INTHE SUPERIOR COURT
OF  THEVIRGIN ISLANDS

FILED

July 13, 2020

TAMARA CHARLES
CLERK OF THE COURT

# EXHIBIT B

# UNITED STATES VIRGIN ISLANDS
DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
*****CICO SUBPOENA*****

# DUCES TECUM

SUBPOENA FOR:

RECORDS

CASE

# IN THE NAME OF THE GOVERNMENT OF THE VIRGIN ISLANDS

TO: Ghislaine Maxwell
c/o Quintairos, Prieto, Wood & Boyer, P.A.
9300 S. Dadeland Blvd.
4 thFloor
Miami, FL 33156

ATTN: Kyle R. Waldner, Esq.

Title 14 V.I.C. § 612(a) provides that "[w]herever any person is reasonably suspected to have engaged in, or to be engaging in, or about to engage in any conduct constituting a violation of any of the provisions of section 605r the Attorney General may, in his discretion, conduct an investigation of the conduct. The Attorney General is authorized before the commencement of and during any civil or criminal proceeding or action under this chapter to subpoena witnesses, compel their attendance, examine them under oath, or to require the production of any books, documents, records, writings, recordings of tangible things (hereinafter referred to as "documentary material") relevant or material to the investigation for inspection, reproducing, and/or copying.

Pursuant to Title 14 V.I.C. Section 612(a), YOU ARE HEREBY COMMANDED to produce forthwith copies of the documents listed in Exhibit A:

Pursuant to 14 V.I.C. § 612(c), the documents requested is in reference to an ongoing investigation by the Virgin Islands Department of Justice of the rape, abuse, exploitation and trafficking of young women and underage girls by Jeffrey E. Epstein and his associates in violation of 14 V.I.C. § 133 and 1624, as well as other Virgin Islands statutes.

Personal appearance is not required to satisfy this subpoena; instead, please provide the requested information to Special Agent Tarique Turnbull, Department of Justice.

PLACE: United States Virgin Islands Department of Justice 3438 Kronprindsens Gade G.E.R.S. Complex, 2nd Floor St. Thomas, VI 00802-5712
DATE: April 17, 2020
TIME: 3:00 p.m.

NOTE: This subpoena places you on notice of an investigation by the Virgin Islands Department of Justice. You must maintain, and may not destroy, any documents, electronic records, or other material relating to Jeffrey Epstein and the entities described in the subpoena.

Failure to produce the documents requested may cause the Attorney General to petition the Superior Court to

compel you to produce the documents requested and to the is uance of a warrant for your arrest, under Title 14 V.LC. ~ 612(k).

<signature> DATED this 19 day of March, 2020.
Ariel M. Smith, Esquire
Chief of the Civil Division
V.I. Department of Justice
Office of the Attorney General
3438 Kronprindsens Gade
G.E.R.S. Complex, 2nd Floor
St. Thomas, VI 00802
(340) 774-5666 Ext. 10303

## RETURN OF SERVICE

Received by Server on: <empty>
Place: <empty>
Served on (Name): <empty>
Date: <empty>
At: <empty>
Served by: <empty>
Title: <empty>

DECLARATION OF SERVER

I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE United States of America and the Territory of the United States Virgin Islands that the foregoing information contained in the Return of Services Statement is true and correct.

Executed on: <empty>
By: <empty>

## Exhibit A

Subpoena Duces Tecum directed to Banco Popular de Puerto Rico

RECORDS DELIVERY ONLY. NO ORAL TESTIMONY WILL BE TAKEN.

IF RECORDS ARE DELIVERED PRIOR TO April 17, 2020, YOU NEED NOT APPEAR.

If more than thirty (30) days is needed to respond to this subpoena, please contact the Civil Division Chief, Attorney Ariel Smith, at the Virgin Islands Department of Justice.

## I.  Definitions

Unless otherwise specified, the documents specified below are required to be produced for the time period commencing January 1, 1998 and continuing through the present. Where production of account data is provided in electronic format or media the preferred software format to incorporate the data into is Microsoft Excel.

As used herein, the following terms are defined as indicated:

1. As used herein, the term "Account Holder" shall mean any person or entity in whose name an account is held or where the person or entity has held any ownership or other interest or has had signatory authority.

2. "All/Each." The term "all" and "each" shall be construed as all and each.

3. "And/Or." The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope.

4. "Communication" means the transmittal of information (in the form of facts, ideas, inquiries or otherwise).

5. "Concerning" means relating to, referring to, describing, evidencing or constituting.

6. The terms "Document" or "Documents" are defined to be synonymous and equal in scope to the usage of these terms in Federal Rule of Civil Procedure 34(a), including, without limitation, any written, drawn, printed, typed, photographed or other graphic or electronically or computerized recorded data or compilations of any kind or nature prepared or received by, or in the possession, custody or control of the answering party, its agents, servants, employees or other representatives. Originals, drafts and all nonidentical copies are separate documents within the meaning of this term.

7. The term "identify" when used with reference to a person, means to give, to the extent known, the person's full name, present or last known address, and when referring to a natural person, additionally, the present or last known place of employment. Once a person has been identified in accordance with this subparagraph, only the name of that person need to be listed in response to subsequent discovery requesting the identification of that person.

8. The term "identify" when used with reference to documents, means to give, to the extent known, the (i) type of document; (ii) general subject matter; (iii) date of the document; and (iv) author(s), addressee(s) and recipient(s).

9. The term "identify" when used with reference to an oral communication, discussion, conversation or any other oral statement, shall mean to describe in detail the substance of each such communication, discussion, conversation or statement, state the date of such communication, discussion, conversation or statement, the place where such communication, discussion, conversation or statement was held and identify each person present for such communication, discussion, conversation or statement.

10. "Person" means any natural person or any business, legal or governmental entity or association.

11. "Referring to", "relating to", "reflecting", "regarding" or "with respect to" mean, without limitation the concepts: pertain to, deal with, concern, reflect, record, report, constitute, contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, assess, support, modify, contradict, criticize, summarize, comment, or otherwise involve, in whole or in part.

12. "You means You, along with any organization or entity in which You have management or controlling interests, together with all present and former directors, officers, employees, agents, representatives or any other persons acting, or purporting to act, on Your behalf.

## II.  Instructions

1. When providing Your responses, indicate the Request to which each Document or answer responds in the metadata field, Request No.

2. Documents produced pursuant to these Requests shall be produced as they are kept in the ordinary course of business.

3. For each Document that You produce, produce the current version together with all earlier editions or predecessor Documents during the relevant time period, even though the title of earlier Documents may differ from current versions. Format for Documents produced electronically:

	a. Data shall be produced in single page TIFFs at a 300 DPI resolution which are named for the Bates Number of the page. There shall be no more than 1000 images per folder. Bates numbers, confidentiality designations, and redactions shall be burned into the TIFF image file so as not to unreasonably obstruct any information on the page.

	b. Document Unitization. Each page of a Document shall be electronically converted into an image as described above. If a Document is more than one page, the unitization of the Document and any attachments and/or affixed notes shall be maintained as it existed in the original when creating the image file and appropriately designated in the load files. The corresponding parent/attachment relationships, to the extent possible, shall be provided in the load files furnished with each production.

	c. Include Document level text files containing optical character recognition ("OCR") or extracted text named with the Bates Number of the first page of the Document.

	d. Include data load files containing all of the metadata fields (both system and application - see list below) from the original Native Documents with extension.dat for Concordance.

	e. Include the database field name in the first line of the metadata file, in such a manner that it is clear how the metadata is organized in the file.

	f. Include an image load file for Concordance - such as .opt.

	g. All hidden text (e.g.,track changes, hidden columns, comments, notes, etc.) shall be expanded, extracted, and rendered in the . TIFF file.

	h. Documents created in Excel (spreadsheets), .CSV files, Access (databases), and audio and video media files shall be produced in Native format. The extractable metadata and text shall be produced in the same manner as other Documents that originated in electronic form (as described herein) to the extent that metadata exists or is reasonably accessible.

	i. Email attachments and embedded files or links shall be mapped to their parent.

