for Case: 50D-NY-3027571
Filtering on: Type(s):1B
Item # Collected On
1B146 7/22/2022 10:00
1B145 5/25/202214:00
1B144 5/25/2022 14:00
1B143 7/7/2019 3:00
1B142 10/8/202113:00
1B141 10/8/202113:00
1B140 10/8/202113:00
1B139 6/29/202116:15
18138 8/12/2019 19:20
1B137 8/28/2006 11:50
1B136 1/26/202116:00
1B135 6/6/2019 12:00
1B134 8/28/2006 11:00
1B133 8/28/2006 11:00
1B132 8/28/2006 11:50
18131 8/28/2006 11:50
1B130 8/28/2006 11:50
1B129 8/28/2006 11:50
1B128 8/28/200611:50
18127 8/28/2006 11:50
18126 8/12/2019 19:20
1B125 8/12/2019 19:20
1B124 8/12/2019 19:20
1B123 8/12/2019 19:20
1B122 8/12/2019 19:20
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18112 8/12/2019 19:20
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1B108 8/12/2019 19:20
1B107 8/12/2019 19:20
18106 8/12/2019 19:20
11105 8/12/2019 19:20
1B104 8/12/2019 19:20
EFTA01684467
18103 8/12/2019 19:20
1B102 8/12/2019 19:20
18101 8/12/2019 19:20
1B100 8/12/2019 19:20
1B99 8/12/2019 19:20
1898 8/12/2019 19:20
1B97 8/12/2019 19:20
1B96 8/12/2019 19:20
1B95 8/12/2019 19:20
1B94 8/12/2019 19:20
1893 8/12/2019 19:20
1B92 8/12/2019 19:20
1691 8/12/2019 19:20
1690 8/12/2019 19:20
1889 8/12/2019 19:20
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1683 8/12/2019 19:20
1682 8/12/2019 19:20
1881 8/12/2019 19:20
1680 8/12/2019 19:20
1679 7/11/2019 15:35
1B78 7/11/2019 15:35
1B77 7/11/2019 15:35
1B76 7/11/2019 15:35
1B75 7/11/2019 15:35
1B74 7/11/2019 15:35
1B73 7/11/2019 15:35
1872 7/6/2019 18:15
1871 7/6/2018 18:15
1870 7/11/2019 19:28
1869 7/11/2019 19:28
1B68 7/11/2019 19:28
1867 7/11/2019 19:28
1B66 7/11/2019 19:28
1865 7/11/2019 19:28
1B64 7/11/2019 19:28
1B63 7/11/2019 19:28
1862 7/11/2019 19:28
1B61 7/11/2019 19:28
1860 7/11/2019 19:28
1B59 7/11/2019 19:28
1658 7/11/2019 19:28
1857 7/11/2019 19:28
EFTA01684468
1856 7/11/2019 19:28
1B55 7/11/2019 19:28
1B54 7/11/2019 19:28
1653 7/11/2019 19:28
1B52 7/11/2019 16:28
1B51 7/11/2019 16:28
1B50 7/11/2019 16:28
1849 7/11/2019 16:28
1848 7/11/2019 16:28
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1846 7/11/2019 16:28
1845 7/11/2019 19:28
1844 7/11/2019 19:28
1843 7/11/2019 19:28
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1841 7/11/2019 19:28
1840 7/11/2019 19:28
1B39 7/11/2019 19:28
1B38 7/11/2019 19:28
1837 7/11/2019 19:28
1B36 7/11/2019 19:28
1835 7/11/2019 19:28
1B34 7/11/2019 19:28
1833 7/11/2019 19:28
1B32 7/11/2019 19:28
1B31 7/11/2019 19:28
1B30 7/11/2019 19:28
1B29 7/11/2019 19:28
1B28 7/11/2019 19:28
1827 7/7/2019 3:00
1826 7/7/2019 3:00
1825 7/7/2019 3:00
1824 7/7/2019 3:00
1823 7/7/2019 3:00
1822 7/7/2019 3:00
1821 7/7/2019 3:00
1B20 7/7/2019 3:00
1819 7/7/2019 3:00
1818 7/7/2019 3:00
1817 7/7/2019 3:00
1816 7/7/2019 3:00
1815 7/7/2019 3:00
1B14 7/7/2019 3:00
1813 7/7/2019 3:00
1812 7/7/2019 3:00
1811 7/7/2019 3:00
1810 7/7/2019 3:00
EFTA01684469
1B9 7/7/2019 3:00
188 7/7/2019 3:00
1B7 7/7/2019 3:00
1B6 7/7/2019 3:00
1B5 7/6/2019 0:00
1B4 5/29/201918:00
1B3 5/29/201918:00
1B2 5/29/2019 18:00
1B1 5/29/201918:00
EFTA01684470
Description
(U) ONE CELLOPHANE containing: NYC032395 - One (1)DVD-R containing image log files and FTK reports for systel
(U) Red Rope Containing;NYC032391- Three (3) LTD 6 tape cartridges containing an Arcserve backup of all digital
(U) Red Rope Containing;NYC032392 - Two(2) LTO 6 tape cartridges containing an Arcserve backup of all digital evi
(U) one (1) CD labelled "girl plcs nude book 4"
(U) ONE REDROPE CONTAINING: (1) Envelope containing 1 VHS tape, 2 cassette tapes & 4 micro cassette tapes
(U) ONE REDROPE CONTAINING: (1) Envelope containing 4 CD's
(U) (2) Bankers box containing various EPSTEIN related case materials
(U) ONE BOX CONTAINING: One pair of black women's cowboy boots, size 8
(U) ONE CELLOPHANE containing: Disk containing images of Matchmaker shred reconstruction
(U) ONE CELLOPHANE CONTAINING: (1) un-framed photo.
(U//FOUO) ONE RED ROPE containing: Highly confidential responsive material to include nude and semi nude ima
(U) Box containing Ten yearbooks collected by FBI West Palm Beach Resident Agency
(U) One (1) peach massage table.
(U) One (1) green massage table (PBPD0S-1024).
(U) One (1) beige massage table.
(U) One (1) brown massage table.
(U) One flat box containing one (1) large framed photo.
(U) One box containing four (4) framed photos.
(U) One box containing twelve (12) framed photos.
(U) One box containing five (5) framed photos
(U) One red rope containing: LSJ logbook
(U) One red rope containing:Daily Vessel Trip logs Feb 2, 2017 - Feb 16, 2017
(U) HP Tower S/N: CNV74213M3 Model: 570-p056
(U) Lenovo Tower S/N: 153306G2USAIXEKGX
(U) Lenovo Tower S/N: M107YG6U Machine type: 90J0
(U) Mac DesktopS/N: W89524C2SPJ model A1312
(U) HP TowerS/N: CNV716004YModel #: 260-a010
(U) HP Desktop TowerS/N: CNV7160050Model #: 260-a010
(U) Silver Mac desktop
(U) 6 Bay with 146GB drivesS/N: MXQ824A1R
(U) One box containing Panasonic KX-TDE100S/N: KX-TDA01049LCCD005398
(U) HP server with (4) 500 GB drivesS/N: MXQ3220187
(U) Blue prints
(U) One cellophane containing:Boat trip log & employee lists
(U) Unifi serverMacID: 1735K788A20463234-8uuu9FFCCID: SWX-UASPRO
(U) Unifi videoM/N: UVC-NVR-2TBMacID: 1829FB4FBE426EA90
(U) One cellophane containing:Paper with passwords on both sides
(U) Unifi Cloud keyM/N: UN-CKFCCID: SWX-UCCKIC 6545A-UCCKMac ID: 1843KB4FBE4D30C69-dcRgm9
(U) CELLOPHANE containing Olympus Digital Voice Recorder
(U) Silver Mac desktopModel #: A1311S/N: W804736DDA5
(U) Dell Inspiron tower with power cordReg Model: D19MQCHFA335
(U) One red rope contalning:LSJ & GSI Boat Log 2019
(U) Box containing Shredded paper
EFTA01684471
(U) ONE CELLOPHANE CONTAINING; Apple iPod shuffle on watch band
(U) Silver Macbook Desktop with keyboard
(U) One cellophane containing:Photograph
(U) One cellophane containing:Employee contact list
(U) One red rope containing:Red Nikon Camera
(U) One box containing: Silver Desktop Mac with keyboard
(U) HP Laptop with chargerS/N: CND81368V5
(U) Toshiba Laptop with charger
(U) One red rope containing:Remodeling documents for Island
(U) One cellophane containing:Handwritten notes on LSJ notepad
(U) One flat FedEx box containing: Photos, Photo negatives, letter
(U) One red rope containing:lsland blueprints, island photos, and documents
(U) One red rope containing:photo album of girl & Epstein
(U) One red rope containing:letter, photo album of girls, photos of island
(U) One cellophane containing:Document with names
(U) One cellophane containing:Employee contact list
(U) Silver Mac Desktop
(U) One red rope containing: Notepads with notes - LSJ stationary with handwritten notes
(U) Silver Mac Desktop with mouse & keyboardS/N: C02NM1MOFY14
(U) Silver iPad Model A15675/N: DMPQL1RMG5Yin case
(U) CELLOPHANE containing Silver iPad Model A15675/N: DMPQL25NGSYPYin case
(U) RED ROPE containing Silver MacBook ProS/N: C02QMOGUGWDP
(U) Silver Mac Laptop labeled "JE BIG LAPTOP" "BLACK BAG" in black bag S/N: W89111772QT
(U) Mac Desktop labeled "Kitchen Mac" - grey
(U) One heat-sealed bag containing one yellow envelope marked "SK" dated 08/27/08 containing multiple smaller
(U) RED ROPE CONTAINING: 4 binders with 68 discs inside
(U) One heat-sealed bag containing one small white envelope with writing "2000-SK" containing $4,400 USC (44 x
(U) ONE CELLOPHANE CONTAINING; Austrian Passport with Epstein photograph
(U) RED ROPE CONTAINING: Two blue binders with 58 discs inside
(U) CELLOPHANE containing Black hard drive
(U) CELLOPHANE containing Black hard drive
(U) One (1) silver IPad with serial number DLXQGM3KGMW3.
(U) ONE CELLOPHANE CONTAINING :One (1) black iPhone with IMEI number 357201093322785.
(U) One box containing: 1 Apple Desktop computer
(U) 1 Silver IPAD - 64GB
(U) 1 Space Gray Apple IPAD
(U) 1 Space Gray Apple IPAD
(U) One cellophane containing 1 Black Radioshack recorder
(U) One cellophane containing 1 Silver Olympus recorder
(U) One cellophane containing 1 Sony BM-560 Recorder
(U) Box containing 45 Assorted Cd's
(U) One red rope containing 1 Sony Vaio Laptop
(U) 1 Dell Precision Tower 5810
(U) One red rope containing:1Seagate Barracuda 7200 harddrive 80GB
(U) 1 MSI PC Computer IN A BROWN BOX
(U) One red rope containing:1Sony Camera with black case
(U) 1 Gray Apple Desktop Computer with keyboard and mouse
EFTA01684472
(U) One cellophane containing 1 Seagate Backup Plus Portable Drive - 1TB
(U) One cellophane containing one (1) White Apple (Phone 5, 64GB.
(U) 1 Apple Desktop Computer with keyboard and mouse
(U) 1 Apple Desktop Computer with keyboard and mouse
(U) One cellophane containing:1SPIEF 2014 Silver USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Blue EMTEC 16 GB USB
(U) One cellophane containing 1 EMTEC 16 GB USB
(U) One red rope containing:10 assorted cd's
(U) One cellophane containing 3. Silicone Power Micro SD Adapter with 16GB SD Card
(U) 1 DELL Machine
(U) 1 Cube 9000 Siteserver, (BLACK/SILVER)
(U) 1 HP Compaq Machine
(U) One cellophane containing one (1) Mentor Media 32GB USB.
(U) One cellophane containing one (1) Data Traveler 4GB USB.
(U) One cellophane containing one (1) Data Traveler 4GB USB.
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) Silver Apple Desktop Computer with keyboard and mouse
(U) ONE BOX CONTAINING: 1 stuffed dog
(U) Box containing 2-1inch black binders containing CD's and 13 loose CD's
(U) ONE BOX CONTAINING: 2 white in color busts of female torsos
(U) ONE BOX CONTAINING: 1 brown bust sculpture of female breasts
(U) One red rope containing: 2 photos and 1 album page with additional 2 photos
(U) ONE BOX CONTAINING: 1 blue box containing various Cd's
(U) Red rope containing 12 polaroid photos, 1 folder labeled "Sue" containing various photos/cd's
(U) ONE BANKERS BOX CONTAINING: bundled photos and cd's from "Women Old Photos Box"
(U) 10 black binders containing photos, cd's etc.
(U) 1 blue in color bust of a female torso
(U) One red rope containing: 2 photos of female buttocks
(U) One box containing: 5 costumes and 1 wig
(U) ONE RED ROPE CONTAINI1 vibrator, 3 buttplugs, 1 set of cuffs, 1 dad°, 1 leash, i box of condoms, i nurse cap
(U) ONE RED ROPE CONTAINING; (1) butt plug
(U) One box containing four (4) framed photos of naked females.
(U) ONE CELLOPHANE CONTAINING: 1 set of copper handcuffs and whip
(U) One (1) green massage table.
(U) One cellophane containing:3 sheets of paper- (1) photo depicting two girls, (2) cash disbursements
EFTA01684473
(U) One cellophane containing:3 pages- (1) handwritten note Epstein letterhead, (2) page typed letter
(U) One flat FedEx box containing: 3 photographs- (2) depicting Epstein with two females, (1) photo depicting two
(U) One red rope containing: 3 sheets of paper depicting photographs of a living room
(U) One cellophane containing: 2-page handwritten lette
(U) Box containing one (1) set of Blueprints for residence 9 East 71st Street, New York, New York Stamped receive
(U) ONE RED ROPE CONTAINING: 1 Red Notebook
(U) ONE RED ROPE CONTAINING: 10 Photographs
(U) ONE RED ROPE CONTAINING: 17 Miscellaneous Financial Documents
(U) ONE RED ROPE CONTAINING: 1 Premier Day Planner
EFTA01684474
EFTA01684475
envelopes containing $17,115 UK (152 x $100, 35 x $50 4 x $20, 6 x $10, 5 x $5).
EFTA01684476
EFTA01684477
EFTA01684478
Evidence Report for Case: 1500-NY-3027571
Filtering on: Type(s): 1D
Item # Collected On
1D6 8/24/2020 7:00
IDS 8/3/2020 9:25
1D4 5/7/2020 7:00
1D3 4/18/2020 7:00
1D2 2/4/2020 7:00
1D1 8/20/2019 17:00
EFTA01684479
Description
(U) (NY-ERF#19236) Court Authorized Intercept Doc# 20-CRIM-1281832Facile3lu-Ray Disc# 7446!
(U) 07/02/2020; One (1) original SD card and one (1) Blu Ray containing FLIR aerial surveillance footage of Bradfoi
(U) (NY-ERF#18399) Court Authorized Intercept-Doc#20-CRIM-21340Facill i isc#690612-R1
(U) (NY-ERF# 18727) Court Authorized Intercept Doc#20-CRIM-81211Fadlits 3lu-Ray Disc#694397
(U) (NY-ERRS 18309) Court Authorized Intercept Doc# 19-CRIM-2984S1S6Facilier)isc# 671455
(U) Recorded Interview (Non-Custodial - Overt) DTD 8/13/2019 with (REDACTED) - Philadelphia
EFTA01684480
5
d, NH on the aforementioned date.
