document_description: The document provides instructions to a focus group regarding the indictment of Ghislaine Maxwell. It outlines the three counts against her: conspiracy to transport minors, conspiracy to commit sex trafficking, and sex trafficking of a minor. The document explains the burden of proof, the elements required to prove each count, and the concept of aiding and abetting.


source: doj

document_description: This document is a verdict form for the case United States v. Ghislaine Maxwell, where the jury is required to provide a unanimous verdict on three counts: Conspiracy to Transport a Minor in Interstate and Foreign Commerce, Conspiracy to Commit Sex Trafficking, and Sex Trafficking. The form is incomplete with no verdicts or signatures filled in.


document_description: The letter provides information regarding a case involving Ghislaine Maxwell, with details from the French Ministry of Justice. It includes a translation of an excerpt about a person who met Jeffrey Epstein and Ghislaine Maxwell at 16 in France and later traveled to Miami and New York with them. The letter is marked confidential under a protective order.


document_description: Ghislaine Maxwell was arrested by the FBI at her residence in Bradford, New Hampshire, on charges related to conspiracy to entice minors, enticement of a minor, conspiracy to transport minors, transportation of a minor, and perjury. The arrest was conducted without incident, and Maxwell was informed of her rights and charges. A cell phone was found in her possession, and another wrapped in tin foil was discovered but not taken by Maxwell. She was transported to Merrimack County Department of Corrections.


document_description: A subpoena issued by the United States District Court for the Southern District of New York, commanding the Sacramento County Clerk/Recorder to appear and produce a birth certificate in the case of United States v. Ghislaine Maxwell.


document_description: The U.S. Attorney's Office is producing additional materials, including Jencks Act and Giglio material, for the case United States v. Ghislaine Maxwell. The materials are designated as 'confidential' under the Protective Order and are marked accordingly.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to defense counsel regarding the production of materials in the case United States v. Ghislaine Maxwell. The letter details the confidentiality and protective order designations of the materials being produced.


document_description: A request for domestic travel arrangements for a fact witness in the case United States v. Ghislaine Maxwell. The document outlines the witness's travel needs, including appearance dates, hotel requirements, and confirmation that the witness is not facing criminal charges or residing outside the continental U.S.


document_description: The court addresses the Defense's motion to exclude Dr. Lisa Rocchio's expert testimony in the case against Ghislaine Maxwell. The motion is evaluated under Federal Rule of Evidence 702 and the Daubert standard. The court finds Dr. Rocchio qualified to testify on grooming and its effects on minors, but excludes her opinion on 'grooming-by-proxy.' The testimony is deemed relevant and not overly prejudicial, assisting the jury without commenting on specific witness credibility.


document_description: The court addresses the Defense's motion to exclude Dr. Lisa Rocchio's expert testimony in the case against Ghislaine Maxwell. The court denies the motion except for excluding the opinion that a third party can facilitate grooming. Dr. Rocchio's qualifications and the relevance of her testimony are discussed, with the court finding her methods reliable and her testimony relevant to the case.


document_description: A request for domestic travel arrangements for a fact witness in the case United States v. Ghislaine Maxwell. The document outlines the witness's travel needs, including appearance dates, hotel requirements, and other logistical details.


document_description: The document is a communication related to the legal case United States v. Maxwell, 20 Cr. 330, concerning juror questionnaires. It includes a joint letter from the parties involved.


document_description: A joint letter submitted to Judge Alison J. Nathan regarding the positions of the parties on juror questionnaires for the case United States v. Ghislaine Maxwell. It includes lists of prospective jurors proceeding to voir dire, those excused, and objections from both the defense and the government.


document_description: The document appears to be a redacted email or document related to the appointment of counsel. It includes a subject line, date, and mentions a courtroom deputy to Hon. Judith C. McCarthy at the U.S. District Court, S.D.N.Y. The document also references a 'Conflicts List' with a bar chart, but lacks specific data due to redaction.


document_description: The document contains a list of EFTA IDs ranging from EFTA00094684 to EFTA00094714. These appear to be reference numbers, possibly related to a larger dataset or collection of documents.


document_description: The document contains a series of EFTA IDs ranging from EFTA00094715 to EFTA00094722. No additional context or content is provided.


document_description: The court will discuss jury selection logistics and the unopposed request to seal the joint proposed juror questionnaire and voir dire. The court will also consider whether the sealing request should extend to its draft questionnaire and voir dire.


document_description: The Reporters Committee for Freedom of the Press and 17 news organizations urge the court to deny the defendant's request to seal the juror questionnaire and voir dire in the Ghislaine Maxwell case, citing the public's right to access.