	J. Produce all attachments to responsive Documents attached to the responsive Documents.

	k. De-duplicate prior to production. To the extent that exact duplicate Documents (based on MOS or SHA-I hash values at the Document level) reside within a party's data set, each party is only required to produce a single copy of a responsive Document, so long as there is a data field that identifies each custodian who had a copy. In addition, Documents may be de-duplicated in such a way as to eliminate earlier or incomplete chains of emails, and produce only the most complete iteration of an email chain so long as there is a data field that identifies each custodian who had a copy.

## REQUIRED METADATA FIELDS:

BEGDOC: <empty>
ENDDOC: <empty>

BEGATTACH: <empty>
ENDATTACH: <empty>

ATTCOUNT: <empty>
ATTACH: <empty>

CUSTODIAN: <empty>
AUTHOR: <empty>

FROM: <empty>
TO: <empty>

CC: <empty>
BCC: <empty>

FILESIZE: <empty>
PGCOUNT: <empty>

DATERECD: <empty>
TIMERECD: <empty>

DATESENT: <empty>
TIMESENT: <empty>

CRTDATE: <empty>
CRTime: <empty>

<table><tr><th>LASTMODDATE</th><th>LASTMODTIME</th></tr><tr><td>LASTACCDATE</td><td>LASTACCTIME</td></tr><tr><td>TITLE</td><td>SUBJECT</td></tr><tr><td>EMAILSUBJECT</td><td>FILENAME</td></tr><tr><td>FILEEXT</td><td>MD5HASH</td></tr><tr><td>ORGANIZATION</td><td>FULLPATH</td></tr><tr><td>RECORD TYPE</td><td>VERSION</td></tr><tr><td>VOLUME</td><td>COMMENT</td></tr><tr><td>PRINTEDDATE</td><td>ENTRYID</td></tr><tr><td>ATTLST</td><td>ITEMTYPE</td></tr><tr><td>PSTINSIDEPATH</td><td>ITEMCREATIONTIME</td></tr><tr><td>REQATTANDEES</td><td>REMINDERTIME</td></tr><tr><td>REPLYTIME</td><td>APPOINTMENTSTARTDATE</td></tr><tr><td>APPOINTMENTDURATIONTIME</td><td>APPOINTMENTCONTACT</td></tr><tr><td>CATEGORY</td><td>KEYWORDS</td></tr><tr><td>MANAGER</td><td>LASTAUTHOR</td></tr><tr><td>ENCRYPTED</td><td>FAMILYDATE</td></tr><tr><td>NATIVELINK</td><td>TEXTPATH</td></tr><tr><td>REQUESTNO </td><td></td></tr></table>

4. Format for hard copies of Documents produced in response to this Request:

	a. Re-type the question or request to which the Documents respond and firmly attach the Documents to the re-typed request;

		b. Number all Documents consecutively, consistently with the numbers used for the Documents produced electronically.

5. Unless otherwise indicated, the relevant time period for this Request for Production of Documents is January l, 1998 to the present.

6. If no Documents responsive to a particular request exist, so state.

7. As to any Document which no longer exists but which You are aware existed at one time, identify such Document with as much particularity as possible, and in addition, identify the last known location of the Document, the reason the Document is no longer in existence, and the person responsible for the Document's disposition.

8. For information that You withhold on the basis of privilege, provide a descriptive list of each Document stating the grounds for Your refusal and providing the following information: the name or title of the Document; a description of the nature and subject matter of the Document sufficient to enable a meaningful challenge to the assertion of privilege; the date, author(s), sender(s), and recipient(s) of the Document, including whether the person is an attorney and/or was an employee of Banco Popular de Puerto Rico. at the time the Document was authored, sent or received; and the nature of the privilege.

9. These requests shall be deemed continuing in character so as to require prompt supplemental responses if additional Documents called for herein are obtained, discovered, or become known to You between the time of responding to the Requests and the final disposition of this action.

10. Social Security numbers may be redacted from documents to the extent required by applicable law.

## III.  Requests for the Production of Documents

Please produce the following:

1. All Documents and discovery obtained or provided in other litigation concerning or concerning allegations that You or Jeffrey Epstein engaged in sexual abuse, human trafficking, commercial sex, or pornography, including in the Virgin Islands.

2. Transcripts and video recordings of all depositions taken of You in Giuffre v. Maxwell (No. 15 CV 07433-RWS) and Ransome v. Epstein, Maxwell et al (No. 17 Civ. 0616 JGK).

3. All Documents You reference or rely on in the complaint in Maxwell v. Estate ofJeffrey E. Epstein Civil Case No. ST-20-CV-155

4. All Documents reflecting or concerning travel to or from the Virgin Islands for You, Jeffrey Epstein, or other individuals.

5. All Documents reflecting or concerning communications between You, or Your agent or representative, and Darren Indyke, or Richard Kahn.

6. All Documents reflecting or concerning communications between You, or Your agent or representative, and Jeffrey Epstein. For this Request, provide documents from 1991 to present.

7. All Documents reflecting or concerning Your allegation that Jeffrey Epstein agreed to indemnify you, pay Your legal fees, or otherwise provide financial support to You including, but not limited to, the notes referenced in Maxwell v. Estate of Jeffrey E. Epstein Civil Case No. ST-20-CV-155

8. All Documents reflecting or concerning your employment for the companies and entities You described in Maxwell v. Estate ofJeffrey E. Epstein Civil Case No. ST-20-CV-155

9. All Documents reflecting or concerning massages or other services You arranged or compensated for Jeffrey Epstein.

10. All Documents reflecting or concerning a list of masseuses kept for any of the properties owned or controlled by Jeffrey Epstein.

11. All photographs of Jeffrey Epstein, including, but not limited to, all photographs of You and Jeffrey Epstein.

12. All photographs or videos taken of any of the women or girls who ever provided a massage for Jeffrey Epstein, regardless oflocation, or any visitor at Great St. James or Little St. James.

13. All Documents reflecting or concerning a list of names, numbers, and addresses kept at any of the properties owned or controlled by Jeffrey Epstein.

14. All Documents reflecting or concerning lists of names, numbers, and addresses You created or kept in the course of Your employment, as You described in Maxwell v. Estate of Jeffrey E. Epstein Civil Case No. ST-20-CV-155

15. All Documents reflecting or concerning the purchase, maintenance, construction, permits, or other services provided to or obtained in connection with Great St. James or Little St. James.

16. All Documents reflecting or concerning tax incentives obtained by Epstein or any Epstein Entity from the Government of the Virgin Islands or any agency or entity associated with the Government.

17. All Documents reflecting or concerning communications between You, Jeffrey Epstein, or any Epstein Entity with or about the Government of the Virgin Islands, or any agency or entity associated with the Government.

18. All Documents reflecting or concerning visitors to or houseguests of Great St. James or Little St. James.

19. Documents sufficient to identify all email addresses, telephone numbers, and social media accounts used by You and Jeffrey Epstein. (You may answer this question, rather than provide responsive documents.)

20. All Documents reflecting or concerning communications between You and/or Jeffrey Epstein and any Person who visited or was a houseguest at Great St. James or Little St. James regarding the Person's visit or other visitors to the Island.

21. All Documents reflecting or concerning travel on any airplane, helicopter, or boat owned or used by You or Jeffrey Epstein, including, but not limited to, Air Ghislaine.