EFTA01684481
Evidence Report for Case: 50D-NY-3027571
Filtering on: 1A
Type g Acquired On Serial g
1A 317 2025-03-10 706
1A ilfi 2025-03-10 225
1A al 2025-03-10 706
1A 314 2025-02-27 704
1A 313 2024-08-01 702
1A 312 2022-11-02 696
1A 311 2022-05-26 692
1A 310 2022-03-07 687
1A 309 2021-12-11 686
1A Eli 2021-11-24 Q14
1A Igi 2021-11-22 ila
1A 306 2021-11.23 677
1A 305 2021-11-05 674
1A 304 2021-10-19 672
1A 303 2021-11-02 671
1A 302 2021-10-11 670
lA 301 2021-10-14 669
1A 3Q2 2021-06-23 02
lA Z9.2 2021-10-08 01
lA 298 2021-10-08 665
1A 297 2021-10-08 665
lA 336 2021-10-08 §61
lA 295 2021-10-08 665
1A 294 2021-10-08 664
lA 293 2021-10-08 663
1A 292 2021-10-08 662
lA Z91. 2021-10-08 01
1A 290 2021-10-08 660
lA 289 2021-10-08 659
lA 221 2021-10-08 552
1A 287 2021-06-23 657
lA 286 2021-10-07 657
Lk 285 2021-10-07 656
lA 294 2021-09-02 653
Lk 214 2021-09-17 ga
lA 282 2021-05-18 651
1A 281 2021-09-20 650
lA 224 2021-09-20 552
1A Z7_2 2021-05-20 M./
1A 278 2021-09-27 6413
1A 277 2021-08-19 647
1A 276 2021-07-23 646
1A 275 2021-07-23 646
EFTA01684482
LA 274 2021-09-21 645
IA 273 2021-09-01 643
m M 2021-09-01 a
IA M 2021-06-02 442
1A 270 2021-06-02 642
lA 2.62 2021-04-27 al
1A M 2021-08-20 aQ
1A 267 2021-08-12 639
LA 266 2021-08-19 638
1A 265 2021-05-14 637
LA 264 2021-05-14 637
lA 263 2021-09-02 636
lA 262 2021-08-30 635
lA ai 2021-08-31 04
1A 102 2021-09-15 01
1A 259 2021-09-02 632
1A 258 2021-09-02 632
1A M 2021-09-02 632
1A 256 2021-09-08 632
1A 255 2021-07-27 631
1A 254 2021-08-11 630
lA 334 2021-09-14 412
lA M 2021-04-01 421
lA 251 2020-11-30 627
1A 250 2021-06-30 626
lA 242 2021-06-30 42k
lA 248 2021-08-04 624
LA 247 2021-06-28 623
lA 246 2021-06-23 623
LA 245 2021-06-23 623
lA 244 2021-03-23 M
1A 243 2021-07-06 616
lA 242 2021-07-14 615
1A 241 2021-07-14 41E
1A 240 2020-02-14 613
lA 239 2021-06-29 610
LA 238 2021-05-20 607
IA 237 2021-04-13 605
LA 231 2021-04-13 445
lA 235 2021-04-01 604
1A 234 2021-03-30 603
lA M 2021-05-17 W.2
1A M 2021-03-19 596
1A 231 2021-01-29 588
1A 230 2021-03-03 586
1A 229 2021-03-03 586
1A 228 2021-01-21 585
EFTA01684483
1A 227 2021-01-21 585
lA 226 2021-01-19 584
1A al 2021-02-24 512
IA 224 2021-02-11 522
1A 223 2021-02-08 581
lA 222 2020-10-14 514
1A 221 2020-10-15 551)
1A 220 2020-10-14 580
Lk 219 2021-01-27 579
1A 218 2021-02-01 578
Lk 217 2021-01-20 573
lA 216 2021-01-14 M
lA 215 2020-09-25 571
lA j4 2021-02-02 5Z4
1A 211 2021-01-12 55.2
1A 212 2020-10-28 568
1A 211 2021-01-27 567
1A 210 2020-02-07 566
1A 209 2020-10-07 566
Lk 208 2021-01-13 565
1A 207 2020-09-10 564
M 20 2020-10-09 511
m na 2021-01-19 55.4
lA 204 2020-10-15 556
1A 203 2020-11-04 555
1A zu 2020-10-29 54
1A 201 2020-08-13 552
Lk 200 2020-06-19 551
lA 199 2020-08-21 550
Lk 198 2020-08-22 549
lA 122 2020-08-21 54
1A 191 2020-10-09 522
1A 195 2020-08-17 546
1A 191 2020-10-09 5_41
IA al 2020-08-21 543
lA 192 2020-11-18 542
Lk 191 2020-08-24 541
lA 190 2020-10-21 535
lA 182 2020-10-22 1.1E
lA 188 2020-10-09 535
1A 187 2020-06-19 533
lA iik 2020-08-26 521
1A 111 2020-08-19 513
1A 184 2020-08-11 512
1A 183 2020-08-12 511
1A 182 2020-07-17 500
1A 181 2020-07-07 499
EFTA01684484
IA 180 2020-07-15 496
IA 179 2020-07-15 495
IA 01 2020-07-27 al
IA 177 2020-08-04 ga
1A 176 2020-07-28 478
1A iza 2020-07-28 AZ1
1A Ili 2020-07-28 171
1A M 2020-07-28 477
1A 172 2020-07-28 476
1A 171 2020-07-28 476
Lk 170 2020-07-27 475
1A 169 2020-07-21 469
1A 168 2020-07-14 468
1A ifiZ 2020-07-02 422
1A 10 2020-07-02 0/
1A 165 2020-07-08 450
1A 164 2020-07-13 449
1A .aa 2020-07-13 445
1A 162 2020-07-11 443
1A 161 2020-07-10 442
ia 160 2020-07-10 440
m 152 2020-07-10 02
IA 154 2020-06-19 0¢
IA 157 2020-07-06 433
1A 156 2020-06-25 428
1A 1 2020-07-07 422
1A 154 2020-07-02 412
1A 153 2019-07-17 405
1A 152 2019-10-25 404
Lk 151 2020-03-04 403
IA IN 2020-04-10 222
1A a2 2020-02-07 398
IA 148 2020-02-07 398
1A 142 2019-07-22 222
IA 146 2019-11-21 221
IA 145 2019-09-18 395
Lk 144 2019-10-23 394
IA 143 2019-10-23 393
Lk 142 2019-09-12 Ra
IA 141 2019.08-26 391
1A 140 2019-10-18 390
IA 122 2019-10-18 222
1A 121 2019-09-12 212
1A 137 2020-02-28 388
1A 136 2019-10-23 387
1A 135 2020-02-26 386
1A 134 2019-10-24 385
EFTA01684485
LA 133 2019-10-24 385
IA 132 2019-12-04 384
1A at 2019-11-26 iga
IA 1.12 2019-10-11 18/
1A 3.29 2020-02-05 380
1A 12 2019-11-04 222
1A 127 2020-02-05 221
1A 126 2020-02-27 377
LA 125 2019-08-13 376
1A 124 2019.08-13 376
1A 123 2020-02-05 375
1A 122 2020-01-14 M
1A 121 2019-09-10 373
1A ii& 2020-02-19 2Z2
1A 112 2020-01-16 212
1A 118 2019-12-17 366
1A 117 2019-07-26 365
1A 116 2019-07-26 311
1A lis 2019-12-15 359
1A 114 2019-12-15 359
lA 113 2019-12-15 359
1A 112 2020-01-17 35fi
IA M 2020-01-08 255
la 110 2019-08-28 354
1A 109 2019.09-18 353
lA 141 2019-10-23 252
IA 107 2019.09-09 351
LA 106 2019-11-01 350
lA 105 2019-09-18 349
LA 104 2019-08-09 241
lA 142 2019-08-12 342
1A 102 2019-08-12 3_
lA 101 2019.08-28 345
1A LW 2019-08-01 294
IA 99 2020-01-08
IA 98 2019-12-30 343
LA 97 2019-12-30 343
IA 96 2019-12-02 343
LA 25 2019-10-01 ma
lA 94 2019-10-15 340
1A 93 2019-12-17 339
LA 22 2019-12-17 221
1A a 2019.09-19 225
1A 90 2019-10-16 334
1A 89 2019-10-16 333
1A 88 2019-10-15 332
1A 87 2019-09-18 330
EFTA01684486
LA 86 2019-09-19 329
IA 85 2019-11-14 327
1A m 2019-09-28 la
LA 12 2019-07-31 3_U
1A 82 2019-07-12 324
1A Al 2019-11-13 222
1A a 2019.08-28 316
1A 79 2019.08-27 315
1A 78 2019-08-29 306
1A 77 2019.08-29 306
LA 76 2019-08-06 304
1A 75 2019.09-24 303
1A 74 2019-07-05 300
1A Z2 2019-08-27 22A
1A 3 2019-07-11 2E
1A 71 2019-07-12 296
1A 70 2019-08-13 294
1A 4.2 2019.09-16 289
1A 68 2019-07-12 286
1A 67 2019-09-05 285
1A 66 2019.09-05 283
1A c..a 2019.09-14 /$1.
1A 14 2019.08-13 M
1A 63 2019.08-24 272
1A 62 2019.08-28 271
1A 11 2019.08-27 222
1A 60 2019.08-13 269
1A 59 2019-08-12 268
1A 58 2019.08-12 268
1A 57 2019-08-12 268
lA a 2019-08-12 ag
1A 55 2019-08-12 268
lA 54 2019.08-11 268
1A 42 2019-08-20 214
IA 52 2019.08-13 261
IA 51 2019-08-28 258
LA 50 2019-08-27 257
IA 49 2019-08-07 252
LA 4O 2019-07-11 241
lA 47 2019.08-16 238
1A 46 2019-07-24 216
1A 41 2019-08-09 224
1A 44 2019-07-29 212
1A 43 2019-07-31 208
1A 42 2019-07-31 207
1A 41 2019.08-02 206
1A 40 2019-07-11 203
EFTA01684487
IA 39 2019-07-11 202
IA 38 2019-07-06 194
1A n 2019-07-17 1N
IA 33 2019-07-13 MA
1A 35 2019-07-13 187
1A 24 2019-07-14 IN
1A 22 2019-07-11 185
1A 32 2019-07-02 183
1A 31 2019-07-16 175
IA 30 2019-07-17 171
1A 29 2019-07-06 168
1A 22 2019-07-12 166
1A 27 2019-07-19 159
1A a 2019-07-17 155
1A 25 2019-07-17 2.51
1A 24 2019-07-11 151
1A 23 2019-07-06 150
1A 22 2019-07-07 149
1A 21 2019-07-12 127
1A 20 2019-07-11 116
ia 19 2019-05-29 106
m La 2019-07-06 5/
IA 17 2019-07-08 /2
IA 16 2019.06-24 30
1A 15 2019-05-29 26
1A 14 2019-05-08 25
1A 13 2019-05-23 24
1A 12 2019-05-02 21
1A 11 2019.04-24 20
1A 14 2019-04-26 19
IA 2 2019-04-11 17
1A 3 2019-03-22 16
lA 7 2019-03-22 14
1A 3 2019-03-20 13
1A 5 2019-03-19 12
IA 4 2019-03-25 11
IA 3 2019-03-19 10
IA 2 2019-03-04 8
IA 1 2019-01-30 5
EFTA01684488
Serial Title
(U) Transport of Evidence Items 16136, 16144, 16145, and 1B146
(U) Transport of Evidence Items 1B136, 16144, 16145, and 16146
(U) Transport of Evidence Items 16136, 16144, 16145, and 1B146
(U) Transfer of Case Documents from the New York Field Office to the Washington Field Office
(U) Interview o
(U//FOUO) Identification o s a possible associate of JEFFREY EPSTEIN
(U) Mail Received from Epstein Residence
(U) Phone Interview wit
(U) Defense Notes fo
(U) Telephonic Interview o
(U) Telephonic interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Phone conversation wit
(U) Call wit
(U) Reimbursement of expenses incurred for trial
(U) Reimbursement of expenses incurred for trial
(U) Interview o
(U) Materials from Palm Beach Police Department
(U) Materials from Palm Beach Police Department
(U) Materials from Palm Beach Police Department
(U) Materials from Palm Beach Police Department
U//FOUO NTOC2021 E-Tip Additional Victim Reports Being Human Trafficked By Gislaine Maxwell M A Child (7
U NTOC2020 352mtr01Information on a Possible Accountant of Jeffrey Epstein. (NY)
U//FOUO NTOC2020 024srm01 E-Tip: Possible Human Trafficking in New York, NY. (NY)
U USPS Mail Tipster - Information Related to Jeffrey Epstein/Unnamed 29 YOA Jewish Female
U NTOC2020 195hmb02 Potential Sex Trafficking bin. n New York, NY (NY)
U Email regarding information for sale about the Epstein Zorro Ranch
U//FOUO NTOC2021Conceming Comments (NY)
(U) Reimbursement of expenses incurred for trial
(U) Reimbursement of expenses incurred for trial
(U) Fed-Ex Delivery Confirmation
(U) Interview o September 2, 2021
(U) Meeting wit
(U) Interview o
(U) interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) interview o
(U) Proffer o
(U) Proffer o
EFTA01684489
(U) Service of subpoena.
(U) Interview o September 1, 2021
(U) Interview o September 1, 2021
(U) Interview o
(U) Interview o
(U) Interview/Proffer o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Proffer o
(U) Proffer o
(U) Interview o
(U) Interview o August 30, 2021
(U) Interview o August 31, 2021
(U) Request to serve three trial subpoenas
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o July 27, 2021
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U nterview 8/4/2021
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Locate and Serve witne
(U) Missouri Birth Certificate Identified and obtained
(U) Missouri Birth Certificate Identified and obtained
(U) Device Extraction - MDUS 13768
(U//FOUO) Collection of evidence in Austin, Texas
(U) IA Lab Report Material: Lab # 2021-00585
(U) Interview o
(U) Interview o
(U) Interview o
(U) Introductory conversation wit
(U) 2021-00585-2 Questioned Documents
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) interview o Day 3
EFTA01684490
(U) Interview o Day 3
(U) Interview o Day 1
(U) Interview o
(U) Virtual Interview o
(U) Telephonic Interview •
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Introductory Conversation wit
(U) Interview o Day 2
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Proffer o
(U) Interview/Proffer o
(U) Interview/Proffer o
(U) Interview o
(U) Interview o
(U) Interview o
atdf
(t
(U) Call received fro
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Victim Services Division - Case Support Unit Assistance
(U) Interview o
(U) Fund Reimbursement - Five 2TB Hard drives
(U) Fund Reimbursement - Five 2TB Hard drives
(U) Fund Reimbursement - Five 2TB Hard drives
(U) Fund Reimbursement - 12 TB External Hard Drive
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
EFTA01684491
(U) Interview o
(U) Interview o
(U//FOU0) Interview o
(U//FOU0) Interview o
(U) Lead Request to Serve grand jury subpoen
(U) Lead Request to Serve grand Jury subpoen
(U) Lead Request to Serve grand jury subpoen
(U) Lead Request to Serve grand jury subpoen
(U) Lead Request to Serve grand Jury subpoen
(U) Lead Request to Serve grand jury subpoen
(U) Date Submitted: 07/25/2020 10:08:31AM ET Transaction Number: 4D291278-3SFF-489A-A26C
(U) On 07/21/2020, at 2:17 a.m. Eastern lime date of birtl
(U//FOUO) Telephone Interview 0
(U) Arrest of GHISLAINE MAXWELL
(U) Arrest of GHISLAINE MAXWELL
(U//FOUO) Impersonation of FBI Agent
(U//FOUO) Interview o
(U) On 07/12/2020, at 3:12:08 PM Eastern Time date of birti
(U) On 07/11/2020, at 10:02 a.m. Eastern Time, an anonymous tipster, Internet Protocol
(U) On 07/09/2020, at 9:47 p.m. Eastern lime email addres
(U) On 07/10/2020, at 9:44 a.m. Eastern Time, an anonymous tipster, Internet Protocol (IP
(U) On 07/10/2020, at 9:22 a.m. Eastern Time, an anonymous tipster, Internet Protocol (IP
(U) Fund Reimbursement
(U) On 07/06/2020, at 10:19 AM Eastern Time, the FBI Office of Public Affairs (OPA)
(U//FOUO) Aerial photos o
(U) On 07/06/2020, at 12:33:51PM Eastern Time, an anonymous complainant, Email account
(U//FOUO) Interview o
(U) Information provided b
(U) Interview o •n 10/25/19
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o • n 11.21.19
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
EFTA01684492
(U) Interview o
(U) Proffer o nterview #2
(U) Proffer o nterview #1
(U) Interview o • n 10/11/2019
(U) Pass information to Swedish authorities for informational purposes.
(U) Interview o
(U) Share information with Swedish Authorities
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Proffer o
(U) Interview o
(U) Interview o
(U) Interview o 2/17/2019
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Epstein Breifing EVAF Expenditures
(U) Phone conversation wit
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Phone call with Attornet
(U) Interview o
U nterview
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Epstein Breifing EVAF Expenditures
(U) Epstein Brelfing EVAF Expenditures
(U) Epstein Breifing EVAF Expenditures
(U) Epstein Brelfing EVAF Expenditures
(U) Epstein Breifing EVAF Expenditures
(U) Interview o
(U) Emergency Victim Funds and Budget Matters, Office of the Director
(U) Emergency Victim Funds and Budget Matters, Office of the Director
(U nterview
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview .
EFTA01684493
(U) Interview o • n 9/19/2019
(U) Interview o • n 11/14/2019
(U) Interview o
(U) Interview o • n 7/31/19
(U) Proffer o nterview #1
(U) Victim Services Division - Victim Meeting
(U) Interview o
(U nterview
(U) Lead Forwared to Legat Mexico City, Mexico
(U) Lead Forwared to Legat Mexico City, Mexico
(U) Interview o
(U) Emergency Victim Funds and Budget Matters, Office of the Director
(U) Interview •
(U nterview
(U) Interview •
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Device Unlock and Extraction - MDUS 10398
(U) Device Unlock and Extraction - MDUS 10399
(U) On 09/14/2019, at 2:58 p.m. Eastern lime date of birti
(U) Interview o
(U) FBI New York - Jeffrey Epstein - Child Sex Trafficking - 190904-175728
(U) Follow-Up Law Enforcement Inquiries Pertaining t •
(U) Interview •
(U
(U) Search Warrant Execution
(U) Search Warrant Execution
(U) Search Warrant Execution
(U) Search Warrant Execution
(U) Search Warrant Execution
(U) Search Warrant Execution
(U//FOU0 PROTECT SOURCE) interview #3
(U) Phone Interview o
financial connection to JEFFREY EPSTEIN
U NTOC2019 1971(103 E-Tip: Information Regarding Multiple Criminal Allegations such as Human Sex Traffi
(U//FOUO PROTECT SOURCE) interview #2
(U) Inventory of Two Suite Cases (black/blue) for JEFFREY EPSTEIN
(U) On 8/15/19, at 11:15 a.m. Eastern Time, the FBI Office of Public Affairs (OPA)
(U//FOUO PROTECT SOURCE) Interview One
(U) On 08/08/2019, at 9:02 a.m. Eastern lime date of bin
(U) Interview
(U) Interview o
(U) Interview
(U) Return of Property t • • n 08/02/2019
(U) Interview •
EFTA01684494
(U) Interview o • n 07/11/2019
(U) Post Arrest Spontaneous Utterances made by Defendant JFFREY E. EPSTEIN
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Interview o
(U) Arrest of JEFFREY EPSTEIN
(U) Jeffrey Epstein
(U) Interview •
(U) Interivew o
(U) Interview o • n 07/15/2019
(U) Provide information to SEATTLE FO for conducting interview
(U) On 07/17/2019, at 3:43 p.m. Eastern Time, the FBI's Office of Public Affairs (OPA)
(U) On 07/17/2019, at 3:51p.m. Eastern Time, the FBI Office of Public Affairs (OPA)
(U) Search Warrant Executed- 9 East 71st Street, New York, New York 10021
(U) Interivew o
(U) Attempted Interview of GHISLAINE MAXWELL
(U//FOUO) On 07/11/2019, at 10:56 p.m. Eastern Time, tipster email addre
(U) On 07/11/2019, at 2:31a.m., Eastern Time, the FBI Office of Public Affairs (OPA)
(U) Interview o • n 5/29/2019
(U) Search Warrant Executed- 9 East 71st Street, New York, New York 10021
(U//FOUO) On 07/08/2019, at 1:10 P.M. Eastern Standard Time, the Office of Public Affairs
(U) 31E-NY-3027571
(U) Interview o • n 5/29/2019
(U) Interview o • n 5/8/2019
(U) Interview o
(U) Interview o • n 5/2/2019
(U) Interview o
(U//FOUO) TECS Silent Hit Notification
(U) Interview o
(U) Interview o
(U) interview o
(U) Interview o
(U) Interview o
(U) Interview •
(U) Interview o
(U) Interview o
(U) Interview o
EFTA01684495
Summary
(U) Chains of Custody
(U) Ending Transport Photographs
(U) Starting Transport Photographs
(U) Photos and Photo Logs
(U) Agent Notes
(U//FOUO) Email fro nd attachments from=
(U) letter from former Epstein Estate; fake NY State Driver's license
(U nterview notes
(U//FOUO) Defense notes fo
(U nterview notes
(U nterview notes
(U) interview notes
(U) digital notes
(U) Digital notes, household manual
(U) Notes
(U em otes
(U) 794
(U) Receipt
(UMiterview notes
(U) Property receipt
(U) Trash pull
(U) Digital case files
(U) Subpoena
U 755162_NY
U 696289_NY
U 708478_NY
U 664501_NY
U 658904_NY
U 603998_NY
U 751864_NY
(U) Receipt
(U) FD-794
(U) Fed-Ex Delivery Confirmation, #1864 0967 1500
(UMterview notes - 9.2.21& Scan shown tcM
(U) Notes
(U) notes & doncuments
(U) Emails fro
(U nterview notes
(U) Notes
(U) Notes
(U) Notes
(U) Documents shown t.