22. All Documents reflecting or concerning transfers or payment of money or other assets between You, Jeffrey Epstein, any Epstein Entity or agent, any entity of which you are an owner, officer, shareholder, or employee.

23. All Documents reflecting or concerning bank accounts, securities or other investments, property, or other assets held by or transferred to or from Jeffrey Epstein or any Epstein Entity or agent.

24. All Documents reflecting or concerning visas or other travel arrangements for models or other women or girls transported to the United States, including the Virgin Islands.

25. All photographs, videos, audio messages, and/or any other visual media or audio recording reflecting You, Jeffrey Epstein, and/or any visitor to Little St. James or Great St. James.

26. All Documents reflecting or concerning the presence of any Person on Little St. James or Great St. James for any purpose, including, but not limited to, any contractors or employees of Epstein or any Epstein Entity.

27. All Documents reflecting to any offer of employment or contract of employment, severance agreement, or non-disclosure agreement for any employee of Jeffrey Epstein or any Epstein Entity, including, but not limited to, temporary, part-time, or full-time employees, in any capacity, at Little St. James or Great St. James.

28. Your telephone and credit card statements.

29. All Documents reflecting or concerning payments You received from any Epstein Entity.

30. All Documents reflecting or concerning Your role as Director and Treasurer of Financial Trust Company, including, but not limited to, payroll records, client lists, vendor lists, correspondence, bank statements or account documents, and business plans.

31. All Documents reflecting or concerning identification documents (such as passports or driver licenses) for visitors to Little St. James or Great St. James.

## EXHIBIT B

SubpoenaDuces Tecum directed to Ghislaine Maxwell

RECORDS DELIVERY ONLY. NO ORAL TESTIMONY WILL BE TAK.EN.

IF RECORDS ARE DELIVERED PRIOR TO April 17, 2020, YOU NEED NOT APPEAR.

If more than thirty (30) days is needed to respond to this subpoena, please contact the Civil Division Chief, Attorney Ariel Smith, at the Virgin Islands Department of Justice.

Individuals and Entities For Which Information To Be Provided

<table><tr><th>I.</th><th>Jeffrey E. Epstein</th></tr><tr><td>2.</td><td>Estate of Jeffiey E. Epstein</td></tr><tr><td>3.</td><td>The 1953 Trust</td></tr><tr><td>4.</td><td>PlanD, LLC</td></tr><tr><td>5.</td><td>Great St. Jim, LLC</td></tr><tr><td>6.</td><td>Nautilus, Inc.</td></tr><tr><td>7.</td><td>Hyperion Air, LLC</td></tr><tr><td>8.</td><td>Poplar Inc.</td></tr><tr><td>9.</td><td>C.O.U.Q. Foundation</td></tr><tr><td>10.</td><td>Epstein Foundation, Inc.</td></tr><tr><td>11.</td><td>Epstein Interests</td></tr><tr><td>12.</td><td>Gratitude America LTD</td></tr><tr><td>13.</td><td>J. Epstein Foundation, Inc.</td></tr><tr><td>14.</td><td>Southern Trust Co.</td></tr><tr><td>15.</td><td>Financial Trust Co. Inc.</td></tr><tr><td>16.</td><td>IGY-A YH St. Thomas Holdings, LLC.</td></tr><tr><td>17.</td><td>Maple, Inc.</td></tr><tr><td>18.</td><td>Cypress, Inc.</td></tr><tr><td>19.</td><td>Laurel, Inc.</td></tr><tr><td>20.</td><td>JEGE,LLC.</td></tr><tr><td>21.</td><td>Southern Country International</td></tr></table>

## EXHIBIT C

# UNITED STATES DISTRICT COURT

# SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

- V . -

GHISLAINE MAXWELL ,

X

:

:

:

:

=

:

:

:

:

SEALED

INDICTMENT

20 Cr.

20 Cr. 330

Defendant.

# COUNT ONE

(Cons pir acy to Entice Minors to Travel t o Engage in

(Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts)

The Grand Jury charges :

## OVERVIEW

1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18.

2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to

Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. Moreover, in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described herein , when providing testimony under oath in 2016 .

## FACTUAL BACKGROUND

3. During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, beLween in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:

- Image type: photograph (scanned/printed, low-quality/grainy with horizontal banding).
- Subjects: two adult humans, standing close together; left person has arm draped around right person's shoulders.
- Expressions/pose: right person smiling broadly; left person has neutral/closed-mouth expression, facing slightly toward right.
- Clothing: left person — dark jacket/blazer over a light blue shirt; right person — light-colored long-sleeve top.
- Background: dark, indistinct (indoor, low lighting).
- Surrounding text asserts the photo depicts named individuals (Ghislaine Maxwell and Jeffrey Epstein); identity cannot be verified from the image alone.

2

4. Beginning in at least 1994, GHISLAINE MAXWELL,

the defendant, enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods, including but not limited to the following:

a. MAXWELL first attempted to befriend some of -Epstein's minor victims prior to their abuse, including by asking the victims about their lives, their schools, and thei~ families . MAXWELL and Epstein would spend time building friendships with minor victims by, for example, taking minor victims to the movies or shopping. Some of these outings would involve MAXWELL and Epstein spending time together with a minor victim, while some would involve MAXWELL or Epstein spending time alone with a minor victim.

b. Having developed a rapport with a victim, MAXWELL would try to normalize sexual abuse for a minor victim by, among other things, discussing sexual topics, undressing in front of the victim, being present when a minor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein.

c. MAXWELL'S presence during minor victims' interactions with Epstein, including interactions where the minor victim was undressed or that involved sex acts with Epstein, helped put the victims at ease because an adult woman was present. For example, in some instances, MAXWELL would

3

massage Epstein in front of a minor victim. In other instances, MAXWELL encouraged minor victims to provide massages to Epstein, including sexualized massages during which a minor victim would be fully or partially nude. Many of those massages resulted in Epstein sexually abusing the minor victims.

d. In addition, Epstein offered to help some minor victims by paying for travel and/or educational opportunities, and MAXWELL encouraged certain victims to accept Epstein's assistance. As a result, victims were made to feel indebted and believed that MAXWELL and Epstein were trying to help them.

e. Through this process, MAXWELL and Epstein enticed victims to engage in sexual activity with Epstein. In some instances, MAXWELL was present for and participated in the sexual abuse of minor victims. Some such incidents occurred in the context of massages, which developed into sexual encounters.

5. GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims knowing that he had a sexual preference for underage girls and that he intended to engage in sexual activity with those victims. Epstein's resulting abuse of minor victims included, among other things, touching a victim's breast, touching a victim's genitals, placing a sex toy such as a vibrator on a victim's genitals,

4

directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals .

## MAXWELL AND EPSTEIN'S VICTIMS

6. Between approximately in or about 1994 and in or about 199 7, GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims by, among other things, inducing and enticing, and aiding and abetting the inducement and enticement of, multiple minor victims . Victims were groomed and/or abused at multiple locations, including the following:

a. A a multi-story private residence on the Upper East Side of Manhattan , New York owned by Epstein (the "New York Residence"), which is depicted in the following photograph:

- Subject: Multi-story private residence (the "New York Residence") on the Upper East Side, Manhattan, owned by Epstein.
- Building: Large townhouse with stone/ornamental façade, arched central entrance.
- Floors: Approximately 4–5 visible stories.
- Entrance: Prominent centered doorway with a red door.
- Street context: Mature trees along sidewalk casting shadows across façade.
- Vehicles: Several parked cars in front (including a dark SUV and a blue car).

5

b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"), which is depicted in the following photograph:

The image depicts Epstein's Palm Beach residence. The house is a long, one-story building visible behind hedges and palm trees. A gate and driveway are in the foreground.

c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residencen), which is depicted in the following photograph :

The image shows an aerial view of Epstein's New Mexico Residence in Santa Fe. The compound consists of multiple buildings, a circular track, parking for multiple vehicles, and a large lawn. The surrounding area is largely desert vegetation.

d. MAXWELL'S personal residence in London,
England.

7. Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:

a . MAXWELL met Minor Victim-1 when Minor Victim-1 was approximately 14 years old. MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences, knowing that Minor Victim-1 was under the age of 18 at the time . During these interactions, which took place between approximately 1994 and 1997, MAXWELL groomed Minor Victim-1 to engage in sexual acts with Epstein through multiple means. First, MAXWELL and Epstein attempted to befriend Minor Victim-1, taking her to the movies and on shopping trips. MAXWELL also asked Minor Victim-1 about school, her classes, her family, and other aspects of her life. MAXWELL then sought to normalize inappropriate and abusive conduct by, among other things, undressing in front of Minor Victim-1 and being present when Minor Victim-1 und~essed in front of Epstein. Within the first year after MAXWELL and Epstein met Minor Victim- 1, Epstein began sexually abusing Minor Victim-1. MAXWELL was present for

7

and involved in some of this abuse. In particular, MAXWELL involved Minor Victim-1 in group sexualized massages of Epstein. During those group sexualized massages, MAXWELL and/or Minor Victim-1 would engage in sex acts with Epstein. Epstein and MAXWELL both encouraged Minor Victim-1 to travel to Epstein's residences in both New York and Florida. As a result, Minor Victim-1 was sexually abused by Epstein in both New York and Florida. Minor Victim-1 was enticed to travel across state lines for the purpose of sexual encounters with Epstein, and MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-1 after Minor-Victim-1 traveled to Epstein's properties, including in the context of a sexualized massage.

b. MAXWELL interacted with Minor Victim-2 on at

least one occasion in or about 1996 at Epstein's residence in New Mexico when Minor Victim-2 was under the age of 18. Minor Victim-2 had flown into New Mexico from out of state at Epstein's invitation for the purpose of being groomed for and/or subjected to acts of sexual abuse. MAXWELL knew that Minor Victim-2 was under the age of 18 at the time. While in New Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed Minor Victim-2's school, classes, and family with Minor Victim 2. In New Mexico, MAXWELL began her efforts to groom Minor Victim-2 for abuse by Epstein by, among other things, providing

8

:

1

an unsolicited massage to Minor Victim-2, during which Minor

Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to massage Epstein.

c. MAXWELL groomed and befriended Minor

Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which MAXWELL knew that Minor Victim-3 was under the age of 18. Among other things, MAXWELL discussed Minor Victim-3's life and family with Minor Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein. During those interactions, MAXWELL encouraged Minor Victirn-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages. Minor Victim-3 provided Epstein with the requested massages, and during those massages, Epstein sexually abused Minor Victim-3. MAXWELL was aware that Epstein engaged in sexual activity with Minor Victirn-3 on multiple occasions, including at times when Minor Victim-3 ~as under the age of 18, including in the context of a sexualized massage.

MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT

8. In or around 2016, in the context of a deposition

as part of civil litigation, GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the

9

abuse of minor victims by Jeffrey Epstein, including some of the specific events and acts of abuse detailed above.

## STATUTORY ALLEGATIONS

9. From at least in or about 1994, up to and

including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, enticement, in violation of Title 18, United States Code, Section 2422.

10. It was a part and object of the conspiracy that

GH,ISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did knowingly persuade, induce, entice, and coerce one and more individuals to travel in interstate and foreign commerce, to engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2422.

overt Acts

11. ln furtherance of the conspiracy and to effect

the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:

10

a. Between in or about 1994 and in or about

1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida.

b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.

c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless.

d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages.

(Title 18, United States Code, Section 371.)

COUNT TWO (Enticement of a Minor to Travel to Engage in Illegal Sex Acts)

The Grand Jury further charges:

12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.

11

13. From at least in or about 1994, up to and

including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did persuade, induce, entice, and coerce an indiv:i:-dual to travel in interstate a~d foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do the same, and aided and abetted the same, to wit, MAXWELL persuaded, induced, enticed, and coerced Minor Victim-1 to travel from Florida to New York, New York on multiple oc_casions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130 . 55.

(Title 18, United States Code, Sections 2422 and 2.)

## COUNT THREE COUNT THREE

(Conspiracy to Transport Minors with Intent to

## Engage in Criminal Sexual Activity)

The Grand Jury further charges:

14. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within.

15. From at least in or about 1994, up to and

including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to

12

wit, transportation of minors, in violation of Title 18, United States Code, Section 2423(a).

16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423(a).

Overt Acts

17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:

a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with EPSTEIN and Minor Victim-1 in New York and Florida.

b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the

13

New York Residence, in violation of New York Penal Law, Section 130.55.

c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXW_ELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless.

d . Between in or about 1994 and in or about 1995, when Minor Victim- 3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim·-3 during those massages ..

('I'itle 18, United States Code, Section 371.)

## COUNT FOUR COUNT FOUR

(Transportation of a Minor with Intent to (Transportation of a Minor with Intent to

## Engage in Criminal sexual Activity)

The Grand Jury further charges:

18. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within .

19. From at least in or about 1994, up to and

including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an indi vidual who had not attained the age of 18 in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do so, and

14

aided and abetted the same, to wit, MAXWELL arranged for Minor Victim-1 to be transported from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55.

(Title 18, United States Code, Sections 2423(a} and 2.)

COUNT FIVE
(Perjury)

The Grand Jury further charges:

20. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within.

21. On or about April 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony:

Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know.

A. I don't know what you're talking about.

15

Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?

A. I'm not aware of anybody that I interacted with, other than obviously (the plaintiff] who was 17 at this point.

(Title 18, United States Code, Section 1623.)

COUNT SIX
(Perjury)

The Grand Jury further charges:

22. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within.

23. On or about July 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony:

Q: Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A: No, not that I recall ....

Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? A. No.

16

Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities?

A. I wasn't aware that he was having sexual activities with anyone when I was with him other than myself.

Q. I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?

A.

That is my testimony, that is correct.

Q.  Is it your testimony that you've never given
anybody a massage?

A.  I have not given anyone a massage.

Q. You never gave Mr. Epstein a massage, is that
your testimony?

A. That is my testimony.

Q. You never gave [Minor Victim-2] a massage is your
testimony?

A. I never gave [Minor Victim-2) a massage. (Title 18, United States Code, Section 1623.)

FOREPERSON

AUDREY STRAUSS
Acting United States Attorney

17

Form No. USA-33s- 274 (Ed. 9-25-58)

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

V.

# GHISLAINE MAXWELL,

Defendant.

## INDICTMENT

(18 U.S.C. §§ 371, 1623, 2422, 2423(a), and 2)
AUDREY STRAUSS
Acting United States Attorney
/ Foreperson

18

# EXHIBIT D

# U ITED STATES VIRGI ISLANDS DEPARTMENT OF JUSTICE OFFICE OF THEATTO RN EY GENERAL

In re: Subpoena for Records for Ghislaine Maxwell

Case No.: N/A

## AFFIDAVIT OF SERVICE

I, Rafael Perez, a Private Process Server, being duly sworn, depose and say:

That I have been duly authorized to make service of the Subpoena Duces Tecum with Exhibits in the above entitled case.

Tha tJ am ov er th e age or eighteen years and not a par ty to or otherwise int erested in this action.