(U nterview notes
EFTA01684496
(U) Drivers license information for each individual.
(U) News article shown t.
(U) Notes
(U) Documents shown t.
(U nterview notes
(U nterview notes
(U) Notes
(U) Notes
(U) Notes
(U nterview notes
(U) Documents shown t
(U) Notes
(U) Notes
(U) Notes
(U) Trial Subpoenas
(U) photobook
(U) Nude photo o
(U) Items shown touring Interview
(U) Notes
(U nterview notes
(U) Notes
(U) notes
(U) Notes
(U) Notes
(U) Messages pads
(U) notes
(U) Notes
(U) Transcript
(U) Epstein phone contact
(U) Notes
(U) Notes
(U) Trial Subpoena
(U) Copy of FedEx shipment with tracking number 774263190664
( ertified Birth Certificate
(U) Legal Authority for Device
(U//FOUO) FD-597
(U) Lab # 2021-00585:1 disk
(U) Photo provided be
(U nterview notes
(U nterview notes
(U otes
(U) 2021-00585-2 QUESTIONED DOCUMENTS
a nterview notes
(U) Interview Notes
(U) Interview notes
(U) Photographs provided via email b
(U) Photo from Myspace account
EFTA01684497
(U) Interview notes day 3
(U) Interview notes day 1
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Emails
(U) Statement referenced in interview
(U) Interview notes
(U) Interview notes
(U) Notes
(U) Interview notes day 2
(U) Interview Notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Rodgers flight log
(U) interview notes
(U nterview notes
(U) Interview notes
(U) Interview notes
(U involvement in U.S. Presidential pardon petitions and influences from Russia and Israel on Pres
(U) notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U uterview notes
(U) Latest contact information tracked and updated by ODAG partners.
(U) Interview notes
(U) 10.21HD Receipt
(U) 10.22 HD Receipt
(U) 10.9 HD Receipt
(U) Receipt
(U) Interview notes
(U) Interview Notes
(U) Interview notes
(U) Interview notes
(U nterview notes
(U) Interview notes
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(U) Interview notes
(U) Interview notes
(U//FOUO) Notes Re: Interview • • n July 27, 2020.
(U//FOUO) City of Maricopa Police Department Officer Report fo '00722037
(U) Subpoena
(U) Accurint
(U) Subpoena
(U) Accurint
(U) Subpeona
(U) Accurint
(U) (U//FOUO) THE INFORMATION CONTAINED HEREIN HAS BEEN DETERMINED BY THE FBI TO BE PERTINEN
(U) Screenshot of Reddit post by us
(UHFOUO) NYPD SVD Hotline Worksheet
(U) Photo
(U) Arrest warrant, arrest paperwork, notes
(U//FOUO) Document and audio recording from Bradford (NH) Police
(U//FOUO) Interview notes o
(U) Graphic Capture of Viral Video.
(U) screenshot o • uora page
(U) Screenshots of Epstein's alleged employee's confession on YouTube and 4chan
(U) Website www.kidsquest.com
(U) Screenshots from kidsquest.com
(U) Receipt
(U) Reported Tweets to NTOC
(U//FOUO) Aerial photos o
(U) Screen shot of lmgur capture of the comment made b
(U//FOUO) Notes fro
(U) Photographs provided b
(U nterview notes
(U) Interview notes & documents provided al
(U nterview notes
(U) Flight logs
(U) Rodgers interview notes
nterview notes
(U nterview notes
(U nterview notes
(U terview notes
(U nterview notes
(U nterview notes
(U terview notes
(U) Two boxes of papers and media from PBPD
(U) Interview Notes
(U) Interview notes
(U) Interview Notes
(U) Interview Notes & police report
(U) Interview notes
(U) Photo provided b nd her attorneys
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(U) Interview notes
(U nterview notes
(U) interview notes
(U nterview notes
(U :02
(U) Interview Notes
(U :02
(U nterview notes
(U) Photo Book
(U) Interview notes
(U) Interview notes
(U nterview notes
(U) Interview notes and Message pad copies shown
(U terview notes
(U) Interview notes
(U) Interview notes
(U) Facebook Profile Screenshots
(U nterview notes
(U) Photos
(U) Emails
(U) Interview notes
(U W Hotel charges, approval to accept charge, and proof of refund.
(UM•hone call notes
(U nterview notes
(U nterview notes
(U) Interview Notes
(U) Interview notes
(U) Interview notes
notes
(U) Interview Notes
(U nterview notes
(U nterview notes
(U nterview notes
(U nterview notes
(U .odging
(U odging
(U ging
(U elmbursement
(U) Receipts of EVAF Expenditures for Epstein Victims
(U) Interview Notes
(U) Receipts
(U) Receipts
(U) Interview notes
(U) Interview Notes
(U) Interview Notes
(U) Interview Notes
(U) Interview notes
EFTA01684500
(U nterview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes and photos provided b
(U) Interview notes
(U) RSVP/potential victim list, templates, reminders and overviews
(U) interview notes
(U) Interview notes
(U) VA DMV image
(U) DMV Images o A an' IA. TLO reports concemin: .
(U) Interview notes
(U) Receipts
(U rand Jury Subpoena
(U) Interview Notes
(U) Interview notes
(U) interview notes
(U
(U) Interview Notes
(U) Interview notes
(U) Administrative Documents
(U) Administrative Documents
(U) Screenshot of YouTube Video
(U) Interview notes
(U) Enclosed are the IC3 complaints
(U) Police Records from Cranston RI Police Department
(U) Interview Notes
(U) Interview notes
(U) Receipt for Property (FD-597)
( n' wit Building 6, Search Paperwork
Search Paperwork
alearch Paperwork
(U) Evidence Log, Sign-In Log, map, notes
(U) Search Warran
(U//FOUO) Interview Notes
(U) Interview Notes
U 579223 CV
U 566318 PH
(U//FOUO) Interview Notes, images provided
(U) two (2) property receipts, one (1) inventory log, 1 (one) ERT photographic log and one CD with photograi
(U) Twitter screenshots of the links provided.
(U//FOUO) Interview Notes and photograph of "Jeff"
(U CIC
(U) Notes
(U) Notes
(U) Notes
(U) (1) DVD of photos, (2) original signed receipt for property forms FD-597, (1) business card
(U) ori final handwritten notes o nterview on 07/11/2019
EFTA01684501
(U) copy of Handwritten contact information fo his attome and property
(U) Photocopy of working folder pertaining to arrest paperwork of JEFFREY E. EPSTEIN
(U) Interview notes
(U) Interview Notes
(U) Interview Notes
(U) Interview Notes
(U) Interview Notes
(U) Epstein arrest warrant
(U) Arrest paperwork, search warrant, photographs disc
(U//FOUO) Interview Note /17/2019
(U dentification
(U) Original Handwritten Interview Notes c •n 07/12/2019
(U) TLO report and WASHINGTON STATE DL image of potential victim to be interviewed.
(U) Twitter screenshots
(U) Twitter Post.
(U) Search warrant execution log, FBI Sign in log, Evidence Collected item log, copy of search warrant, (1) FD
(U otes
(U) Documents from UPS
(U) Attachments from tipster.
(U) twitter screenshot
(UM nterview notes
(U) original search logs, copy of search warrant, (1) signed FD-597, (1) DVD disk of Search photos
(U//FOLIO) Twitter Usernam
(U) Fed-EX signature confirmation page.
WM nterview notes 5.29.19
(U) Interview notes 5/8/19
(U) Interview notes
(U) Interview notes 5.2.19, Photos 1 through 19 and A through F
anterview Notes
(U//FOUO) TEES silent hit entered
(U interview notes
( nterview notes
a nterview notes
(U nterview notes
(Unterview Notes
(U nterview notes
(U nterview notes
(U) Interview notes
(U) Interview notes
EFTA01684502
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p 2021-00585-2 IA.4 CASE COMMUNICATION LOG: Con
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1TO & WITHIN THE SCOPE OF AN AUTHORIZED LAW ENFORCEMENT ACTIVITY & SHOULD BE CONSIDERI
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EFTA01684510
tmunicadonLog2021-00585.pdf CASE NOTE INTERFACE REPORT: CNI Questioned Documents (AF)
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,ED IN THE CONTEXT OF THE ASSESSMENT OR PREDICATED INVESTIGATION TO WHICH THE INFORMATI0
EFTA01684513
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EFTA01684517
ase Note (143683).p CASE FILES: 2021-00585 #1, Lead 17.pdf 2021-00585 Shipping Invoice C
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N RELATES. PARTICULAR ATTENTION SHOULD BE GIVEN TO THE AUTHORIZED PURPOSE FOR COLLECTIN
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EFTA01684522
EFTA01684523
EFTA01684524
ntainer C.pdf 2021-00585 #1 LER, Seria 575.pdf 2021-00585 Shipping Invoice Container B.p
EFTA01684525
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5 & RECORDING THIS INFORMATION PURSUANT TO THE ATTORNEY GENERAL'S GUIDELINES FOR DOME
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EFTA01684529
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if 2021-00585 Al Check-In Notes.rtf CASE CHAIN OF CUSTODY: Chain0Kustody2021-005854
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'TIC FBI OPERATIONS & THE DOMESTIC INVESTIGATION & OPERATIONS GUIDE. THAT PURPOSE MAY BE
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EFTA01684538
df CASE RECORD REPORT: CaseReport2021-00585 Record #2.pdf CASE COMMUNICATION LOG FIL
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SET FORTH IN THE FILE'S OPENING ELECTRONIC COMMUNICATION OR OTHER
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Jeffrey Epstein
31E-NY-3027571
ranplafee
Unknown/She was directly responsible for wrong pith
but *least 10 gkis state she Is the dire* point d contact Unknottin a she actually restated or abused
fat sdneddeg Its massage WPOlitnerds In West Pr a. any of We victims. Was said to have been
Beach and New York Ott. *deers was also ki char of one of Epshin's NYC meats and
ayeeting the girls a Ms A. and NY residences, making responsible for manning massage
them fed comfottable ad welcome, offeting Mere food, appolribnents. Nay have on 1.2 maids*
bringing then Ito the masrow nun and giving than paid victims at the Madsen Avenue office for
hsbudions, and then Stan parting them aftemmds. the massages. Unknown If she was ever
bides was also Epstelmes personal bud asskizet aid preset at any of Epstelnis homes.
fleet with Nen a over the world. She was the dyed
Th o
supersikor to and Unburied her to rowing.
massage , and destroy evidence during the tlrlhied
Palm Bead investigation into Epstekts conduct. At last 1
SIM stabs thailM on venal abused her dale° a
massage wed Epstein.
2 *We
Unknown if the adze* recruited or
abused any of the victims. 1Vm
rumored to be EpstelnY "sex slave'
aid victims often &sated tannins
fitting her disaiption as being
bathed in the SOWS abuse during
Ovate property manager brad Epstdn's these massages. Teaseled with
property's. Was observed by a property Multiple stems state
= war the mat
ma
(Ainown a she refs drecdy responsible for Epstein ail over the meld.
manager to have pointd phone based
remitting girls bit admits during a proffer
massage appointments. themes raga
she was trained by to schedge R.
and NY massage appoirommis S Epstein.
-nos made to ;edam manage. an
Sremds
girls Mat spider web into that
weer dscussed (Wig the vs
aamintnurit phone at but Wings midi as
oripind Palm Beath tenestIttifiadar schod or perels were often bra** up. On
Epstein at hiSte Island. Ross vim
Its Name. may have been physic* at least 2 oomslons stems Mewl Mt
insluded by I= to regime tans from
inched in some d the abuse that occurred nos the one to pay them at It Madison
Ns Palm Beach home and Virgin Wand home
diming these massages, but has not personal Avenue office building Unthawed she
and have them destroyed during the Palm
attuned* At this tins no violins have actually matted cc abused any of the
Bead) inveotigcbcin. taknowe If she Sealy
*dams. Unicoovin if she was me* preset at
recruited or abused any d the as.
any of Enda homes.
EFTA01699908
A
VICTIM WITNESS
DOB
1 ane Doe Jane Doe #2 aneDoe #3 Jane Doe #4 Jane-Doe #6 Jane Doe #6
AGE AT FIRST 15 14 15 15 17 16
2 CONTACT
HIGH SCHOOL Palm Beach Central HS 9th Grade - Lake Worth HS Royal Palm Beach HS Royal Palm Beach HS
and John I. Leonard HS
3
BROUGHT BY Ghislaine Maxwell
4
DATES OF Approx: 1999 2001 - 7/2004 4/25/2004 - 10/06/2005
• CONTACT! SOURCE Testimony Testimony/Message elephone
Pad
5
GIRLS RECRUITED Ind unidentified -nd
ma es ages 15 - 25. (20-21yoa) Paid $200.00
maybe 3I each by SK
6 girls
NUMBER OF Multiple Unknown, multiple times Approx. 10-15 1 Less than 10 times but
MASSAGES more than five.
7 -.—.... ____ ._ . ._ _ . . . ..
ENTICEMENT
8 Title •I8 USC 2422(14
Interstate Commerce Telephone Records Telephone Records i Telephone Records Telephone Records
Connection
9
Under 18 at time of YES - 17 YES -14 YES -15 YES - 15 YES -17 YES -16
sexual activity
10
Advised if asked to as YES/ NU YES - YES -_.advised In
state they were over a vise o say she that she would make
18/Advised by was 17 by $200.00, to dress cute, JE
whom? might touch her, and to
tell JE if she was
uncomfortable and JE
11 would stop.
EFTA01699909
A B
VICTIM WITNESS
DOB
1 Jane Doe fil Jane Doe 1/2 ane Doe ' Jane Doe #4 Jane Doe #5 Jane Doe #6
Knowledge or ________ • tein asked JE askedMi er age. ili p- old JE she IN told JE she was 18 told JE she was a
Discussion of Age
with JE?
er age and she • stated that she
uttered "four" and then insisted that she was 18.
said 17. Epstein
was 18. but she said that she
thought he knew better.
Junior at Royal Palm
Beach High School.
told JE that she and
al
responded by saying, were good friends and .
"so you are E• I - - i I' went to same school and
JE also told in same class.. and JE
they would no e discussed Mak of girls
anyone. • frdshp. I. said was
worried b/c she had
mentioned prom to JE.)
12
Payment for YES/$200.00-500.00 YES/$200.00 YES/$200.00 YES/$200.00 YES/$200.00
services?/Amount
13
Payment for $100.00 per girl $200.00 per girl Epstein offered $200.00 per girl $200.00 per girl
14 recruitment $300.00 to brio
Payments made by Epstein Epstein- Epstein Epstein Epstein and
15
Taken upstairs by NU LNU (possibly
16
Clothing worn during Bra and underwear, Topless, one time Nude. Topless and Nude. Nude Bra and Underwear, and
massage topless and nude. topless.
17
EFTA01699910
A I B I C D I E F I G
VICTIM WITNESS
DOB
1 Jane Doe #1 Jane ,Doe Jane 'Doe #4 Jane Doe #5 Jane Doe #6
--
Sexual activity at • observed JE would rub his chest. JE requested Performed massages in JE pulled bra down
age 17 (observed by engage in stated that JE never to rub his chest and nipples. the nude. would not and
IMI • .
old female. JE asked her to rub his chest while she
introduced an cted nipples massaged him. During
unidentified female to s
s
• while JE and JE toucli-JJ
had the OF as he used a
with the unidentified ice on the
female.
18 .
Masturbation YES YES YES YES YES, made moaning
noises while touching
19 himself.
Ejaculation YES YES YES YES She believed he
ejaculated.
20
EFTA01699911
A : 1 C D I E I F I G
VICTIM WITNESS
1 Jane Doe #1 Jane Doe #2 ane oe. a ane. Jane Doe #5 Jane Doe #6
Sexual activity with No No No
21
Statements made by Take off your shirt. I'll pay you $200.00 for Asked her to take her
Epstein Take off your pants. " every girl you bring to me. clothes off. Told her she
Are you going to get Make sure they know could make more money
comfortable? Why what is expected. The if she would do more.
are you going to keep younger the better. Told her she could make
your panties on? So more money if she
you are 14. brought her pretty friends.
You should know what to
expect when you come
here. Do you have sex
with your boyfriend?