That on 3/20/2020 at 12:10 PM, I served Ghislaine Maxwell c/o Quintairos, Prieto, Wood & Boyer, P.A. with the Subpoena Duces Tecum with Exhibits at 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 by serving Eric Boyer, Designated Agent, who stated that he/she is authorized to accept service on behalf of Ghislaine Maxwell c/o Quintairos, Pricto, Wood & Boyer, P.A..

Eri c Boyer is des cribed herein as:

Gender: Male Race/Skin: White Age: 40's Weight: 180 Height: 5'6" Hair: White Glasses: No

I declare under penalty of perjury that this information is true and correct.

Sworn to before me on 3/24/2020
<signature>
Notary Public
My Commission Expires:
Notary Public State of Florida
Gabriela Padron
My Commission GG 929484
Expires 11/06/2023



<signature>
Rafael Perez

Client Ref Number:N/A

Job #: 1576402

Capitol Process Services, Inc. | 1827 18th Street, NW, Washington, DC 20009 | (202) 667-0050

# UNITED STATES VIRGIN ISLANDS
DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
*****CICO SUBPOENA*****
DUCES TECUM

RD
10017
320/20
1210p
Eric Boyer

SUBPOENA FOR:
RECORDS CASE

IN THE NAME OF THE GOVERNMENT OF THE VIRGIN ISLANDS

TO: Ghislaine Maxwell
c/o Quintaíros, Prieto, Wood & Boyer, P.A.
9300 S. Dadeland Blvd.
4th Floor
Miami, FL 33156

ATTN: Kyle R. Waldner, Esq.

Title 14 V.I.C. § 612(a) provides that "[w]henever any person is reasonably suspected to have engaged in, or to be engaging in, or about to engage in any conduct constituting a violation of any of the provisions of section 605r the Attorney General may, in his discretion, conduct an investigation of the conduct. The Attorney General is authorized before the commencement of and during any civil or criminal proceeding or action under this chapter to subpoena witnesses, compel their attendance, examine them under oath, or to require the production of any books, documents, records, writings, recordings or tangible things (hereinafter referred to as "documentary material") relevant or material to the investigation for inspection, reproducing, and/or copying.

Pursuant to Title 14 V.I.C. Section 612(a), YOU ARE HEREBY COMMANDED to produce forthwith copies of the documents listed in Exhibit A:

Pursuant to 14 V.I.C. § 612(c), the documents requested is in reference to an ongoing investigation by the Virgin Islands Department of Justice of the rape, abuse, exploitation and trafficking of young women and underage girls by Jeffrey E. Epstein and his associates in violation of 14 V.I.C. § 133 and 1624, as well as other Virgin Islands statutes.

Personal appearance is not required to satisfy this subpoena; instead, please provide the requested information to Special Agent Tarique Turnbull, Department of Justice,

PLACE:
United States Virgin Islands
Department of Justice
3438 Kronprindsens Gade
G.E.R.S. Complex, 2nd Floor
St. Thomas, VI 00802-5712

DATE: April 17, 2020
TIME: 3:00 p.m.

NOTE: This subpoena places you on notice of an investiga tion by the Virgin Islands Department of Justice. You must maintain, and may not destroy, any documents, electronic records, or olher material relating to Jeffrey Epstein and the entities described in the subpoena.

Failure to produce the documents requested may cause the Attorney Genernl to petition the Superior Court to

compel you to produce the documents requested and to the issuance of a warrant for your arrest, under Title 14 V.I.C. § 612(k).

<signature>
DATED this 19 day of March, 2020.
Ariel M. Smith, Esquire
Chief of the Civil Division
V.I. Department of Justice
Office of the Attorney General
3438 Kronprindsens Gade
G.E.R.S. Complex, 2nd Floor
St. Thomas, VI 00802
(340) 774-5666 Ext. 10303

## RETURN OF SERV[CE

Received by Server on: <empty>
Place: <empty>
Served on (Name): <empty>
Date: <empty>
At: <empty>
Served by: <empty>
Title: <empty>

## DECLARATION OF SERVER

I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE United States of America and the Territory of the United States Virgin Islands that the foregoing information contained in the Return of Se1vices Statement is tme and correct.

Executed on: <empty> By: <empty>

# EXHIBIT E

From: david.cattie@cattie-law.com <david.cattie@cattie-law.com>

Sent:Wednesday, April 15, 2020 12:43 PM
To:  Ariel Smith <Ariel.Smith-Francois@vi.gov>
Subject:  [EXTERNAL MAIL]Ghislaine Maxwell

Good day Attorney Smith:

Please note that I have been retained by Ghislaine Maxwell In regard to two subpoenas from your office which were delivered to Quintairos, Prieto, Wood & Boyer in Miami Florida. I am not sure about your work schedule in light of the COVID-19 issues, but I would like to meet or set up a conference call with you to discuss these matters. Unfortunately, I am having emergency surgery tomorrow so I will likely not be in a position to meet/conference with you until the middle of next week. Please let me know if/when you would be able to meet and your preferred method to conduct a meeting. Thank you and I hope you are staying safe.

Dave

David  J.  Cattie, Esq.
T he Cattie Law Firm, P.C.
1710 Kongens Gade
St. Thomas, Virgin Islands 00802
T. 340.775.1200/F. 800.878.5237
www.cattie-law.com

# EXHIBIT F

From: Singer, Linda <lsinger@motleyrice.com> Sent: Friday, May 1, 2020 9:42 AM To: David Cattie <david.cattie@cattie-law.com> Cc: Ariel Smith <Ariel.Smith-Francois@vi.gov>; Scott, Carmen <cscott@motleyrice.com > Subject: f/u on our conversation this week

Attorney Cattie:

I hope that you are well. When we spoke on Monday, you indicated that you expected to have a response from your client by the end of this week. Can you let us know where things stand? I would be happy to set up a call for this afternoon if you would prefer to speak by phone.

Best,

Linda

Linda Singer I Attorney at Law I Motley Rice LLC 401 9th St. NW,Suite 1001 I Washington, DC 20004 o. 202.386.9626 x5626 I f. 202.386.9622 j lsinger@motleyrice.com

## EXHIBIT G

From: david.cattie@cattie-law.com <david.cattie@cattie-law.com> Sent: Tuesday, May 12, 2020 12:52 PM To: Singer, Linda Isinger@motleyrice.coml Cc: 'Ariel Smith' <Ariel.Smith-Francois@vi.gov>; Scott, Carmen <cscott@motleyrice.com>; 'Carol Jacobs' <Carol.Jacobs@vi.gov> Subject: RE: EXTERNAL-RE: f/u on our conversation this week

Good day counsels:.

I thank you for your consideration in this matter. I cannot waive the issue of service of the subpoenas, nor can I disclose my client's location to anyone at this time. In the interest of resolving this issue, however, I am willing to collect and provide the documents/items on the attached list. As you know, there are rather broad protective orders in the non-VI litigation which preclude even me from accessing most of the information in those cases. I have determined that I can provide the items on the attached list without running afoul of those protective orders. If you are amenable to resolving the subpoenas in this manner please confirm that in writing (perhaps we should draft a short agreement to that effect) and I will collect and produce this information to you in short order.

If you wou Id like to discuss this matter fu rther, please let me know.

Dave



David J. Cattie, Esq. | Attorney & Counselor at Law The Cattie Law Firm, P.C. tel: 340.775.1200/ fax.: 800.878.5237 e-mail: david.cattie@cattie-law.com web: www.cattie-law.com address: 1710 Kongens Gade, St. Thomas V.I. 00802

## EXHIBIT H

| From:    | Singer, Linda                                      |
|-|-|
| Sent:    | Thursday, May 28, 2020 4:01 PM                     |
| To:      | david.cattie@cattie-law.com                        |
| Cc:      | 'Ariel Smith'; Scott, Carmen; 'Carol Jacobs'       |
| Subject: | RE: EXTERNAL-RE: f/u on our conversation this week |

David:

Apologies for the slow response, and thank you for reaching out.