When told JE she was
a virgin, JE asked 'You
don't like sex?" Come
closer. Rub my chest.
Take your clothes off.
22
Asked to bring Yes/Epstein Yes/Epstein (JE upset Yes/Epstein stated JE YES/ Epstein YES/ =and Epstein
others/By whom? when. brought a black said no black girls or girls
23 girl, JE - no heavy girls) with tattoos.)
EFTA01699912
A I C I D I E
1
VICTIM WITNESS
DOB
Jane Doe #1 Jane Doe #2 Jane Doe #3
ISJane Doe #4
all
Jane Doe #5 Jane Doe
Gifts YES - Apartment rent YES - Victoria's Secret Bikini from Brazil YES - 5600.00-700.00 to NO NO
paid by Epstein. bras and underwear, apply toward the purchase
massage oils, book of a vehicle. Book -
titled "Massage for Massage for Dummies.
Dummies." Concert
tickets to see the band
Incubus at the Sound
Advice Amphitheater.
24
Physical Evidence MP / Massage for Telephone Records / MP / Telephone Records Confession MP - 1
(i.e. Message Pads, Dummies Book JB Petty Cash Report - MP - 9 MP - 4
Trash Pulls, Search Baby gifts TP - 4
Warrant, Payment
Documentation, etc.)
25
TRAVEL
26 Title 18 USC 2423(b)
Dates of 03/31/9751Fillir
27
Travel/Aircraft
HUMAN SEX
TRAFFICKING
1
r
28 Title 18 USC 1591(a)
Who Scheduled [ rands LNU
Appointments? (phonetic)
29
30 Miscellaneous
EFTA01699913
A F I G
VICTIM WITNESS
DOB
1 Jane Doe #1 Jane Doe #2 Jane Doe #3 Jane Doe #4 Jane Doe #5 Jane Doe #6
posed nude for told the PBPD that recently spoke told What JE believed told her
photographs taken by she is in love with JE and Fall 2007). doesn't do that (referring about the vibrator
at JE's that she would not speak talked of her twin to sex) he plays around provided to %dor to
request. was paid about him positively or boys and mentioned she with them. said that Spring 2005. knew of
$500.00 to pose nude. negatively. JE told. was living in Manhattan. JE liked and. the JE's offer to takes and
that he would take her to described most. IS to New York or his
NY or Brazil. late on as a storyteller island. • knew of gifts
rent asked JE for $300.00 and a bad liar. JE provided to. i.e.
and JE gave her $500.00. lingerie, birthday flowers,
JE and SK thrum a vibrator and rental car.
baby shower for her
friends at.rs house.
31
Interviewed by PBPD No No No No Yes Yes
32
33 Interviewed by FBI Yes Yes Yes No Yes
EFTA01699914
A H I I I K I L I M
VICTIM WITNESS
DOB
1 Jane Doe #7 Jane Doe #8 ane oe ane oe Jane Doe #11 Jane Doe #12
AGE AT FIRST 16 17 17 17 17 16
2 CONTACT
HIGH SCHOOL WT Dwyer HS Royal Palm Beach HS Lake Worth HS Palm Beach Central HS John I. Leonard HS Royal Palm Beach HS
3
BROUGHT BY Unknown
4
DATES OF 07/04/2004 - 07/16/2004 07/15/2004 - 09/01/2005 07/22/2004 - 11/02/2005 08/19/2004 - 02/14/2005 08/21/2004 - 08/18/2005 09/2004 - Testimony -
CONTACT/ SOURCE Telephone INTelephone Telephone • Telephone I.Telephone Start date only.
5
GIRLS RECRUITED N/A . N/A
18)
6
NUMBER OF 3 - 4 times multiple times a stated Approx. 15 4 Approx 10 times 1 massage
MASSAGES hundreds of times Second visit she brought 2 more residence visits
7
111
ENTICEMENT
8 Title 18 USC 2422(p) -
Interstate Commerce Telephone Records Telephone Records Telephone Records Telephone Records Telephone Records Telephone Records
Connection
9
Under 18 at time of Yes -16 YES -17 a stated 16 YES YES -160r17 YES - 17 YES - 17
sexual activity and 16/17) Junior Year of H.S.
10
Advised if asked to
state they were over
18/Advised by
whom?
11
EFTA01699915
A
VICTIM WITNESS
DOB
1 ane oe Jane Doe #8 Jane Doe #9 ane oe Jane Doe #11 ane e 2
Knowledge or told JE she was 18. leoriginally told JE she le told JE she was in • told JE multiple times None
Discussion of Age JE responded that he was 18, but on her High School. JE asked that she was 17. JE
with JE? knew she was not 18. JE eighteenth birthday JE her how old she was and stated to her he couldn't
sent roses to RPBHS for gave her four tickets to she told him her actual wait for her to turn 18 so
le for her performance in see David Copperfield in age at the time which was she could be his personal
a school play. le Fort Lauderdale, Florida. 16 or 17. JE told le when masseuse. He also
provided JE with a school she turned 18 he would couldn't wait for her to
transcript In hopes he take her to Los Angeles. turn 18 so they could go
would help her financially JE said that he would give on vacation (Paris).
and obtain entry into NYU. her a place to stay when
flown to NY for her she was 18 and that he
18th Birthday. would take her
12 everywhere.
Payment for YES/$200.00 YES/$200.00 - 1st time, YES/$200.00 YES/$200.00 YES/$200.00 YES/$200.00
services?/Amount $300.00 - $600.00 and
$1000.00 paid after penile
13 penetration.
Payment for Yes/$200.00 YES -• stated. NO YES/$200.00 fore YES/$200.00 per girl YES/$100.00
14 recruitment recvd $200.00
Payments made by Epstein Epstein Epstein Epstein Epstein
15
Taken upstairs by Epstein and "T'
16
Clothing worn during Underwear and Nude Underwear - first 1st time - Shorts and Bra, Bra and Underwear, and Nude Cropped tank top that
massage massage/ Nude 3rd visit - Nude Topless exposed her belly and
17 blue jeans
EFTA01699916
A
VICTIM WITNESS
DOB MIE
1 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 Jane Doe #11 ane uoe
Sexual activity JE instructed to rub JE JE touched-_ JE rolled over on his side -ach time JE rubbed s legs and
JE . JE would rub his 2-3 separate and while massaged him. JE
JE • provided the
used a back massager/ massage.
JE pulle closer to him vibrator on her breast App
that. JE also attempted to
. On one occasion, JE vibrating back massager
age 17) with his her belt was too tight. JE
witnessed the while he rubbed his nipples and
. JE at least two occasions, started to until
requested to perform JE's girlfriend/assistant he ejaculated.
, when she ccompanied
refused he offered her an
minutes. All but once, but
less than five times, JE
requested. and
engage in sexual ouched
i.e. kissing, touching, and vaginal pulled Nada's
front of him hand away. O
and with him. Additional
and used one by JE
andIN during the
massages.
18
Masturbation Yes YES YES Yes Yes YES
19
Ejaculation • •
EFTA01699917
A
VICTIM WITNESS
DOB
1 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 Jane Doe #11 Jane Doe #12
Sexual activity with No Yes, kissing, touching and Yes, Nada touched No No No
vaginally vagina, • pulled Nada's
penetrated with hand away. On more
vibrator/sex toys. than one occasion, Nada
placed the massager
21 directly on Mis vagina.
Statements made by JE told to get On more than one JE asked II to touch his According toe, JE JE asked IN andIll to Get a little bit more
Epstein comfortable. JE told • occasion, JE asked. to penis, she declined. JE refers to the girls that take their shirts and bras comfortable. Take of your
that she could not tell have sex with him and askecM about he massage him as off (they did) and • shirt and pull down your
anyone what happened at perform oral sex on him. attending college in the "clientele". JE told • would show DN what to pants. Let me touch you
the house or bad things future. JE provided that he had a girl he paid do. JE tot to leave like I like to be touched.
could happen.
ted dealing with her parents to take everything off which
her an• eavy. 'e told he talk dirty to him. JE asked
that she was here for that wanted cute girls like her. if she would have sex
reason. When other girls at JE's with him and that he'd
residence asked for wine, give her more money (she
JE replied "I don't drink or declined). JE told he
do drugs." JE asked M, could not wait for her to
"do you have any friends turn le so she could be
that would do this?" his personal masseuse.
22
Asked to bring YES/ Epstein and
others/By whom?
23
EFTA01699918
A H I
VICTIM WITNESS
DOB I mS I
1 ane oe Jane Doe #8 Jane Doe #9 ane Doe #1 ane oe Sane oe 12
Gifts YES - Multiple Victoria's YES - Brazilian bathing None None NO
Secret underwear sets. suit, Western Union -
Bathing suit and Louis Cancun $350.00 Rec.
Vuitton purse. Movie 06/02/2005 Western
tickets/show tickets i.e.. Union - San Diego
David Copperfield (FL) $200.00 Rec
and Phantom of the 07/13/2005
Opera (NY). Plane ticket David Copperfield Tickets
to NY. $2000.00
Christmas bonus. 2005
Dodge Neon. IE
believed JE would pay for
24 her to attend NYU.
Physical Evidence Testimony/Telephone MP - 6 MP - 10 MP Massage oils Testimony
(I.e. Message Pads, Records SW-H.S. Transcript TP - 09/21/2005 Testimony
Trash Pulls, Search Message pads JB's Petty Cash Receipt MI Petty Cash Receipt
Warrant, Payment Photo Lineup-MID Brazilian bathing suit,
Documentation, etc.) Palm Beach PD report- Western Union - Cancun
taken when E went to $350.00 Recvd
pick up Christmas bonus. 06/02/2005 West
DataSet-10
Unknown
70 pages
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70
EXHIBIT A
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
EFTA01079793
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged
Objection Abbreviation
General Objections --
Inadequate Privilege Log Inadequate Log
Failure to Prove Factual Underpinnings of Privilege Claim No Factual Underpinnings
Waiver of Confidentiality Waiver
Government's Fiduciary Duty to Crime Victims Bars Privilege Fiduciary Duty
Communications Facilitating Crime-Fraud-Misconduct Not Covered Crime-Fraud-Misconduct
Factual Materials Not Covered Factual Materials
Documents Not Prepared in Anticipation of CVRA Litigation Not in Anticipation of Litigation
Attorney Client Objections -
Ordinary Governmental Communications Not Covered Ordinary Government Communication
Attorney-Client Relationship Not Established No Attorney-Client Relationship
Deliberative Process Objections -
Privilege Not Properly Invoked Improper Invocation
Final Decision Exempted from Privilege Final Decision
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Investigative Privilege -
Privilege Not Properly Invoked Improper Invocation
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Product Doctrine
No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Claims Against Public Prosecutor
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Attorney Conduct at Issue
Rule 6(e)
Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) Court Authorized Under 6(e)(3)(E)
The Court Has Inherent Power to Release Grand Jury Materials Court Inherent Power to Release
Victims Have Properly Petitioned for the Release of Grand Jury Proper Victim's Petition
The CVRA Gives the Court Authority to Release Grand Jury Materials CVRA-authorized release
Page 1 of 69
EFTA01079794
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 3 of 70
Grand Jury Materials Can Be Severed from Other Materials Material Severable
The Privacy Rights of Other Victims
Government Redaction Can Resolve Privacy Concerns Redaction
No Assertion of Privacy Rights by Other Victims No Assertion by Victims
Privacy Act
The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Court-Compelled Disclosure
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings;
P-000001 SUBPOENAS" containing correspondence Work Product Fiduciary Duty; Not in Anticipation of
thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor;
P-000039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable; Overriding Need
Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in
thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper
P-000549 related to enforcement of same, documents subject to investigative Invocation; Overriding Need; Claims Against
produced in response to some subpoenas; privilege Public Prosecutor; Attorney Conduct at Issue;
and attorney (Villafafia) handwritten notes Also contains documents Factual Materials; Court Authorized Under
subject to privacy rights of 6(e)(3)(E); Court Inherent Power to Release;
victims who are not Proper Victim's Petition; CVRA-authorized
parties to this litigation release; Material Severable; Redaction; No
Assertion by Victims; Overriding Need
Page 2 of 69
EFTA01079795
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 4 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Ritz Compact Flash 6(e) Inadequate Log; No Factual Underpinnings;
P-000550 SW" containing copies of a sealed search Contains information Fiduciary Duty; Factual Materials; Not in
thru warrant application, warrant, and subject to investigative Anticipation of Litigation; Improper
P-000621 supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "PNY Technologies 6(e) Inadequate Log; No Factual Underpinnings;
P-000622 Compact Flash SW" containing copies of a Contains information Fiduciary Duty; Factual Materials; Not in
thru sealed search warrant application, warrant, subject to investigative Anticipation of Litigation; Improper
P-000693 and supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "JE Corporations" Work Product Inadequate Log; No Factual Underpinnings;
P-000694 containing attorney research on Epstein- Contains information Fiduciary Duty; Not in Anticipation of
thru owned corporations and prior litigation subject to investigative Litigation; Improper Invocation; Overriding
P-000781 privilege Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Overriding Need
Box #1 File folder entitled "Capital One" 6(e) Inadequate Log; No Factual Underpinnings;
P-000782 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court
thru Authorized Under 6(e)(3)(E); Court Inherent
P-000803 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Page 3 of 69
EFTA01079796
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "DTG 6(e) Inadequate Log; No Factual Underpinnings;
P-000804 Operations/Dollar Rent-a-Car" containing Contains documents and Fiduciary Duty; Factual Materials; Not in
thru subpoena and responsive documents information subject to Anticipation of Litigation; Improper
P-000854 investigative privilege Invocation; Overriding Need; Factual
Also contains documents Materials; Court Authorized Under 6(e)(3)(E);
and information subject to Court Inherent Power to Release; Proper
privacy rights of victims Victim's Petition; CVRA-authorized release;
who are not parties to this Material Severable; Redaction; No Assertion
litigation by Victims
Box #1 File folder entitled "JP Morgan Chase" 6(e) Inadequate Log; No Factual Underpinnings;
P-000855 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000937 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled 'Washington Mutual" 6(e) Inadequate Log; No Factual Underpinnings;
P-000938 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000947 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Computer Search &" Work Product Inadequate Log; No Factual Underpinnings;
P-000948 containing legal research on computer Attorney-Client Fiduciary Duty; Factual Materials; Not in
thru search and handwritten notes on indictment Contains information Anticipation of Litigation; Ordinary
P-000982 preparation subject to investigative Government Communication; No Attorney-
privilege. Also contains Client Relationship; Improper Invocation;
information subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue;
who are not parties to this Redaction; No Assertion by Victims
litigation
Page 4 of 69
EFTA01079797
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 6 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Attorney Notes from Work product Inadequate Log; No Factual Underpinnings;
P-000983 Document Review" containing typed and 6(e) Fiduciary Duty; Factual Materials; Not in
thru handwritten attorney (Villafafia) notes, Contains information Anticipation of Litigation; Improper
P-001007 target letters, correspondence re grand jury subject to investigative Invocation; Overriding Need; Claims Against
subpoena privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Notes from Fed Ex Work Product Inadequate Log; No Factual Underpinnings;
P-001008 Records" containing handwritten and typed 6(e) Fiduciary Duty; Factual Materials; Not in
thru attorney (Villafafia) notes and screen shots Contains information Anticipation of Litigation; Improper
P-001056 of FedEx subpoena response electronic file subject to investigative Invocation; Overriding Need; Claims Against
privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Colonial Bank 6(e) Inadequate Log; No Factual Underpinnings;
P-001057 Records" containing records received in Contains information Fiduciary Duty; Not in Anticipation of
thru response to grand jury subpoena subject to investigative Litigation; Improper Invocation; Overriding
P-001959 privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Page 5 of 69
EFTA01079798
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 7 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "OLY Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-001960 Vol 2: OLY-51 THROUGH" containing Contains information Fiduciary Duty; Factual Materials; Not in
Thru subpoenas numbered OLY-51 through subject to investigative Anticipation of Litigation; Improper
P-002089 OLY-81 with related correspondence privilege. Also contains Invocation; Overriding Need; Factual
information subject to Materials; Court Authorized Under 6(e)(3)(E);
privacy rights of victims Court Inherent Power to Release; Proper
who are not parties to this Victim's Petition; CVRA-authorized release;
litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled - Epstein Corporate 6(e) Inadequate Log; No Factual Underpinnings;
P-002090 Records: OLY-51, OLY-52, OLY-53, Contains information and Fiduciary Duty; Not in Anticipation of
Thru OLY-54" containing subpoenas, records documents subject to Litigation; Improper Invocation; Overriding
P-002169 received in response to subpoenas, and investigative privilege Need; Factual Materials; Court Authorized
related correspondence Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Colonial Bank" 6(e) Inadequate Log; No Factual Underpinnings;
P-002170 containing subpoenas, correspondence Contains information and Fiduciary Duty; Not in Anticipation of
Thru related to subpoenas, records received in documents subject to Litigation; Improper Invocation; Overriding
P-002246 response to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "JEGE & Hyperion 6(e) Inadequate Log; No Factual Underpinnings;
P-002247 from Goldberger OLY-46 & OLY-47" Contains information and Fiduciary Duty; Not in Anticipation of
Thru containing documents received in response documents subject to Litigation; Improper Invocation; Overriding
P-002265 to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Page 6 of 69
EFTA01079799
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002266 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, of individuals listed as and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
"Additional victims" privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable
litigation
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002387 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002769 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, relevant pieces of grand jury and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
materials, telephone records/flight records privacy rights of victims Proper Victim's Petition; CVRA-authorized
analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No
photographs, DAVID records, NCICs, and litigation Assertion by Victims
related materials for persons identified as
Jane Does #15, 16, 17, 18, 19, Past
Em lo ees, Misc. Witnesses
Page 7 of 69
EFTA01079800
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 9 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002770 witness/victim list with identifying 6(e) Fiduciary Duty; Factual Materials; Not in
Thru information, sexual activity summary, Contains information and Anticipation of Litigation; Improper
P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against
(Villafafia) handwritten notes, 302s, investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
portions of state investigative file, attorney Also contains information Redaction; No Assertion by Victims
(Villafafia) typed notes, relevant pieces of and documents subject to
grand jury materials, telephone privacy rights of victims
records/flight records analysis charts, who are not parties to this
victim/witness photographs, DAVID litigation
records, NCICs, and related materials for
persons identified as Jane Does #1, 2, 3, 4,
5, 6, 7, 8
Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings;
P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper
P-003545 a number of victim/witnesses documents subject to Invocation; Overriding Need; Claims Against
, an investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Page 8 of 69
EFTA01079801
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70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 FBI Reports of March 2008 interviews of Work product Inadequate Log; No Factual Underpinnings;
P-003546 additional witness/victim located in New 6(e) Fiduciary Duty; Factual Materials; Not in
Thru York Contains information and Anticipation of Litigation; Improper
P-003552 documents subject to Invocation; Overriding Need; Claims Against
investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Box #1 Printout of filenames from Federal Express Work product Inadequate Log; No Factual Underpinnings;
P-003553 subpoena response with Attorney notations 6(e) Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003555B Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable
Box #1 Document entitled "Identified Numbers" Work product Inadequate Log; No Factual Underpinnings;
P-003556 with accompanying handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru list compiled from grand jury materials and Contains information Litigation; Improper Invocation; Overriding
P-003562 attorney analysis of records subject to investigative Need; Claims Against Public Prosecutor;
privilege Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Page 9 of 69
EFTA01079802
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70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Folder entitled "Flight Manifests" 6(e) Inadequate Log; No Factual Underpinnings;
P-003563 containing manifests received pursuant to Contains information and Fiduciary Duty; Not in Anticipation of
Thru grand jury subpoena documents subject to Litigation; Improper Invocation; Overriding
P-003629 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Recent Attorney Work product Inadequate Log; No Factual Underpinnings;
P-003630 Notes" containing handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru (Villafafia) notes regarding document Investigative privilege Litigation; Improper Invocation; Overriding
P-003633 review and case strategy Deliberative process Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Box #1 File folder bearing victim name containing Work product Inadequate Log; No Factual Underpinnings;
P-003634 FBI interview report from May 2008, Attorney-client privilege Fiduciary Duty; Factual Materials; Not in
Thru telephone activity report with attorney 6(e) Anticipation of Litigation; Ordinary
P-003646 (Villafanafia) handwritten notes, related Investigative privilege Government Communication; No Attorney-
grand jury material Also contains information Client Relationship; Improper Invocation;
and documents subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue; Factual
who are not parties to this Materials; Court Authorized Under 6(e)(3)(E);
litigation Court Inherent Power to Release; Proper
Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Page 10 of 69
EFTA01079803
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #I File folder entitled "Summary of Sexual Work product Inadequate Log; No Factual Underpinnings;
P-003647 Activity" containing chart bearing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru handwritten title "Sexual Activity — Investigative privilege Anticipation of Litigation; Improper
P-003651 Summary" with meta-analysis of Deliberative process Invocation; Overriding Need; Claims Against
information, sorted by name of each Also contains information Public Prosecutor; Attorney Conduct at Issue;
victim/witness, including name and and documents subject to Factual Materials; Court Authorized Under
identifying information of each privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
victim/witness who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Victim Civil Suits" Not privileged. N/A
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research it JE Work product Inadequate Log; No Factual Underpinnings;
P-003664 Websites" containing attorney research Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003678 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Serene Cano (N.Y. Work product Inadequate Log; No Factual Underpinnings;
P-003679 AUSA)" containing attorney (Villafafia) Fiduciary Duty; Not in Anticipation of
Thru handwritten notes Litigation; Claims Against Public Prosecutor;
P-003680 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Dr. Anna Salter" Work product Inadequate Log; No Factual Underpinnings;
P-003681 containing attorney (Villafafia) memo to Investigative privilege Fiduciary Duty; Not in Anticipation of
Thru expert witness and handwritten attorney Litigation; Improper Invocation; Overriding
P-003687 notes Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue
Page 11 of 69
EFTA01079804
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 13 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "IR G[] Interview" Work product Inadequate Log; No Factual Underpinnings;
P-003688 containing attorney handwritten notes of Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru interview, and attorney handwritten notes Also contains information Anticipation of Litigation; Improper
P-003693 regarding potential charges subject to privacy rights of Invocation; Overriding Need; Claims Against
victims who are not Public Prosecutor; Attorney Conduct at Issue;
parties to this litigation Redaction; No Assertion by Victims
Box #1 File folder entitled "Research re Travel for Work product Inadequate Log; No Factual Underpinnings;
P-003694 Prostitution" containing attorney 6(e) Fiduciary Duty; Factual Materials; Not in
Thru (VillafaiIa) handwritten notes regarding Investigative privilege Anticipation of Litigation; Improper
P-003711 grand jury presentation, chart entitled Also contains information Invocation; Overriding Need; Claims Against
"Brought to Epstein's House" with and documents subject to Public Prosecutor; Attorney Conduct at Issue;
handwritten notes, Message Pad meta- privacy rights of victims Factual Materials; Court Authorized Under
analysis chart, summary of evidence who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
related to one victim/witness, and relevant litigation Proper Victim's Petition; CVRA-authorized
grand jury information release; Material Severable; Redaction; No
Assertion by Victims
Box #1 Empty file folder bearing name of Investigative privilege N/A
P-003712 victim/witness Also contains information
subject to privacy rights of
victim who is not a party
to this litigation
Box #1 File folder entitled "T[] M[]" containing 6(e) Inadequate Log; No Factual Underpinnings;
P-003713 grand jury subpoenas, motion and order to Documents under seal Fiduciary Duty; Factual Materials; Court
Thru compel testimony, and correspondence pursuant to court order Authorized Under 6(e)(3)(E); Court Inherent
P-003746 regarding same Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Box #1 File folder entitled 6(e) Inadequate Log; No Factual Underpinnings;
P-003747 containing subpoena an correspondence Fiduciary Duty; Factual Materials; Court
Thru regarding same Authorized Under 6(e)(3)(E); Court Inherent
P-003751 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Page 12 of 69
EFTA01079805
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "PBPD Investigative 6(e) Inadequate Log; No Factual Underpinnings;
P-003752 File" obtained via subpoena Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru Also contains information Anticipation of Litigation; Improper
P-004295 and documents subject to Invocation; Overriding Need; Factual
privacy rights of victims Materials; Court Authorized Under 6(e)(3)(E);
who are not parties to this Court Inherent Power to Release; Proper
litigation Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings;
P-004296 containing meta-analysis chart showing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone calls, travel, and grand jury Investigative privilege Anticipation of Litigation; Improper
P-004350 materials relevant to possible charges Also contains information Invocation; Overriding Need; Claims Against
and documents subject to Public Prosecutor; Attorney Conduct at Issue;
privacy rights of victims Factual Materials; Court Authorized Under
who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
litigation Proper Victim's Petition; CVRA-authorized
release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled Work product Inadequate Log; No Factual Underpinnings;
P-004351 Documents 53909- Fiduciary Duty; Not in Anticipation of
Thru attorney research related to bias issue Litigation; Claims Against Public Prosecutor;
P-004381 Overriding Need; Attorney Conduct at Issue
Box #1 File Folder entitled "FEDEX" containing 6(e) Inadequate Log; No Factual Underpinnings;
P
DataSet-10
Unknown
70 pages
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70
EXHIBIT A
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
EFTA00208682
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged
Objection Abbreviation
General Objections --
Inadequate Privilege Log Inadequate Log
Failure to Prove Factual Underpinnings of Privilege Claim No Factual Underpinnings
Waiver of Confidentiality Waiver
Government's Fiduciary Duty to Crime Victims Bars Privilege Fiduciary Duty
Communications Facilitating Crime-Fraud-Misconduct Not Covered Crime-Fraud-Misconduct
Factual Materials Not Covered Factual Materials
Documents Not Prepared in Anticipation of CVRA Litigation Not in Anticipation of Litigation
Attorney Client Objections -
Ordinary Governmental Communications Not Covered Ordinary Government Communication
Attorney-Client Relationship Not Established No Attorney-Client Relationship
Deliberative Process Objections -
Privilege Not Properly Invoked Improper Invocation
Final Decision Exempted from Privilege Final Decision
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Investigative Privilege -
Privilege Not Properly Invoked Improper Invocation
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Product Doctrine
No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Claims Against Public Prosecutor
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Attorney Conduct at Issue
Rule 6(e)
Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) Court Authorized Under 6(e)(3)(E)
The Court Has Inherent Power to Release Grand Jury Materials Court Inherent Power to Release
Victims Have Properly Petitioned for the Release of Grand Jury Proper Victim's Petition
The CVRA Gives the Court Authority to Release Grand Jury Materials CVRA-authorized release
Page 1 of 69
EFTA00208683
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 3 of 70
Grand Jury Materials Can Be Severed from Other Materials Material Severable
The Privacy Rights of Other Victims
Government Redaction Can Resolve Privacy Concerns Redaction
No Assertion of Privacy Rights by Other Victims No Assertion by Victims
Privacy Act
The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Court-Compelled Disclosure
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings;
P-000001 SUBPOENAS" containing correspondence Work Product Fiduciary Duty; Not in Anticipation of
thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor;
P-000039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable; Overriding Need
Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in
thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper
P-000549 related to enforcement of same, documents subject to investigative Invocation; Overriding Need; Claims Against
produced in response to some subpoenas; privilege Public Prosecutor; Attorney Conduct at Issue;
and attorney (Villafafia) handwritten notes Also contains documents Factual Materials; Court Authorized Under
subject to privacy rights of 6(e)(3)(E); Court Inherent Power to Release;
victims who are not Proper Victim's Petition; CVRA-authorized
parties to this litigation release; Material Severable; Redaction; No
Assertion by Victims; Overriding Need
Page 2 of 69
EFTA00208684
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 4 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Ritz Compact Flash 6(e) Inadequate Log; No Factual Underpinnings;
P-000550 SW" containing copies of a sealed search Contains information Fiduciary Duty; Factual Materials; Not in
thru warrant application, warrant, and subject to investigative Anticipation of Litigation; Improper
P-000621 supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "PNY Technologies 6(e) Inadequate Log; No Factual Underpinnings;
P-000622 Compact Flash SW" containing copies of a Contains information Fiduciary Duty; Factual Materials; Not in
thru sealed search warrant application, warrant, subject to investigative Anticipation of Litigation; Improper
P-000693 and supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "JE Corporations" Work Product Inadequate Log; No Factual Underpinnings;
P-000694 containing attorney research on Epstein- Contains information Fiduciary Duty; Not in Anticipation of
thru owned corporations and prior litigation subject to investigative Litigation; Improper Invocation; Overriding
P-000781 privilege Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Overriding Need
Box #1 File folder entitled "Capital One" 6(e) Inadequate Log; No Factual Underpinnings;
P-000782 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court
thru Authorized Under 6(e)(3)(E); Court Inherent
P-000803 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Page 3 of 69
EFTA00208685
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "DTG 6(e) Inadequate Log; No Factual Underpinnings;
P-000804 Operations/Dollar Rent-a-Car" containing Contains documents and Fiduciary Duty; Factual Materials; Not in
thru subpoena and responsive documents information subject to Anticipation of Litigation; Improper
P-000854 investigative privilege Invocation; Overriding Need; Factual
Also contains documents Materials; Court Authorized Under 6(e)(3)(E);
and information subject to Court Inherent Power to Release; Proper
privacy rights of victims Victim's Petition; CVRA-authorized release;
who are not parties to this Material Severable; Redaction; No Assertion
litigation by Victims
Box #1 File folder entitled "JP Morgan Chase" 6(e) Inadequate Log; No Factual Underpinnings;
P-000855 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000937 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled 'Washington Mutual" 6(e) Inadequate Log; No Factual Underpinnings;
P-000938 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000947 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Computer Search &" Work Product Inadequate Log; No Factual Underpinnings;
P-000948 containing legal research on computer Attorney-Client Fiduciary Duty; Factual Materials; Not in
thru search and handwritten notes on indictment Contains information Anticipation of Litigation; Ordinary
P-000982 preparation subject to investigative Government Communication; No Attorney-
privilege. Also contains Client Relationship; Improper Invocation;
information subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue;
who are not parties to this Redaction; No Assertion by Victims
litigation
Page 4 of 69
EFTA00208686
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 6 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Attorney Notes from Work product Inadequate Log; No Factual Underpinnings;
P-000983 Document Review" containing typed and 6(e) Fiduciary Duty; Factual Materials; Not in
thru handwritten attorney (Villafafia) notes, Contains information Anticipation of Litigation; Improper
P-001007 target letters, correspondence re grand jury subject to investigative Invocation; Overriding Need; Claims Against
subpoena privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Notes from Fed Ex Work Product Inadequate Log; No Factual Underpinnings;
P-001008 Records" containing handwritten and typed 6(e) Fiduciary Duty; Factual Materials; Not in
thru attorney (Villafafia) notes and screen shots Contains information Anticipation of Litigation; Improper
P-001056 of FedEx subpoena response electronic file subject to investigative Invocation; Overriding Need; Claims Against
privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Colonial Bank 6(e) Inadequate Log; No Factual Underpinnings;
P-001057 Records" containing records received in Contains information Fiduciary Duty; Not in Anticipation of
thru response to grand jury subpoena subject to investigative Litigation; Improper Invocation; Overriding
P-001959 privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Page 5 of 69
EFTA00208687
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 7 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "OLY Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-001960 Vol 2: OLY-51 THROUGH" containing Contains information Fiduciary Duty; Factual Materials; Not in
Thru subpoenas numbered OLY-51 through subject to investigative Anticipation of Litigation; Improper
P-002089 OLY-81 with related correspondence privilege. Also contains Invocation; Overriding Need; Factual
information subject to Materials; Court Authorized Under 6(e)(3)(E);
privacy rights of victims Court Inherent Power to Release; Proper
who are not parties to this Victim's Petition; CVRA-authorized release;
litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled - Epstein Corporate 6(e) Inadequate Log; No Factual Underpinnings;
P-002090 Records: OLY-51, OLY-52, OLY-53, Contains information and Fiduciary Duty; Not in Anticipation of
Thru OLY-54" containing subpoenas, records documents subject to Litigation; Improper Invocation; Overriding
P-002169 received in response to subpoenas, and investigative privilege Need; Factual Materials; Court Authorized
related correspondence Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Colonial Bank" 6(e) Inadequate Log; No Factual Underpinnings;
P-002170 containing subpoenas, correspondence Contains information and Fiduciary Duty; Not in Anticipation of
Thru related to subpoenas, records received in documents subject to Litigation; Improper Invocation; Overriding
P-002246 response to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "JEGE & Hyperion 6(e) Inadequate Log; No Factual Underpinnings;
P-002247 from Goldberger OLY-46 & OLY-47" Contains information and Fiduciary Duty; Not in Anticipation of
Thru containing documents received in response documents subject to Litigation; Improper Invocation; Overriding
P-002265 to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Page 6 of 69
EFTA00208688
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002266 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, of individuals listed as and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
"Additional victims" privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable
litigation
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002387 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002769 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, relevant pieces of grand jury and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
materials, telephone records/flight records privacy rights of victims Proper Victim's Petition; CVRA-authorized
analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No
photographs, DAVID records, NCICs, and litigation Assertion by Victims
related materials for persons identified as
Jane Does #15, 16, 17, 18, 19, Past
Em lo ees, Misc. Witnesses
Page 7 of 69
EFTA00208689
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 9 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002770 witness/victim list with identifying 6(e) Fiduciary Duty; Factual Materials; Not in
Thru information, sexual activity summary, Contains information and Anticipation of Litigation; Improper
P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against
(Villafafia) handwritten notes, 302s, investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
portions of state investigative file, attorney Also contains information Redaction; No Assertion by Victims
(Villafafia) typed notes, relevant pieces of and documents subject to
grand jury materials, telephone privacy rights of victims
records/flight records analysis charts, who are not parties to this
victim/witness photographs, DAVID litigation
records, NCICs, and related materials for
persons identified as Jane Does #1, 2, 3, 4,
5, 6, 7, 8
Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings;
P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper
P-003545 a number of victim/witnesses documents subject to Invocation; Overriding Need; Claims Against
and investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Page 8 of 69
EFTA00208690
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 10 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 FBI Reports of March 2008 interviews of Work product Inadequate Log; No Factual Underpinnings;
P-003546 additional witness/victim located in New 6(e) Fiduciary Duty; Factual Materials; Not in
Thru York Contains information and Anticipation of Litigation; Improper
P-003552 documents subject to Invocation; Overriding Need; Claims Against
investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Box #1 Printout of filenames from Federal Express Work product Inadequate Log; No Factual Underpinnings;
P-003553 subpoena response with Attorney notations 6(e) Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003555B Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable
Box #1 Document entitled "Identified Numbers" Work product Inadequate Log; No Factual Underpinnings;
P-003556 with accompanying handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru list compiled from grand jury materials and Contains information Litigation; Improper Invocation; Overriding
P-003562 attorney analysis of records subject to investigative Need; Claims Against Public Prosecutor;
privilege Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Page 9 of 69
EFTA00208691
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 11 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Folder entitled "Flight Manifests" 6(e) Inadequate Log; No Factual Underpinnings;
P-003563 containing manifests received pursuant to Contains information and Fiduciary Duty; Not in Anticipation of
Thru grand jury subpoena documents subject to Litigation; Improper Invocation; Overriding
P-003629 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Recent Attorney Work product Inadequate Log; No Factual Underpinnings;
P-003630 Notes" containing handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru (Villafafia) notes regarding document Investigative privilege Litigation; Improper Invocation; Overriding
P-003633 review and case strategy Deliberative process Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Box #1 File folder bearing victim name containing Work product Inadequate Log; No Factual Underpinnings;
P-003634 FBI interview report from May 2008, Attorney-client privilege Fiduciary Duty; Factual Materials; Not in
Thru telephone activity report with attorney 6(e) Anticipation of Litigation; Ordinary
P-003646 (Villafanafia) handwritten notes, related Investigative privilege Government Communication; No Attorney-
grand jury material Also contains information Client Relationship; Improper Invocation;
and documents subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue; Factual
who are not parties to this Materials; Court Authorized Under 6(e)(3)(E);
litigation Court Inherent Power to Release; Proper
Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Page 10 of 69
EFTA00208692
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #I File folder entitled "Summary of Sexual Work product Inadequate Log; No Factual Underpinnings;
P-003647 Activity" containing chart bearing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru handwritten title "Sexual Activity — Investigative privilege Anticipation of Litigation; Improper
P-003651 Summary" with meta-analysis of Deliberative process Invocation; Overriding Need; Claims Against
information, sorted by name of each Also contains information Public Prosecutor; Attorney Conduct at Issue;
victim/witness, including name and and documents subject to Factual Materials; Court Authorized Under
identifying information of each privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
victim/witness who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Victim Civil Suits" Not privileged. N/A
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research it JE Work product Inadequate Log; No Factual Underpinnings;
P-003664 Websites" containing attorney research Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003678 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Serene Cano (N.Y. Work product Inadequate Log; No Factual Underpinnings;
P-003679 AUSA)" containing attorney (Villafafia) Fiduciary Duty; Not in Anticipation of
Thru handwritten notes Litigation; Claims Against Public Prosecutor;
P-003680 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Dr. Anna Salter" Work product Inadequate Log; No Factual Underpinnings;
P-003681 containing attorney (Villafafia) memo to Investigative privilege Fiduciary Duty; Not in Anticipation of
Thru expert witness and handwritten attorney Litigation; Improper Invocation; Overriding
P-003687 notes Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue
Page 11 of 69
EFTA00208693
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 13 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "IR G[] Interview" Work product Inadequate Log; No Factual Underpinnings;
P-003688 containing attorney handwritten notes of Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru interview, and attorney handwritten notes Also contains information Anticipation of Litigation; Improper
P-003693 regarding potential charges subject to privacy rights of Invocation; Overriding Need; Claims Against
victims who are not Public Prosecutor; Attorney Conduct at Issue;
parties to this litigation Redaction; No Assertion by Victims
Box #1 File folder entitled "Research re Travel for Work product Inadequate Log; No Factual Underpinnings;
P-003694 Prostitution" containing attorney 6(e) Fiduciary Duty; Factual Materials; Not in
Thru (Villafaria) handwritten notes regarding Investigative privilege Anticipation of Litigation; Improper
P-003711 grand jury presentation, chart entitled Also contains information Invocation; Overriding Need; Claims Against
"Brought to Epstein's House" with and documents subject to Public Prosecutor; Attorney Conduct at Issue;
handwritten notes, Message Pad meta- privacy rights of victims Factual Materials; Court Authorized Under
analysis chart, summary of evidence who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
related to one victim/witness, and relevant litigation Proper Victim's Petition; CVRA-authorized
grand jury information release; Material Severable; Redaction; No
Assertion by Victims
Box #1 Empty file folder bearing name of Investigative privilege N/A
P-003712 victim/witness Also contains information
subject to privacy rights of
victim who is not a party
to this litigation
Box #1 File folder entitled "T[] M[]" containing 6(e) Inadequate Log; No Factual Underpinnings;
P-003713 grand jury subpoenas, motion and order to Documents under seal Fiduciary Duty; Factual Materials; Court
Thru compel testimony, and correspondence pursuant to court order Authorized Under 6(e)(3)(E); Court Inherent
P-003746 regarding same Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Box #1 File folder entitled ' 6(e) Inadequate Log; No Factual Underpinnings;
P-003747 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court
Thru regarding same Authorized Under 6(e)(3)(E); Court Inherent
P-003751 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Page 12 of 69
EFTA00208694
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "PBPD Investigative 6(e) Inadequate Log; No Factual Underpinnings;
P-003752 File" obtained via subpoena Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru Also contains information Anticipation of Litigation; Improper
P-004295 and documents subject to Invocation; Overriding Need; Factual
privacy rights of victims Materials; Court Authorized Under 6(e)(3)(E);
who are not parties to this Court Inherent Power to Release; Proper
litigation Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings;
P-004296 containing meta-analysis chart showing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone calls, travel, and grand jury Investigative privilege Anticipation of Litigation; Improper
P-004350 materials relevant to possible charges Also contains information Invocation; Overriding Need; Claims Against
and documents subject to Public Prosecutor; Attorney Conduct at Issue;
privacy rights of victims Factual Materials; Court Authorized Under
who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
litigation Proper Victim's Petition; CVRA-authorized
release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Daniel Gonzalez Work product Inadequate Log; No Factual Underpinnings;
P-004351 Documents 53909-004" containing Fiduciary Duty; Not in Anticipation of
Thru attorney research related to bias issue Litigation; Claims Against Public Prosecutor;
P-004381 Overriding Need; Attorney Conduct at Issue
Box #1 File Folder entitled "FEDEX" containing
DataSet-10
Unknown
255 pages
Case Number:
Case Summary:
EFTA01730748
SOD-NY-3027571
Child Sex Trafficking investigation into Epstein, opened 12/08/2018. Epstein was indicted on
07/02/2019 and arrested on 07/06/2019. On 08/10/2019, FBI NY was notified Epstein committed
suicide in his jail cell. Maxwell was indicted on 06/29/2020 and arrested on 07/02/2020. The
Maxwell trial began on 11/28/2021. Maxwell was convicted on 12/29/2021 on S out of 6 counts.
Maxwell was sentenced on 06/28/2022 to 20 years. In November 2024, the U.S. appeals court
rejected Maxwell's request for en banc review. Maxwell requested an appeals extension to
04/10/2025. This investigation remains in Pending Inactive status.
EFTA01730749
Evidence Report for Case: 50D-NY-3027571
Filtering on: 1A
Type g Acquired On Serial g
1A 317 2025-03-10 706
1A ilfi 2025-03-10 225
1A al 2025-03-10 706
1A 314 2025-02-27 704
1A 313 2024-08-01 702
1A 312 2022-11-02 696
1A 311 2022-05-26 692
1A 310 2022-03-07 687
1A 309 2021-12-11 686
1A Eli 2021-11-24 Q14
1A Igi 2021-11-22 ila
1A 306 2021-11.23 677
1A 305 2021-11-05 674
1A 304 2021-10-19 672
1A 303 2021-11-02 671
1A 302 2021-10-11 670
lA 301 2021-10-14 669
1A 3Q2 2021-06-23 02
lA Z9.2 2021-10-08 01
lA 298 2021-10-08 665
1A 297 2021-10-08 665
lA 336 2021-10-08 §61
lA 295 2021-10-08 665
1A 294 2021-10-08 664
lA 293 2021-10-08 663
1A 292 2021-10-08 662
lA Z91. 2021-10-08 01
1A 290 2021-10-08 660
lA 289 2021-10-08 659
lA 221 2021-10-08 552
1A 287 2021-06-23 657
lA 286 2021-10-07 657
Lk 285 2021-10-07 656
lA 294 2021-09-02 653
Lk 214 2021-09-17 ga
lA 282 2021-05-18 651
1A 281 2021-09-20 650
lA 224 2021-09-20 552
1A Z7_2 2021-05-20 M./
1A 278 2021-09-27 6413
1A 277 2021-08-19 647
1A 276 2021-07-23 646
1A 275 2021-07-23 646
EFTA01730750
LA 274 2021-09-21 645
IA 273 2021-09-01 643
m M 2021-09-01 a
IA M 2021-06-02 442
1A 270 2021-06-02 642
lA 2.62 2021-04-27 al
1A M 2021-08-20 aQ
1A 267 2021-08-12 639
LA 266 2021-08-19 638
1A 265 2021-05-14 637
LA 264 2021-05-14 637
lA 263 2021-09-02 636
lA 262 2021-08-30 635
lA ai 2021-08-31 04
1A 102 2021-09-15 01
1A 259 2021-09-02 632
1A 258 2021-09-02 632
1A M 2021-09-02 632
1A 256 2021-09-08 632
1A 255 2021-07-27 631
1A 254 2021-08-11 630
lA 334 2021-09-14 412
lA M 2021-04-01 421
lA 251 2020-11-30 627
1A 250 2021-06-30 626
lA 242 2021-06-30 42k
lA 248 2021-08-04 624
LA 247 2021-06-28 623
lA 246 2021-06-23 623
LA 245 2021-06-23 623
lA 244 2021-03-23 M
1A 243 2021-07-06 616
lA 242 2021-07-14 615
1A 241 2021-07-14 41E
1A 240 2020-02-14 613
lA 239 2021-06-29 610
LA 238 2021-05-20 607
IA 237 2021-04-13 605
LA 231 2021-04-13 445
lA 235 2021-04-01 604
1A 234 2021-03-30 603
lA M 2021-05-17 W.2
1A M 2021-03-19 596
1A 231 2021-01-29 588
1A 230 2021-03-03 586
1A 229 2021-03-03 586
1A 228 2021-01-21 585
EFTA01730751
IA 227 2021-01-21 585
IA 226 2021-01-19 584
M 22.1 2021-02-24 al
IA 224 2021-02-11 53/
1A 223 2021-02-08 581
lA 222 2020-10-14 514
1A 221 2020-10-15 512
1A 220 2020-10-14 580
Lk 219 2021-01-27 579
1A 218 2021-02-01 578
Lk 217 2021-01-20 573
lA 216 2021-01-14 M
1A 215 2020-09-25 571
lA 2,14 2021-02-02 57.4
1A all 2021-01-12 522
lA 212 2020-10-28 568
1A 211 2021-01-27 567
1A 210 2020-02-07 566
lA 209 2020-10-07 566
Lk 208 2021-01-13 565
1A 207 2020-09-10 564
lA 2 2020-10-09 522
1A 205 2021-01-19 558
lA 204 2020-10-15 556
lA lca 2020-11-04 555
1A 202 2020-10-29 554
Lk 201 2020-08-13 552
M 200 2020-06-19 551
LA 199 2020-08-21 550
lA ag 2020-08-22 itia
1A Di 2020-08-21 .5
lA 196 2020-10-09 547
lA 125 2020-08-17 24_6
IA ISA 2020-10-09 545
lA 193 2020-08-21 543
LA 192 2020-11-18 542
IA 191 2020-08-24 541
1A 192 2020-10-21 525
lA 189 2020-10-22 535
1A 188 2020-10-09 535
lA 16/ 2020-06-19 522
1A 1.4¢ 2020-08-26 5_2A
lA 185 2020-08-19 513
1A 184 2020-08-11 512
lA 183 2020-08-12 511
1A 182 2020-07-17 500
EFTA01730752
LA 181 2020-07-07 499
lA 180 2020-07-15 496
1A n2 2020-07-15 1. 81
lA al 4 2020-07-27 MA
1A in 2020-08-04 488
1A 1.7.fi 2020-07-28 VI
1A iza 2020-07-28 4Z
1A 174 2020-07-28 477
1A 173 2020-07-28 477
1A 172 2020-07-28 476
lA M 2020-07-28 476
lA n_Q 2020-07-27 171
lA 1O 2020-07-21 01
lA 168 2020-07-14 468
1A 167 2020-07-02 467
1A 1.61 2020-07-02 4Z
1A 165 2020-07-08 450
1A 164 2020-07-13 449
1A 163 2020-07-13 445
LA 162 2020-07-11 443
lA 101. 2020-07-10 g_42
1A 160 2020-07-10
IA 159 2020-07-10 439
1A 15A 2020-06-19 OA
lA 157 2020-07-06 433
lA 156 2020-06-25 428
LA 155 2020-07-07 422
lA 154 2020-07-02 412
lA 151 2019-07-17 O.5
lA 152 2019-10-25 404
1A 151 2020-03-04 403
1A 152 2020-04-10 222
1A 2,42 2020-02-07 22A
1A 148 2020-02-07 398
1A 147 2019-07-22 397
1A 146 2019-11-21 396
1A 145 2019-09-18 395
EFTA01730753
1A 144 2019-10-23 394
IA 143 2019-10-23 393
1A 142 2019-09-12 ila
IA 141 2019-08-26 331.
1A 140 2019-10-18 390
1A 122 2019-10-18 39.2
1A al 2019.09-12 222
1A 137 2020-02-28 388
1A 136 2019-10-23 387
IA 135 2020-02-26 386
Lk 134 2019-10-24 385
lA 133 2019-10-24 385
1A 132 2019-12-04 384
2019-11-26 222
1A 1 2019-10-11 27
1A 129 2020-02-05 380
1A 128 2019-11-04 379
1A 127 2020-02-05 378
1A 126 2020-02-27 377
Lk 125 2019-08-13 376
lA 124 2019.08-13 376
m al 2020-02-05 ill
IA 122 2020-01-14 M
IA 121 2019.09-10 373
1A 120 2020-02-19 372
1A 112 2020-01-16 222
1A 118 2019-12-17 366
1A 117 2019-07-26 365
1A 116 2019-07-26 365
Lk 115 2019-12-15 359
IA 114 2019-12-15 252
1A 113 2019-12-15 359
lA 112 2020-01-17 356
1A 111 2020-01-08 3.55
IA 110 2019.08-28 54
IA 109 2019-09-18 353
Lk 108 2019-10-23 352
IA 107 2019-09-09 351
IA 1.9.¢ 2019-11-01 ESQ
IA 105 2019-09-18 349
IA 104 2019-08-09 348
IA isl 2019.08-12 liz
1A 12Z 2019.08-12 II&
1A 101 2019.08-28 345
1A 100 2019-08-01 344
1A 99 2020-01-08 343
1A 98 2019-12-30 343
EFTA01730754
LA 97 2019-12-30 343
IA 96 2019-12-02 343
1A 21 2019-10-01 al
IA a 2019-10-15 3a
1A 93 2019-12-17 339
1A 22 2019-12-17 laa
1A a 2019.09-19 331
1A 90 2019-10-16 334
1A 89 2019-10-16 333
1A 88 2019-10-15 332
1A 87 2019-09-18 330
1A 86 2019.09-19 329
1A 85 2019-11-14 327
1A M 2019-09-28 321
1A $.5 2019-07-31 315
1A 82 2019-07-12 324
1A 81 2019-11-13 322
1A N 2019.08-28 316
1A n 2019-08-27 315
Lk 78 2019-08-29 306
lA 77 2019-08-29 306
m 16 2019-08-06 30
IA Z5 2019.09-24
IA 74 2019-07-05 300
1A 73 2019.08-27 298
1A 22 2019-07-11 22Z
1A 71 2019-07-12 296
1A 70 2019-08-13 294
1A 69 2019-09-16 289
LA 68 2019-07-12 286
lA §.2 2019-09-05 /8.5
1A a 2019-09-05 283
lA 65 2019.09-14 281
1A 0 2019-08-13 2Z/
IA 63 2019.08-24 272
IA 62 2019-08-28 271
LA 61 2019-08-27 270
IA 60 2019-08-13 269
LA 52 2019-08-12 2.0
IA 58 2019-08-12 268
IA 57 2019-08-12 268
LA a 2019.08-12 211
1A II 2019.08-12 268
1A sit 2019.08-11 268
1A 53 2019-08-20 264
1A 52 2019-08-13 261
1A 91 2019-08-28 258
EFTA01730755
1A 50 2019-08-27 257
IA 49 2019-08-07 252
1A g 2019-07-11 2g
1A 47 2019.08-16 /31
1A 46 2019-07-24 216
1A 4.5. 2019-08-09 214
1A 44 2019-07-29 212
1A 43 2019-07-31 208
1A 42 2019-07-31 207
1A 41 2019-08-02 206
1A 40 2019-07-11 203
1A 39 2019-07-11 202
1A 38 2019-07-06 194
1A az 2019-07-17 M
1A 3..¢ 2019-07-13 MI
1A 35 2019-07-13 187
1A 34 2019-07-14 186
1A 33 2019-07-11 185
1A 32 2019-07-02 183
1A 31 2019-07-16 175
ia 30 2019-07-17 171
m as 2019-07-06 MI
IA a 2019-07-12 16_¢
IA 27 2019-07-19 159
IA 26 2019-07-17 153
IA 22 2019-07-17 M
IA 24 2019-07-11 151
1A 23 2019-07-06 150
ia 22 2019-07-07 14/
1A 21 2019-07-12 127
1A 20 2019-07-11 116
1A 12 2019-05-29 142
IA 18 2019-07-06 2
IA 17 2019-07-08 49
IA 16 2019-06-24 30
IA 15 2019-05-29 26
IA 14 2019-05-08 25
ia 13 2019-05-23 24
1A 12 2019-05-02 21
1A fl 2019-04-24 2Q
1A 14 2019.04-26 12
1A 9 2019.04-11 17
1A 8 2019-03-22 16
1A 7 2019-03-22 14
1A 6 2019-03-20 13
EFTA01730756
LA 5 2019-03-19 12
IA 4 2019-03-25 11
m A 2019-03-19 12
IA 2 2019-03-04 I
IA 1 2019-01-30 5
EFTA01730757
Serial Title
(U) Transport of Evidence Items 16136, 16144, 16145, and 1B146
(U) Transport of Evidence Items 1B136, 16144, 16145, and 16146
(U) Transport of Evidence Items 16136, 16144, 16145, and 1B146
(U) Transfer of Case Documents from the New York Field Office to the Washington Field Office
(U) Interview of [REDACTED]
(U//FOUO) Identification of [REDACTED] as a possible associate of JEFFREY EPSTEIN
(U) Mail Received from Epstein Residence
(U) Phone Interview with [REDACTED]
(U) Defense Notes for [REDACTED]
(U) Telephonic Interview of [REDACTED]
(U) Telephonic interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Phone conversation with [REDACTED]
(U) Call with [REDACTED]
(U) Reimbursement of expenses incurred for trial
(U) Reimbursement of expenses incurred for trial
(U) Interview of [REDACTED]
(U) Materials from Palm Beach Police Department
(U) Materials from Palm Beach Police Department
(U) Materials from Palm Beach Police Department
(U) Materials from Palm Beach Police Department
U//FOUO NTOC2021 E-Tip Additional Victim Reports Being Human Trafficked By Gislaine Maxwell M A Child (7
U NTOC2020 352mtr01Information on a Possible Accountant of Jeffrey Epstein. (NY)
U//FOUO NTOC2020 024srm01 E-Tip: Possible Human Trafficking in New York, NY. (NY)
U USPS Mail Tipster - Information Related to Jeffrey Epstein/Unnamed 29 YOA Jewish Female
U NTOC2020 195hmb02 Potential Sex Trafficking by [REDACTED] and [REDACTED) in New York, NY (NY)
U Email regarding information for sale about the Epstein Zorro Ranch
U//FOUO NTOC2021Conceming Comments by (REDACTED]. (NY)
(U) Reimbursement of expenses incurred for trial
(U) Reimbursement of expenses incurred for trial
(U) Fed-Ex Delivery Confirmation
(U) Interview of [REDACTED]- September 2, 2021
(U) Meeting with [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Proffer of [REDACTED]
(U) Proffer of [REDACTED]
EFTA01730758
(U) Service of subpoena.