First, my reading of the protective order, as with most protective orders, is that Ms. Maxwell can share any document that she produced or other discovery material that she designated confidential.

Second, also per the protective order, Ms. Maxwell could seek the consent of opposing counsel to produce the materials produced by the opposing party.

I suspect that would cover at least substantially all of the documents in that litigation. Please let me know if you disagree with my interpretation.

In part, we focused on these litigation materials because we believe that they would not be burdensome to collect and produce. However, we also would be happy to discuss emai ls or other records that are relevant to the Government's investigation in Ms . Maxwell's custody and control that could be produced outside of the protective order.

Please let me know if you would like to discuss.
Best,
Linda

Linda Singer I Attorney at Law I Motley Rice LLC Linda Singer I Attorney at Law I Motley Rice LLC

401 9th St. NW, Suite 1001 I Washington, DC 20004 401 9th St. NW, Suite 1001 I Washington, DC 20004

o. 202.386.9626 x5626 | f. 202.386.9622 | Isinger@motleyrice.com o. 202.386.9626 x5626 If. 202.386.9622 I lsinger@motleyrice.eom

# EXHIBIT I

# UNITED STA TES VIRGIN ISLANDS
DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
*****CICO SUBPOENA*****

# DUCESTECUM

SUBPOENA FOR:

RECORDS

CASE ST-20-CV-014

# IN THE NAME OF THE GOVERNMENT OF THE VIRGIN ISLANDS

TO: Ghislaine Maxwell
c/o David J. Cattie, Esq.
1710 Kongens Gade
St. Thomas, V.I., 00802

ATTN: David J. Cattie, Esq.

Title 14 V.I.C. § 612(a) provides that "[w]henever any person is reasonably suspected to have engaged in, or to be engaging in, or about to engage in any conduct constituting a violation of any of the provisions of section 605r the Attorney General may, in his discretion, conduct an investigation of the conduct. The Attorney General is authorized before the commencement of and during any civil or criminal proceeding or action under this chapter to subpoena witnesses, compel their attendance, examine them under oath, or to require the production of any books, documents, records, writings, recordings or tangible things (hereinafter referred to as "documentary material") relevant or material to the investigation, for inspection, reproducing, and/or copying.

Pursuant to Title 14 V.I.C. Section 612(a), YOU ARE HEREBY COMMANDED to produce forthwith copies of the documents listed below in Exhibit A:

Pursuant to 14 V.I.C. § 612(c), the documents requested is in reference to an ongoing investigation by the Virgin Islands Department of Justice of the rape, abuse, exploitation and trafficking of young women and underage girls by Jeffrey E. Epstein and his associates in violation of 14 V.I.C. § 133 et seq., as well as other Virgin Islands statutes.

Personal appearance is not n:quired to deliver the documents required by this subpoena; instead, please provide them to Special Agent Tariqtie'.{'urnbull, DepartntenJ pf.Justice.

| PLACE:    | United States Virgin Islands                               | DATE: July 2, 2020   |
|-|-|-|
|           | Department of Justice                                      |                      |
|           | 3438 Kronprindsens Gade                                    |                      |
|           | G.E.R.S. Complex, 2nd Floor<br />St. Thomas, VI 00802-5712 | TIME: 3:00 p.m.      |

NOTE: This subpoena places you on notice of an investigation by the Virgin Islands Department of Justice. You must maintain, and may not destroy, any documents, electronic records, video or other material relating to Jeffrey Epstein.

Failure to produce the documents requested may cause the Attorney General to petition the Superior Court to compel you to produce the documents requested and to the issuance of a warrant for your arrest, under Title 14 V.I.C. * 612(k). '-.·,

<signature>
Ariel Smith Esquire
DATED this 11th day of June, 2020.

Ariel Smith, Esquire

Chief of the Civil Division

V.I. Department of Justice

Office of the Attorney General

3438 Kronprindsens Gade

G.E.R.S. Complex, 2nd Floor

St. Thomas, VI 00802

(340) 774-5666 Ext. 10155

## RETURN OF SERVICE

Received by Server on: <empty>
Place: <empty>
Served on (Name): <empty>
Date: <empty>
At:
Served by: <empty>
Title: <empty>

## DECLARATION OF SERVER

I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE United States of America and the Territory of the United States Virgin Islands that the foregoing infonnation contained in the Return of Services Statement is tme and coITect.

Executed on: <empty> By: <empty>

# EXHIBIT J

| From:        | david.cattie@cattie-law.com                              |
|-|-|
| Sent:        | Wednesday, June 17, 2020 2:00 PM                         |
| To:          | Singer, Linda                                            |
| Cc:          | 'Ariel Smith'; Scott, Carmen; 'Carol Jacobs'             |
| Subject:     | RE: EXTERNAL-RE: f/u on our conversation this week       |
| Attachments: | 2020 06 11 Subpoena Duces Tecum to Ghislaine Maxwell.pdf |

Good day:

Please note that I have previously advised you that I am not authorized to accept service on behalf of Ms. Maxwell. Today (while I was actually on a Zoom call with Attorney Smith), the Attorney General's Office attempted to complete service of a CICO Subpoena (attached) through me. I advised the office that I was not authorized to accept service on her behalf. Also, please note that while the subpoena demands documents attached as Exhibit "A", there is no such exhibit attached thereto.

David Cattie



David J. Cattie, Esq. I Attorney & Counselor at Law IThe Cattie Law Firm, P.C. I tel: 340.775.1200/ fax.: 800.878.5237 I e-mail: david.cattie@cattie-law.com I web: www .cattie-law.com I address: 1710 Kongens Gade, St. Thomas V.I. 00802

## EXHIBIT K

Case 1:17-cv-00616-JGK-SN

Document 97

Filed 01/05/18

Page 1 of 8

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 43

Plaintiff,

No. 17 Civ. 00616 (JGK)

V.

JEFFREY EPSTEIN, GHISLAINE MAXWELL,
SARAH KELLEN, LESLEY GROFF and
NATALYA MALYSHEV

Defendants.

## PLAINTIFF'S RENEWED MOTION TO APPROVE ALTERNATE SERVICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(e)(l)

Plaintiff, Sarah Ransome 1, by and through her undersigned counsel and pursuant to Federal Rule of Civil Procedure 4(e)(l) and the New York Civil Practice Law and Rules Section 308(5) files this Renewed Motion to Approve Alternative Service and for grounds thereof states: As this Court is aware, Defendant Maxwell is also a defendant in another action in the Southern District of New York, Giuffre v. Maxwell, Case No. 15-cv-07433 RWS. In that action, Maxwell is represented by counsel who appeared before that Court on her behalf as recently as November 8, 2017. Despite that fact, Maxwell will apparently not authorize her counsel to accept service of the complaint in this case. Indeed, Maxwell's counsel has gone so far as to hire their own separate legal counsel to argue to this Court that they should not have to accept service in this case. Yet in this very case, Maxwell has already actively participated, including having counsel make a request for additional time to serve her answer and attempting to impose

1 Plaintiff has decided to reveal her identity in connection with this matter and has filed a Notice to Change Case Caption.

1

Case 1:17--cv-00616-JGK-SN

Document 97

Filed 01/05/18

Page 2 of 8

restrictions on the case of discovery materials. SeeDE 69 and November 23, 2017 Letter to Judge Koeltl, Exhibit D.