(U) Interview of [REDACTED] - September 1, 2021
(U) Interview of [REDACTED) - September 1, 2021
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview/Proffer of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Proffer of [REDACTED)
(U) Proffer of [REDACTED)
(U) interview of [REDACTED]
(U) Interview of [REDACTED] - August 30, 2021
(U) Interview of [REDACTED] - August 31, 2021
(U) Request to serve three trial subpoenas
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED) - July 27, 2021
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) [REDACTED] Interview 8/4/2021
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Locate and Serve witness (REDACTED)
(U) Missouri Birth Certificate Identified and obtained
(U) Missouri Birth Certificate Identified and obtained
(U) Device Extraction - MDUS 13768
(U//FOUO) Collection of evidence in Austin, Texas
(U) lA Lab Report Material: Lab it (REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Introductory conversation with [REDACTED)
(U) 2021-00585-2 Questioned Documents
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED] - Day 3
EFTA01730759
(U) Interview of [REDACTED) - Day 3
(U) Interview of [REDACTED] - Day 1
(U) Interview of [REDACTED)
(U) Virtual Interview of [REDACTED]
(U) Telephonic Interview of [REDACTED]
(U) Interview of[REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Introductory Conversation with [REDACTED]
(U) Interview of [REDACTED] - Day 2
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Proffer of [REDACTED]
(U) Interview/Proffer of [REDACTED]
(U) Interview/Proffer of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
( -013.pdf
(U) Call received from [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Victim Services Division - Case Support Unit Assistance
(U) Interview of [REDACTED]
(U) Fund Reimbursement - Five 2TB Hard drives
(U) Fund Reimbursement - Five 2TB Hard drives
(U) Fund Reimbursement - Five 2TB Hard drives
(U) Fund Reimbursement - 12 TB External Hard Drive
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
EFTA01730760
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U//FOUO) Interview of [REDACTED]
(U//FOUO) Interview of [REDACTED]
(U) Lead Request to Serve grand Jury subpoena [REDACTED]
(U) Lead Request to Serve grand jury subpoena [REDACTED]
(U) Lead Request to Serve grand jury subpoena [REDACTED]
(U) Lead Request to Serve grand Jury subpoena [REDACTED]
(U) Lead Request to Serve grand jury subpoena [REDACTED]
(U) Lead Request to Serve grand jury subpoena [REDACTED]
(U) Date Submitted: 07/25/2020 10:08:31AM ET Transaction Number: 4D291278-35FF-489A-A26C
(U) On 07/21/2020, at 2:17 a.m. Eastern Time, [REDACTED], date of birth [REDACTED],
(U//FOUO) Telephone Interview Of [REDACTED]
(U) Arrest of GHISLAINE MAXWELL
(U) Arrest of GHISLAINE MAXWELL
(U//FOUO) Impersonation of FBI Agent
(U//FOUO) Interview of [REDACTED]
(U) On 07/12/2020, at 3:12:08 PM Eastern Time, [REDACTED], date of birth [REDACTED],
(U) On 07/11/2020, at 10:02 a.m. Eastern Time, an anonymous tipster, Internet Protocol
(U) On 07/09/2020, at 9:47 p.m. Eastern Time, [REDACTED], email address [REDACTED]
(U) On 07/10/2020, at 9:44 a.m. Eastern Time, an anonymous tipster, Internet Protocol (IP
(U) On 07/10/2020, at 9:22 a.m. Eastern Time, an anonymous tipster, Internet Protocol (IP
(U) Fund Reimbursement
(U) On 07/06/2020, at 10:19 AM Eastern Time, the FBI Office of Public Affairs (OPA)
(U//FOUO) Aerial photos of [REDACTED]
(U) On 07/06/2020, at 12:33:51PM Eastern Time, an anonymous complainant, Email account
(U//FOUO) Interview of [REDACTED]
(U) Information provided by [REDACTED]
(U) Interview of [REDACTED] on 10/25/19
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED] on 11.21.19
(U) Interview of [REDACTED]
EFTA01730761
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Proffer of [REDACTED] interview #2
(U) Proffer of [REDACTED] Interview B1
(U) interview of[REDACTED] on 10/11/2019
(U) Pass information to Swedish authorities for informational purposes.
(U) Interview of [REDACTED]
(U) Share information with Swedish Authorities
(U) interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Proffer of[REDACTEDI
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Epstein Breifing EVAF Expenditures
(U) Phone conversation with [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Phone call with Attomey[REDACTED]
(U) Interview of [REDACTED]
(U)[REDACTED] interview
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) interview of [REDACTED]
(U) Epstein Breiflng EVAF Expenditures
(U) Epstein Breifing EVAF Expenditures
EFTA01730762
(U) Epstein Breifing EVAF Expenditures
(U) Epstein Breifing EVAF Expenditures
(U) Epstein Breifing EVAF Expenditures
(U) Interview of [REDACTED]
(U) Emergency Victim Funds and Budget Matters, Office of the Director
(U) Emergency Victim Funds and Budget Matters, Office of the Director
(U)[REDACTED] interview
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED] on 9/19/2019
(U) Interview of [REDACTED] on 11/14/2019
(U) Interview of [REDACTED]
(U) Interview of [REDACTED] on 7/31/19
(U) Proffer of (REDACTED) Interview #1
(U) Victim Services Division - Victim Meeting
(U) Interview of [REDACTED]
(U) (REDACTED] Interview
(U) Lead Forwared to Legat Mexico City, Mexico
(U) Lead Forwared to Legat Mexico City, Mexico
(U) Interview of [REDACTED]
(U) Emergency Victim Funds and Budget Matters, Office of the Director
(U) Interview of [REDACTED]
(U)(REDACTED] interview
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Device Unlock and Extraction - MDUS 10398
(U) Device Unlock and Extraction - MDUS 10399
(U) On 09/14/2019, at 2:58 p.m. Eastern Time, (REDACTED], date of birth (REDACTED]
(U) Interview of [REDACTED]
(U) FBI New York - Jeffrey Epstein - Child Sex Trafficking - 190904-175728
(U) Follow-Up Law Enforcement Inquiries Pertaining to [REDACTED]
(U) Interview Of [REDACTED]
(U) (REDACTED]
(U) Search Warrant Execution - Little Saint James
(U) Search Warrant Execution - Little Saint James
(U) Search Warrant Execution - Little Saint James
(U) Search Warrant Execution - Little Saint James
(U) Search Warrant Execution - Little Saint James
(U) Search Warrant Execution - Little Saint James
(U//FOUO) [REDACTED] (PROTECT SOURCE) Interview #3
(U) Phone interview of (REDACTED]
U (REDACTED] - financial connection to JEFFREY EPSTEIN
EFTA01730763
U NTOC2019 1971(103 E-Tip: Information Regarding Multiple Criminal Allegations such as Human Sex Traffi
(U//FOUO) [REDACTED] (PROTECT SOURCE) Interview 42
(U) Inventory of Two Suite Cases (black/blue) for JEFFREY EPSTEIN
(U) On 8/15/19, at 11:15 a.m. Eastern Time, the FBI Office of Public Affairs (OPA)
(U//FOUO) [REDACTED] (PROTECT SOURCE) Interview One
(U) On 08/08/2019, at 9:02 a.m. Eastern Time, [REDACTED], date of birth [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Return of Property to [REDACTED] on 08/02/2019
(U) Interview of [REDACTED]
(U) Interview of [REDACTED) on 07/11/2019
(U) Post Arrest Spontaneous Utterances made by Defendant JFFREY E. EPSTEIN
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Arrest of JEFFREY EPSTEIN
(U) Jeffrey Epstein
(U) Interview of [REDACTED]
(U) Interivew of [REDACTED]
(U) Interview of [REDACTED] on 07/15/2019
(U) Provide information to SEATTLE FO for conducting interview
(U) On 07/17/2019, at 3:43 p.m. Eastern Time, the FBI's Office of Public Affairs (OPA)
(U) On 07/17/2019, at 3:51p.m. Eastern Time, the FBI Office of Public Affairs (OPA)
(U) Search Warrant Executed- 9 East 71st Street, New York, New York 10021
(U) Interivew of [REDACTED]
(U) Attempted Interview of GHISLAINE MAXWELL
(U//FOUO) On 07/11/2019, at 10:56 p.m. Eastern Time, tipster email address [REDACTED]
(U) On 07/11/2019, at 2:31a.m., Eastern Time, the FBI Office of Public Affairs (OPA)
(U) Interview of [REDACTED) on 5/29/2019
(U) Search Warrant Executed- 9 East 71st Street, New York, New York 10021
(U//FOUO) On 07/08/2019, at 1:10 P.M. Eastern Standard Time, the Office of Public Affairs
(U) 31E-NY-3027571
(U) Interview of [REDACTED] on 5/29/2019
(U) Interview of [REDACTED) on 5/8/2019
(U) Interview of [REDACTED]
(U) Interview of [REDACTED] on 5/2/2019
(U) Interview of [REDACTED)
(U//FOUO) TECS Silent Hit Notification
(U) Interview of [REDACTED)
(U) interview of [REDACTED]
(U) Interview of [REDACTED)
(U) Interview of [REDACTED]
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(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
(U) Interview of [REDACTED]
EFTA01730765
Summary
(U) Chains of Custody
(U) Ending Transport Photographs
(U) Starting Transport Photographs
(U) Photos and Photo Logs
(U) Agent Notes
(U//FOUO) Email from [REDACTED] and attachments from Null
(U) letter from former Epstein Estate; fake NY State Driver's license
(U) [REDACTED) interview notes
(U//FOUO) Defense notes for [REDACTED]
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) interview notes
(U) digital notes
(U) Digital notes, household manual
(U) Notes
(U) [REDACTED] notes
(U) 794
(U) Receipt
(U) [REDACTED) interview notes
(U) Property receipt
(U) Trash pull
(U) Digital case files
(U) Subpoena
U 755162_NY
U 696289_NY
U 708478_NY
U 664501_NY
U 658904_NY
U 603998_NY
U 751864_NY
(U) Receipt
(U) FD-794
(U) Fed-Ex Delivery Confirmation, #1864 0967 1500
(U) [REDACTED] Interview notes - 9.2.21& Scan shown to NB
(U) Notes - [REDACTED]
(U) notes & doncuments
(U) Emails from [REDACTED]
(U) [REDACTED] interview notes
(U) Notes
(U) Notes
(U) Notes
(U) Documents shown to [REDACTED)
(U) [REDACTED] interview notes
EFTA01730766
(U) Drivers license information for each individual.
(U) News article shown to [REDACTED]
(U) Notes
(U) Documents shown to [REDACTED]
(U) [REDACTED] interview notes
(U) [REDACTED) Interview notes
(U) Notes
(U) Notes
(U) Notes
(U) [REDACTED] interview notes
(U) Documents shown to [REDACTED]
(U) Notes
(U) Notes
(U) Notes
(U) Trial Subpoenas
(U) photobook
(U) Nude photo of [REDACTED]
(U) Items shown to [REDACTED) during interview
(U) Notes
(U) [REDACTED] interview notes
(U) Notes
(U) notes
(U) Notes
(U) Notes
(U) Messages pads
(U) notes
(U) Notes
(U) Transcript
(U) Epstein phone contact
(U) Notes
(U) Notes
(U) Trial Subpoena - [REDACTED]
(U) Copy of FedEx shipment with tracking number 774263190664
(U)[REDACTED] Farmer Certified Birth Certificate
(U) Legal Authority for Device
(U//FOUO) FD-597
(U) Lab # [REDACTED): 1 disk
(U) Photo provided by [REDACTED]
(U) [REDACTED] interview notes
(U) [REDACTED) Interview notes
(U) [REDACTED] notes
(U) 2021-00585-2 QUESTIONED DOCUMENTS
(U) [REDACTED] interview notes
(U) Interview Notes
(U) Interview notes
(U) Photographs provided via email by [REDACTED)
(U) Photo from Myspace account
EFTA01730767
(U) Interview notes day 3
(U) Interview notes day 1
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Emails
(U) Statement referenced in interview
(U) Interview notes
(U) Interview notes
(U) Notes
(U) Interview notes day 2
(U) Interview Notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) [REDACTED] flight log
(U) interview notes
(U) [REDACTED] interview notes
(U) Interview notes
(U) Interview notes
(U) [REDACTED] involvement in U.S. Presidential pardon petitions and influences
from Russia and Israel on [REDACTED] and [REDACTED]
(U) notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U) [REDACTED] Interview notes
(U) Latest contact information tracked and updated by ODAG partners.
(U) Interview notes
(U) 10.21HD Receipt
(U) 10.22 HD Receipt
(U) 10.9 HD Receipt
(U) Receipt
(U) Interview notes
(U) Interview Notes
(U) Interview notes
(U) Interview notes
(U) [REDACTED] interview notes
EFTA01730768
(U) Interview notes
(U) Interview notes
(U) Interview notes
(U//FOUO) Notes Re: Interview of [REDACTED] on July 27, 2020.
(U//FOUO) City of Maricopa Police Department Officer Report for D.R. 200722037
(U) Subpoena
(U) Accurint
(U) Subpoena
(U) Accurint
(U) Subpeona
(U) Accurint
(U) (U//FOUO) THE INFORMATION CONTAINED HEREIN HAS BEEN DETERMINED BY
THE FBI TO BE PERTINENT TO & WITHIN THE SCOPE OF AN AUTHORIZED LAW
ENFORCEMENT ACTIVITY & SHOULD BE CONSIDERED IN THE CONTEXT OF THE
ASSESSMENT OR PREDICATED INVESTIGATION TO WHICH THE INFORMATION
RELATES. PARTICULAR ATTENTION SHOULD BE GIVEN TO THE AUTHORIZED
PURPOSE FOR COLLECTING & RECORDING THIS INFORMATION PURSUANT TO THE
ATTORNEY GENERAL'S GUIDELINES FOR DOMESTIC FBI OPERATIONS & THE
DOMESTIC INVESTIGATION & OPERATIONS GUIDE. THAT PURPOSE MAY BE SET
FORTH IN THE FILE'S OPENING ELECTRONIC COMMUNICATION OR OTHER RELATED
DOCUMENTS.
(U) Screenshot of Reddit post by user [REDACTED)
(U//FOUO) NYPD SVD Hotline Worksheet
(U) Photo
(U) Arrest warrant, arrest paperwork, notes
(U//FOUO) Document and audio recording from Bradford (NH) Police
(U//FOUO) Interview notes of [REDACTED]
(U) Graphic Capture of Viral Video.
(U) screenshot of [REDACTED] Quora page
(U) Screenshots of Epstein's alleged employee's confession on YouTube and 4chan
(U) Website [REDACTED]
(U) Screenshots from [REDACTED]
(U) Receipt
(U) Reported Tweets to NTOC
(U//FOUO) Aerial photos of [REDACTED]
(U) Screen shot of Imgur capture of the comment made by[REDACTED)
(U//FOUO) Notes from [REDACTED]
(U) Photographs provided by [REDACTED]
(U) (REDACTED] interview notes
(U) Interview notes & documents provided by [REDACTED]
(U) [REDACTED] interview notes
(U) Flight logs
(U) [REDACTED] Interview notes
(U) (REDACTED] interview notes
(U) (REDACTED) interview notes
(U) (REDACTED] interview notes
EFTA01730769
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) Two boxes of papers and media from PBPD
(U) Interview Notes
(U) Interview notes
(U) Interview Notes
(U) Interview Notes & police report
(U) Interview notes
(U) Photo provided by [REDACTED] and [REDACTED] attorneys
(U) Interview notes
(U) [REDACTED] interview notes
(U) interview notes
(U) [REDACTED] interview notes
(U) [REDACTED] 302
(U) Interview Notes
(U) [REDACTED] 302
(U) [REDACTED] interview notes
(U) Photo Book
(U) Interview notes
(U) Interview notes
(U) [REDACTED] interview notes
(U) Interview notes and Message pad copies shown
(U) [REDACTED] Interview notes
(U) Interview notes
(U) Interview notes
(U) Facebook Profile Screenshots
(U) [REDACTED] interview notes
(U) Photos
(U) Emails
(U) Interview notes
(U) [REDACTED] W Hotel charges, approval to accept charge, and proof of refund.
(U) [REDACTED] phone call notes
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) Interview Notes
(U) Interview notes
(U) Interview notes
(U) (REDACTED] Notes
(U) Interview Notes
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) [REDACTED] Interview notes
(U) [REDACTED] interview notes
(U) [REDACTED] Lodging
(U) [REDACTED] Lodging
EFTA01730770
(U) [REDACTED] Lodging
(U) [REDACTED] Reimbursement
(U) Receipts of EVAF Expenditures for Epstein Victims
(U) Interview Notes
(U) Receipts
(U) Receipts
(U) Interview notes
(U) Interview Notes
(U) Interview Notes
(U) Interview Notes
(U) Interview notes
(U) [REDACTED] interview notes
(U) Interview notes
(U) Interview notes
(U) Interview notes and photos provided by [REDACTED]
(U) Interview notes
(U) RSVP/potential victim list, templates, reminders and overviews
(U) interview notes
(U) Interview notes
(U) VA DMV image of [REDACTED)
(U) DMV images of [REDACTED], [REDACTED) and [REDACTED], [REDACTED).110 reports concerning [REDA
(U) Interview notes
(U) Receipts
(U)[REDACTED] Grand Jury Subpoena
(U) Interview Notes
(U) Interview notes
(U) interview notes
(U) [REDACTED] Notes
(U) Interview Notes
(U) Interview notes
(U) Administrative Documents
(U) Administrative Documents
(U) Screenshot of YouTube Video, [REDACTED]
(U) Interview notes
(U) Enclosed are the IC3 complaints
(U) Police Records from Cranston RI Police Department
(U) Interview Notes
(U) Interview notes
(U) Receipt for Property (FD-597)
(U) Charlie and Delta Zone, with Bravo's Building 6, Search Paperwork
(U) Bravo Zone Search Paperwork
(U) Alpha Zone Search Paperwork
(U) Evidence Log, Sign•in Log, map, notes
(U) Search Warrant Little Saint James
(U//FOUO) Interview Notes
(U) Interview Notes
U S79223_CV
EFTA01730771
U 566318_PH
(U//FOUO) Interview Notes, images provided
(U) two (2) property receipts, one (1) inventory log, 1 (one) ERT photographic log and one CD with photogral
(U) Twitter screenshots of the links provided.
(U//FOUO) Interview Notes and photograph of (REDACTED]
(U) [REDACTED] NCIC
(U) Notes
(U) Notes
(U) Notes
(U) (1) DVD of photos, (2) original signed receipt for property forms FD-597, (1) business card
(U) original handwritten notes of [REDACTED] interview on 07/11/2019
(U) copy of Handwritten contact information for [REDACTED), his attorney [REDACTED], and property manal
(U) Photocopy of working folder pertaining to arrest paperwork of JEFFREY E. EPSTEIN
(U) Interview notes
(U) Interview Notes
(U) Interview Notes
(U) Interview Notes
(U) Interview Notes
(U) Epstein arrest warrant
(U) Arrest paperwork, search warrant, photographs disc
(U//FOUO) Interview Notes [REDACTED] 7/17/2019
(U) [REDACTED] Florida Identification
(U) Original Handwritten Interview Notes of [REDACTED] on 07/12/2019
(U) TLO report and WASHINGTON STATE DL image of potential victim to be interviewed.
(U) Twitter screenshots - [REDACTED]
(U) Twitter Post.
(U) Search warrant execution log, FBI Sign in log, Evidence Collected item log, copy
of search warrant, (1) FD-597 Forms, (1) DVD disk of Search photos
(U) [REDACTED] Notes
(U) Documents from UPS
(U) Attachments from tipster.
(U) twitter screenshot
(U) [REDACTED] Interview notes
(U) original search logs, copy of search warrant, (1) signed FD-597, (1) DVD disk of Search photos
(U//FOUO) Twitter Username [REDACTED]
(U) Fed-EX signature confirmation page.
(U) [REDACTED] interview notes 5.29.19
(U) Interview notes 5/8/19
(U) Interview notes
(U) Interview notes 5.2.19, Photos 1 through 19 and A through F
(U) [REDACTED] Interview Notes
(U//FOUO) TECS silent hit entered
(U) [REDACTED] interview notes
(U) (REDACTED] Interview notes
(U) (REDACTED). Interview notes
(U) [REDACTED] Interview notes
EFTA01730772
(U)[REDACTED]Interview Notes
(U) [REDACTED] interview notes
(U) [REDACTED] interview notes
(U) Interview notes
(U) Interview notes
EFTA01730773
EFTA01730774
p 2021-00585-2 IA.4 CASE COMMUNICATION LOG: Con
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tmunicadonLog2021-00585.pdf CASE NOTE INTERFACE REPORT: CNI Questioned Documents (AF)
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EFTA01730786
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ase Note (143683).p CASE FILES: 2021-00585 #1, Lead 17.pdf 2021-00585 Shipping Invoice C
EFTA01730791
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EFTA01730793
EFTA01730794
EFTA01730795
EFTA01730796
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ntainer C.pdf 2021-00585 #1 LER, Seria 575.pdf 2021-00585 Shipping Invoice Container B.p
EFTA01730799
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if 2021-00585 Al Check-In Notes.rtf CASE CHAIN OF CUSTODY: Chain0Kustody2021-005854
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df CASE RECORD REPORT: CaseReport2021-00585 Record #2.pdf CASE COMMUNICATION LOG FIL
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S: 2021-00585_UNCLASS.pdf CASE REPORT: CaseReport2021-00S8S.pdf CASE RECORD FILES
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2021-00585 Item 3 Matchmaker Images.pdf
EFTA01730831
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EFTA01730839
Evidence Report for Case: 50D-NY-3027571
Filtering on: Type(s):1B
Item # Collected On
1B146 7/22/2022 10:00
1B145 5/25/202214:00
1B144 5/25/2022 14:00
1B143 7/7/2019 3:00
1B142 10/8/202113:00
1B141 10/8/202113:00
1B140 10/8/202113:00
1B139 6/29/202116:15
18138 8/12/2019 19:20
1B137 8/28/2006 11:50
1B136 1/26/202116:00
1B135 6/6/2019 12:00
1B134 8/28/2006 11:00
1B133 8/28/2006 11:00
1B132 8/28/2006 11:50
18131 8/28/2006 11:50
1B130 8/28/2006 11:50
1B129 8/28/2006 11:50
1B128 8/28/200611:50
18127 8/28/2006 11:50
18126 8/12/2019 19:20
1B125 8/12/2019 19:20
1B124 8/12/2019 19:20
1B123 8/12/2019 19:20
1B122 8/12/2019 19:20
1B121 8/12/2019 19:20
1B120 8/12/2019 19:20
1B119 8/12/2019 19:20
1B118 8/12/2019 19:20
1B117 8/12/2019 19:20
1B116 8/12/2019 19:20
1B115 8/12/2019 19:20
1B114 8/12/2019 19:20
1B113 8/12/2019 19:20
18112 8/12/2019 19:20
1B111 8/12/2019 19:20
1B110 8/12/2019 19:20
1B109 8/12/2019 19:20
1B108 8/12/2019 19:20
1B107 8/12/2019 19:20
18106 8/12/2019 19:20
11105 8/12/2019 19:20
1B104 8/12/2019 19:20
EFTA01730840
18103 8/12/2019 19:20
1B102 8/12/2019 19:20
18101 8/12/2019 19:20
1B100 8/12/2019 19:20
1B99 8/12/2019 19:20
1898 8/12/2019 19:20
1B97 8/12/2019 19:20
1B96 8/12/2019 19:20
1B95 8/12/2019 19:20
1B94 8/12/2019 19:20
1893 8/12/2019 19:20
1B92 8/12/2019 19:20
1691 8/12/2019 19:20
1690 8/12/2019 19:20
1889 8/12/2019 19:20
1888 8/12/2019 19:20
1887 8/12/2019 19:20
1886 8/12/2019 19:20
1685 8/12/2019 19:20
1884 8/12/2019 19:20
1683 8/12/2019 19:20
1682 8/12/2019 19:20
1881 8/12/2019 19:20
1680 8/12/2019 19:20
1679 7/11/2019 15:35
1B78 7/11/2019 15:35
1B77 7/11/2019 15:35
1B76 7/11/2019 15:35
1B75 7/11/2019 15:35
1B74 7/11/2019 15:35
1B73 7/11/2019 15:35
1872 7/6/2019 18:15
1871 7/6/2018 18:15
1870 7/11/2019 19:28
1869 7/11/2019 19:28
1B68 7/11/2019 19:28
1867 7/11/2019 19:28
1B66 7/11/2019 19:28
1865 7/11/2019 19:28
1B64 7/11/2019 19:28
1B63 7/11/2019 19:28
1862 7/11/2019 19:28
1B61 7/11/2019 19:28
1860 7/11/2019 19:28
1B59 7/11/2019 19:28
1658 7/11/2019 19:28
1857 7/11/2019 19:28
EFTA01730841
1856 7/11/2019 19:28
1B55 7/11/2019 19:28
1B54 7/11/2019 19:28
1653 7/11/2019 19:28
1B52 7/11/2019 16:28
1B51 7/11/2019 16:28
1B50 7/11/2019 16:28
1849 7/11/2019 16:28
1848 7/11/2019 16:28
1847 7/11/2019 16:28
1846 7/11/2019 16:28
1845 7/11/2019 19:28
1844 7/11/2019 19:28
1843 7/11/2019 19:28
1842 7/11/2019 19:28
1841 7/11/2019 19:28
1840 7/11/2019 19:28
1B39 7/11/2019 19:28
1B38 7/11/2019 19:28
1837 7/11/2019 19:28
1B36 7/11/2019 19:28
1835 7/11/2019 19:28
1B34 7/11/2019 19:28
1833 7/11/2019 19:28
1B32 7/11/2019 19:28
1B31 7/11/2019 19:28
1B30 7/11/2019 19:28
1B29 7/11/2019 19:28
1B28 7/11/2019 19:28
1827 7/7/2019 3:00
1826 7/7/2019 3:00
1825 7/7/2019 3:00
1824 7/7/2019 3:00
1823 7/7/2019 3:00
1822 7/7/2019 3:00
1821 7/7/2019 3:00
1B20 7/7/2019 3:00
1819 7/7/2019 3:00
1818 7/7/2019 3:00
1817 7/7/2019 3:00
1816 7/7/2019 3:00
1815 7/7/2019 3:00
1B14 7/7/2019 3:00
1813 7/7/2019 3:00
1812 7/7/2019 3:00
1811 7/7/2019 3:00
1810 7/7/2019 3:00
EFTA01730842
1B9 7/7/2019 3:00
188 7/7/2019 3:00
1B7 7/7/2019 3:00
1B6 7/7/2019 3:00
1B5 7/6/2019 0:00
1B4 5/29/201918:00
1B3 5/29/201918:00
1B2 5/29/2019 18:00
1B1 5/29/201918:00
EFTA01730843
Description
(U) ONE CELLOPHANE containing: NYC032395 - One (1)DVD-R containing image log files and FTK reports for systel
(U) Red Rope Containing;NYC032391- Three (3) LTD 6 tape cartridges containing an Arcserve backup of all digital
(U) Red Rope Containing;NYC032392 - Two(2) LTO 6 tape cartridges containing an Arcserve backup of all digital evi
(U) one (1) CD labelled "girl plcs nude book 4"
(U) ONE REDROPE CONTAINING: (1) Envelope containing 1 VHS tape, 2 cassette tapes & 4 micro cassette tapes
(U) ONE REDROPE CONTAINING: (1) Envelope containing 4 CD's
(U) (2) Bankers box containing various EPSTEIN related case materials
(U) ONE BOX CONTAINING: One pair of black women's cowboy boots, size 8
(U) ONE CELLOPHANE containing: Disk containing images of Matchmaker shred reconstruction
(U) ONE CELLOPHANE CONTAINING: (1) un-framed photo.
(U//FOUO) ONE RED ROPE containing: Highly confidential responsive material to include nude and semi nude ima
(U) Box containing Ten yearbooks collected by FBI West Palm Beach Resident Agency
(U) One (1) peach massage table.
(U) One (1) green massage table (PBPD0S-1024).
(U) One (1) beige massage table.
(U) One (1) brown massage table.
(U) One flat box containing one (1) large framed photo.
(U) One box containing four (4) framed photos.
(U) One box containing twelve (12) framed photos.
(U) One box containing five (5) framed photos
(U) One red rope containing: LSJ logbook
(U) One red rope containing:Daily Vessel Trip logs Feb 2, 2017 - Feb 16, 2017
(U) HP Tower S/N: CNV74213M3 Model: 570-p056
(U) Lenovo Tower S/N: 153306G2USAIXEKGX
(U) Lenovo Tower S/N: M107YG6U Machine type: 90J0
(U) Mac DesktopS/N: W89524C2SPJ model A1312
(U) HP TowerS/N: CNV716004YModel #: 260-a010
(U) HP Desktop TowerS/N: CNV7160050Model #: 260-a010
(U) Silver Mac desktop
(U) 6 Bay with 146GB drivesS/N: MXQ824A1R
(U) One box containing Panasonic KX-TDE100S/N: KX-TDA01049LCCD005398
(U) HP server with (4) 500 GB drivesS/N: MXQ3220187
(U) Blue prints
(U) One cellophane containing:Boat trip log & employee lists
(U) Unifi serverMacID: 1735K788A20463234-8uuu9FFCCID: SWX-UASPRO
(U) Unifi videoM/N: UVC-NVR-2TBMacID: 1829FB4FBE426EA90
(U) One cellophane containing:Paper with passwords on both sides
(U) Unifi Cloud keyM/N: UN-CKFCCID: SWX-UCCKIC 6545A-UCCKMac ID: 1843KB4FBE4D30C69-dcRgm9
(U) CELLOPHANE containing Olympus Digital Voice Recorder
(U) Silver Mac desktopModel #: A1311S/N: W804736DDA5
(U) Dell Inspiron tower with power cordReg Model: D19MQCHFA335
(U) One red rope contalning:LSJ & GSI Boat Log 2019
(U) Box containing Shredded paper
EFTA01730844
(U) ONE CELLOPHANE CONTAINING; Apple iPod shuffle on watch band
(U) Silver Macbook Desktop with keyboard
(U) One cellophane containing:Photograph
(U) One cellophane containing:Employee contact list
(U) One red rope containing:Red Nikon Camera
(U) One box containing: Silver Desktop Mac with keyboard
(U) HP Laptop with chargerS/N: CND81368V5
(U) Toshiba Laptop with charger
(U) One red rope containing:Remodeling documents for Island
(U) One cellophane containing:Handwritten notes on LSJ notepad
(U) One flat FedEx box containing: Photos, Photo negatives, letter
(U) One red rope containing:lsland blueprints, island photos, and documents
(U) One red rope containing:photo album of girl & Epstein
(U) One red rope containing:letter, photo album of girls, photos of island
(U) One cellophane containing:Document with names
(U) One cellophane containing:Employee contact list
(U) Silver Mac Desktop
(U) One red rope containing: Notepads with notes - LSJ stationary with handwritten notes
(U) Silver Mac Desktop with mouse & keyboardS/N: C02NM1MOFY14
(U) Silver iPad Model A15675/N: DMPQL1RMG5Yin case
(U) CELLOPHANE containing Silver iPad Model A15675/N: DMPQL25NGSYPYin case
(U) RED ROPE containing Silver MacBook ProS/N: C02QMOGUGWDP
(U) Silver Mac Laptop labeled "JE BIG LAPTOP" "BLACK BAG" in black bag S/N: W89111772QT
(U) Mac Desktop labeled "Kitchen Mac" - grey
(U) One heat-sealed bag containing one yellow envelope marked "SK" dated 08/27/08 containing multiple smaller
(U) RED ROPE CONTAINING: 4 binders with 68 discs inside
(U) One heat-sealed bag containing one small white envelope with writing "2000-SK" containing $4,400 USC (44 x
(U) ONE CELLOPHANE CONTAINING; Austrian Passport with Epstein photograph
(U) RED ROPE CONTAINING: Two blue binders with 58 discs inside
(U) CELLOPHANE containing Black hard drive
(U) CELLOPHANE containing Black hard drive
(U) One (1) silver IPad with serial number DLXQGM3KGMW3.
(U) ONE CELLOPHANE CONTAINING :One (1) black iPhone with
(U) One box containing: 1 Apple Desktop computer
(U) 1 Silver IPAD - 64GB
(U) 1 Space Gray Apple IPAD
(U) 1 Space Gray Apple IPAD
(U) One cellophane containing 1 Black Radioshack recorder
(U) One cellophane containing 1 Silver Olympus recorder
(U) One cellophane containing 1 Sony BM-560 Recorder
(U) Box containing 45 Assorted Cd's
(U) One red rope containing 1 Sony Vaio Laptop
(U) 1 Dell Precision Tower 5810
(U) One red rope containing:1Seagate Barracuda 7200 harddrive 80GB
(U) 1 MSI PC Computer IN A BROWN BOX
(U) One red rope containing:1Sony Camera with black case
(U) 1 Gray Apple Desktop Computer with keyboard and mouse
EFTA01730845
(U) One cellophane containing 1 Seagate Backup Plus Portable Drive - 1TB
(U) One cellophane containing one (1) White Apple (Phone 5, 64GB.
(U) 1 Apple Desktop Computer with keyboard and mouse
(U) 1 Apple Desktop Computer with keyboard and mouse
(U) One cellophane containing:1SPIEF 2014 Silver USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Cruzer Guide 32GB USB
(U) One cellophane containing 1 Blue EMTEC 16 GB USB
(U) One cellophane containing 1 EMTEC 16 GB USB
(U) One red rope containing:10 assorted cd's
(U) One cellophane containing 3. Silicone Power Micro SD Adapter with 16GB SD Card
(U) 1 DELL Machine
(U) 1 Cube 9000 Siteserver, (BLACK/SILVER)
(U) 1 HP Compaq Machine
(U) One cellophane containing one (1) Mentor Media 32GB USB.
(U) One cellophane containing one (1) Data Traveler 4GB USB.
(U) One cellophane containing one (1) Data Traveler 4GB USB.
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard Drives
(U) One red rope containing:1Seagate Path/100 Hard D