While this Court originally granted Plaintiff Ms. Ransome's Motion for Alternate Service (DE 57). Maxwell's counsel sought reconsideration of that Order on October 30, 2017. This Court held a hearing on November 28, 2017 and issued an Order on November 30, 2017 instructing Ms. Ransome to again attempt service on Defendant Maxwell on or before January 5, 2018: "By that date, the plaintiff will fi le either proof of service or a renewed appl ication to the alternate service." DE 90. As directed, Ms. Ransome has made the following attempts to effectuate service on Maxwell:

• Ms. Ransome provided Maxwell 's counsel of record in the Giuffre v. Maxwell case a copy of the summons and complaint;

• Ms. Ransome emailed a copy of the summons and complaint to the following email address which is publicly associated with Maxwell, gmax@ellmax.com. See Mccawley Deel. at Exhibit I, December 4, 2017 E-mail;

• Ms. Ransome retained, at significant expense, a private investigation firm to attempt to effectuate service at locations associated with Maxwell in New York and New Jersey, including the fo llowing addresses:

	l. 116 E. 65th Street, New York, NY 10065;

	2. 457 Madison Avenue, 4th Floor, New York, 1\TY 10022; and

	3. 55 Monterey Avenue, Teaneck, NJ 07666.

As detailed in the affidavit of Investigator Douglas Mercer (See McCawley Deel. at Exhibit 2), at one location, it was clear that individuals were present in the home but were refusing to answer the door and accept service;

• Ms. Ransome conducted a public record search of the London Townhome that was identified in Epstein's Phone Directory as being associated with Defendant Maxwell: 44 Kinnerton Street, London. The UK government record request demonstrates that title to the property was changed on March 17, 2016 to Eaton Square Prope1iies Limited and is no longer owned by Defendant Maxwell rendering attempts at service in London futile. SeeMcCawley Deel. at Exhibit 3, Summary of Title NGL948023; and

2

Case 1:17-cv-00616-JGK-SN

Document 97

Filed 01/05/18

Page 3 of 8

• Defendant Ghislaine Maxwell is also identified as the founder of the TerraMar Project on its website. The organization has a New York address for its headquarters at 326 E. 65 th Street #326, New York, New York 10065 . The email address identified with the organization is hello@theterramarproject.org. On January 4, 2018, we served a copy of the summons and complaint to the followi ng potential email addresses:

	1. gmaxwell@theterramarproject.org;

	2. maxwellg@theterramarproject.org;

	3. ghislaine@theterramarproject.org;

	4. gmax@theterramarproject.org;

	5. maxwell@theterramarproject.org; and

	6. ghislaine.maxwell@theterramarproject.org.

SeeMcCawley Deel. at Exhibit 4. The onl y emai l address which received a delivery failure message was maxwell@theterramarproject.org.

Accordingly, having made renewed - and unsuccessful efforts - to serve Maxwell through conventional means, Ms. Ransome now renews her request for alternative service as such means as the Court may find appropriate. Ms. Ransome respectfully suggests that, as the Court allowed in its previous order, that service of the complaints on cunent legal counsel representing her in a related matter before this Comt and other publicly identified email accounts be permitted as a means of alternative service.

## MEMORANDUM OF LAW

Service of a Complaint should not be a game of cat and mouse paiticularly where the defendant is represented by counsel in a matter pending in the same district. See Carillo v. Hagerty, No. 3:05CV1417 (MRK), 2006 WL 2165679, at * 1 (D. Conn. July 31, 2006) (comt

3

Case 1:17-cv-00616-JGK-SN

Document 97

Filed 01/05/18

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finding defendant should not benefit from service gamesmanship reasoning that: "service of process is not intended to be a game of hide and seek or cat and mouse.").

Based on the exhaustion of the other methods of service delineated above, Ms. Ransome moves, pursuant to Federal Rule of Civil Procedure 4(e)(l), for an order permitting service by an alternative method. Federal Rule of Civil Procedure 4(e)(l) provides that service upon a party may be effected by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." Accordingly, Defendant Maxwell may be served pursuant to CPLR § 308, which provides several methods by which service upon a natural person may be effectuated, including personal service; service by "delivering the summons ... to a person of suitable age and discretion at the actual place of business, dwelling place or usual place of abode of the person to be served" and then mailing the summons to the individual's "last know residence;" or service by "affixing the summons to the door of either the actual place of business, dwelling place or usual place of abode within the state of the person to be served" and then "mailing the summons to such person at his or her last known residence" or to his or her place of business - so called "nail and mail" service. CPLR §§ 308(1), (2) & (4).

If service under CPLR §§ 308(1), (2) & (4) is impracticable, CPLR § 308(5) permits service "in such manner as the court, upon motion without notice, directs." The determination of whether service is impracticable "depends upon the facts and circumstances of a particular case." Securities & Exch. Comm'n v. HGL Inc., No. 99 Civ. 3866 (DLC), 1999 WL 1021087, at *1 (S.D.N.Y. Nov. 8, 1999). Although the plaintiff must show impracticability of service, there is no requirement of "proof of due diligence or of actual prior attempts to serve a party under the other provisions of the statute." Id. "When usual methods of service prove impracticable, service

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that is reasonably calculated, under all the circumstances, to apprise the interested party of the pendency of the action will suffice." D.R.!., Inc. v. Dennis, No. 03 Civ. 10026 (PKL), 2004 WL 1237511, at *1 (S.D.N.Y. June 3, 2004).

New York Courts consistently affirm their right to direct or approve alternative methods of service where regular service has been deemed "impracticable." For example, in Dobkin v. Chapman,21 N.Y.2d 490,498,289 N.Y.S.2d 161, 168 (1968), the New York Court of Appeals held that where a plaintiff could not follow the prescribed methods of service as set forth in § 308, Courts are "given the discretion to fashion other means adapted to the particular facts of the case before it" pursuant to § 308(5) (referred to in Dobkinas § 308(4), the predecessor to § 308(5)). Moreover, the Court of Appeals held that a Court's discretion to fashion such methods of service "must be broad" if the statute is to be "meaningful." Id. at 499, 289 N.Y.S.2d at 168.

There is no doubt that Defendant Maxwell has had actual notice and knowledge of the claims asserted in this Complaint. Ms. Ransome has tried multiple alternative avenues to serve Maxwell, including (1) sending the documents to her current counsel in another matter, (2) investigating and attempting service at multiple locations known to be associated with Defendant Maxwell, and (3) emailing the documents to Defendant Maxwell's publicly available email address. As a result, this Court should deem the service methods attempted to be sufficient and grant the Motion for Alternate Service. See Rampersad v. Deutsche Bank Secs., Inc., No. 02 Civ. 7311 (LTS), 2003 WL21073951, at *1 (S.D.N.Y. May 9, 2003) (authorizing alternative service under§ 308(5) when Plaintiff was unable to determine Defendant's residence or place of business after "extensive Internet searches" and inquires with Defendant's former clients); Javier H. v. Garcia-Botello, 217 F.R.D. 308,309 (W.D.N.Y. 2003) (service by publication authorized when individual Defendant was a fugitive from the criminal justice system; was likely aware of

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the pending civil action through his relatives, who were co-Defendants; and when the Court determined that Defendant would likely read a newspaper that was circulated in the region of his last known residence); see also HG!, Inc., 1999 WL 1021087, at *1 (service by publication in USA Today authorized when Defendant's whereabouts were unknown, efforts to locate his home or business address by searching computer databases failed, and there existed no record that he designated an agent for service); D.R./., Inc., 2004 WL 1237511, at *2 (after Plaintiff unsuccessfully attempted to serve Defendant through a process server and searched databases for his address, Court authorized service by sending process by certified mail to Defendant's last known address; by publishing the action in a local newspaper; and by emailing it to Plaintiffs last known email address).

WHEREFORE, Plaintiff prays for this Court to enter an Order granting Plaintiffs Motion to Approve Alternative Service Pursuant to Federal Rule of Civil Procedure 4(e)(l) and New York Civil Practice Law and Rules Section 308(5) upon Defendant Ghislaine Maxwell and finding that the service efforts made by Plaintiffs counsel herein are sufficient. Dated: January 5, 2018

Respectfully submitted,

BOIES SCHILLER FLEXNER LLP

Isl Sigrid Mccawley
Sigrid S. Mccawley (Admitted Pro Hae Vice)
Meredith Schultz (Admitted Pro Hae Vice)
Boies Schiller Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
Tel: (954) 356-0011

Bradley J. Edwards, Esq.
Stanley Pottinger, Esq.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Tel: (954) 524-2820 Fax: (954) 524-2822

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Paul G. Cassell (Admitted Pro Hae Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-5202 2

2This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.

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## CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 5th day of January, 2018, 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 to all parties of record via transmission of the Electronic

Cou1t Filing System generated by CM/ECF.

Kimo S. Peluso
Sher Tremonte, LLP
90Broad Street, 23rd Floor
New York, NY 10004
kpel uso@she1trernonte.com
Counsel.for Haddon, Morgan & Foreman,
P.C.

Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Email: lmenninger@hmflaw.com
jpagliucaCcv,hmflaw.com

John E. Stephenson, Jr.
Jonathan D. Parente
ALSTON & BIRD LLP
1201 West Peachtree Street
Atlanta, GA 30309
John.stephenson@alston.com
Jonathan.parente@alston.com

Alexander S. Lorenzo
ALSTON & BIRD LLP
90 Park A venue
New York, NY 10016
alexander. lorenzo@alston.com
Counsel/or Defendant Sarah Kellen

Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
1114 A venue of the Americas
New York, NY 10036
mmil ler@steptoe.com
jchu@steptoe.com 
Counsel for Defendants, Jeffrey Epstein and
Lesley Groff

/s Sigrid McCawley
Sigrid McCawley

8

# EXHIBIT L

Ransome v. Epstein, Not Reported in Fed. Supp. (2018)

2018 WL 637421

2018 WL 637421 Only the Westlaw citation is currently available. United States District Court , S.D. New York.

Sarah RANSOME, Plaintiff,

V.

Jeffrey EPSTEIN, et al., Defendants.

17-cv-616 (JGK)
I 
Signed 01/30/2018

Attorneys and Law Firms

Justin Y.K. Chu, Michael Campion Mi ller, Steptoe & Johnson, LLP, Alexander Seton Lorenzo, Alston & Bird , LLP, New York, NY, Laura A. Menninger, Haddon, Morgan and Foreman, P.C., Denver, CO, John E. Stephenson Jr., Alston & Bird LLP, Atlanta, GA , for Defendants.

MEMORANDUM OPINION AND ORDER

John G. Koeltl, nited States District Judge

*1 The plaintiff, Sarah Ransome has moved the Court to approve alternative service on the defendant Ghislaine Maxwell and to find that service has been effected. The plaintiff asserts that, despite diligent measures, she has been unable to serve Maxwell personally. The plaintiff argues, however, that she has taken reasonable measures to provide Maxwell with notice of the pending lawsuit and requests that this service should be deemed sufficient. Non-party Haddon Morgan & Foreman, P.C. ("Haddon Morgan"), Maxwell's counsel in another litigation pending in this Court, has refused to accept service on behalf of Maxwell and has objected to becoming a general agent of process for Maxwell, but has taken no position on the plaintiff's application to deem service effected through the email efforts that the plaintiff has already made. Neither Maxwell nor any representative of Maxwell has otherwise opposed the current motion.

Federal Rule of Civil Procedure 4(e)(1) permits a plaintiff to serve a defendant by following the procedures set forth by state law in the state where the district court is located. New York Civil Practice Law and Rules Section 308 sets forth available methods of service. Where service under §§ 308(1), (2), or (4)-which generally provide variants of personal service is impracticable, § 308(5) provides that

the Court may approve alternative service methods. See, e. 0 .. Rampersad v. Deutsche Bank Sec., Inc., No. 02- cv-7311 (LTS)(AJP), 2003 WL 21073951 , at * I (S.D.N.Y. May 9, 2003). Service under § 308(5) requires a showing of impractieabi lity of the other meth ods of se1v ice, bur does not require a showing of du e di ligence. Id .

The plaintiff has taken various steps in an effort to serve Maxwell personally- all to no ava il. The pla intiff retained a private investigation firm to attempt to determine where Maxwell resides, and that firm attempted service at three physica l addresses potentially assoc iated with Maxwe ll. The plai ntiff also emai led the summons and complaint to severa l email addresses that are publicly assoc iated with Maxwell, only one of wh ich has been rel"urned as undelivered. The plaintiff has also provided a copy of the summons and complaint to Haddon Morgan who currently represents Maxwell in another li tigation pending in this district.

Under these circumstances, the plaintiff has demonstrated impracticability, because she has made numerous efforts to obtain information about the defendant's current residence and general contact information to effectuate personal service but has been unable to locate Maxwell. See, e.g., S.E.C. v. Nnebe, No. 01-cv-5247 (KMW), 2003 WL 402377, at *3 (S.D.N.Y. Feb. 21, 2003) (collecting cases). Accordingly, the Court finds that the plaintiff has demonstrated that service on Maxwell is impracticable and thus grants the motion for alternative service.

*2 Further, the steps already taken by the plaintiff to serve Maxwell are "reasonab ly ca lculated, under the circumstances, to app rise [her] of the pendency of the action and afford [her] an opportunity to present lhe]r obj ections," and the Court therefore deems service of the summons and comp laint lo be complete as to defendant Maxwell. See, e.g., Bozza v. Love. o. I 5-CV-3271 (LGS), 2015 WL 4039849, at *2 (S.D.N.Y. July I, 20 15) (holding that se rvice upon the defendant's counsel in an unrelated matter was sufficient); Rampersad, 2003 WL 2 107395 1, at *l.

Pinally, Haddon Mo rgan's objection to becoming a general agent of process fo r Maxwe ll is un fo unded. The Court's ruling that service by email and personal deli very to Haddon Morgan has been reasonably ca lcul ated to provide Maxwe ll with noti ce of this laws uit and an opportun ity to respond does not turn Haddon Morga n into a general agent for Maxwell. Indeed, this order does not even require Haddon Morgan to

WESTLAW 2020 Thomson Reuters. No claim to original U.S. Government Works.

Ransome v. Epstein, Not Reported in Fed. Supp. (2018)

2018 WL 637421

accept service on behalf of Maxwell, but rather finds that servi ce on Haddon Morgan is likely to provide notice of the lawsuit to Maxwell, given th at Haddon Morgan is presumab ly in contact with Maxwel l with regards to theiJ· representation of her in the other pending matter. See Bozza, 2015 WL 4039849, at *2.

Accordingly, the motion for alternative service is granted. The Clerk of Court is directed to close the motion pending at Docket Number 97. Defendant Maxwe ll 's time to move

or answer is twenty-one clays from the date of this order. lf Maxwell chooses not to appear, the plaintiff may pursue whatever remedies are avai lable, including the entry of a default judgment.

SO ORDERED.

All Citations

Not Reported in Fed. Supp., 2018 WL 637421

## Footnotes

1 The Clerk of Court is directed to amend the case caption to name Sarah Ransome as the plaintiff. See Docket No. 96.

End of Document

© 2020 Thomson Reuters. No claim to original U.S. Government Works.

WESTLAW 2020 Thomson Reuters. No claim to original U.S. Government Works.
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