document_description: A subpoena issued by the United States District Court for the Southern District of New York in the case against Ghislaine Maxwell, commanding the production of documents related to the Epstein Victims' Compensation Program (EVCP). The subpoena outlines the requirements for document production, including definitions and instructions for compliance. It also includes information about the EVCP protocol and eligibility requirements for claimants.


document_description: A memo discussing Shoppers Travel and their past dealings with Jeffrey Epstein. It mentions a conversation with Seth Rosenberg, who does not represent Shoppers Travel, and notes that they are not highly sophisticated and may need assistance. It references a $6,000 payment from Epstein to Rosenberg in June 2006 and a printout from April 2016 summarizing travel, names, invoice numbers, and amounts from January 4, 1999, through December 13, 2006, with a few entries from 2007-09. Darren Indyke is mentioned as a contact for Rosenberg. There is a belief that travel was arranged for Ghislaine Maxwell.


document_description: A legal request submitted by Jeffrey Pagliuca on behalf of Ghislaine Maxwell, asking the court to prohibit the government and associated parties from making extrajudicial statements that could prejudice Maxwell's right to a fair trial. The document cites recent public statements by government officials and attorneys that are claimed to violate Local Criminal Rule 23.1, which aims to prevent prejudicial pretrial publicity.


document_description: This document is a superseding indictment against Ghislaine Maxwell, detailing charges related to her role in the sexual exploitation and abuse of minor girls by Jeffrey Epstein. The indictment outlines multiple counts, including conspiracy to entice minors to travel for illegal sex acts, enticement of a minor, conspiracy to transport minors with intent to engage in criminal sexual activity, transportation of a minor, and perjury. The document provides a factual background of Maxwell's involvement with Epstein, her methods of grooming and abusing victims, and her efforts to conceal her conduct.


document_description: The court denies the defense's motion to prohibit the government and its agents from making extrajudicial statements about the case. The court expects compliance with local rules and warns of potential actions for violations.


document_description: The document is a protective order filed in the case of Ghislaine Maxwell, outlining the terms for handling confidential information during the discovery process. It specifies the conditions under which information can be designated as 'CONFIDENTIAL' and the parties who may access such information. The order also details the procedures for challenging confidentiality designations and the handling of confidential information at the conclusion of the case.


document_description: This document is a legal filing by Ty Gee, counsel for Ghislaine Maxwell, requesting the court to reconsider its decision to unseal deposition transcripts of Ms. Maxwell and Doe 1. The filing argues that the unsealing violates a Protective Order and could prejudice Ms. Maxwell's right to a fair trial. It also requests the court to investigate the violation of the Protective Order and to stay any unsealing pending appeal. The document references the government's use of the transcripts in indicting Ms. Maxwell and suggests that the plaintiff's actions may have been intended to set a perjury trap.


document_description: A table listing anonymous identifiers for employees and inmates, along with their attorneys and cooperator status.


document_description: This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure and seeks reciprocal discovery. It includes a list of materials designated as 'Protected Materials' under a protective order, such as MCC surveillance footage, commissary records, computer analysis, death reports, and more. The letter also outlines the Government's obligations under Brady v. Maryland and requests reciprocal discovery from the defendant.


document_description: A letter from the U.S. Attorney's Office to Jack A. Goldberger, Esq., notifying about the final list of identified victims in the Jeffrey Epstein case. It outlines the plea agreement and conditions, including the rights of victims under Title 18, United States Code, Section 2255.


document_description: An individual, referred to as JOSEPHINE, was interviewed by FBI agents regarding her knowledge of various individuals and events related to Jeffrey Epstein. JOSEPHINE discussed her encounters with notable figures such as Harvey Weinstein, Ghislaine Maxwell, Eva Dubin, Glen Dubin, Leon Black, and Jimmy Savile. She mentioned her suspicions about a cult-like organization and her observations at trade shows. JOSEPHINE also recounted her past interactions with Epstein when he was a substitute teacher at her high school and her observations of other individuals connected to Epstein.


document_description: Ghislaine Maxwell filed a complaint seeking indemnification and advancement of legal fees, security costs, and other expenses from the Estate of Jeffrey E. Epstein and NES, LLC. Maxwell claims these expenses were incurred due to her prior employment relationship with Epstein and his businesses. The complaint outlines Epstein's promises to support Maxwell financially and the Estate's failure to honor these promises after Epstein's death.


document_description: The document is a memo discussing the investigation into the circumstances surrounding Jeffrey Epstein's suicide on August 10, 2019, while in the custody of the Bureau of Prisons at the Metropolitan Correctional Center. It details the investigation into MCC staff's actions, including the decision not to reassign a cellmate to Epstein, failure to perform required checks, and falsification of records. It also covers the investigation into potential obstruction of justice following Epstein's death, including the shredding of documents. The memo discusses the proposed interview of an inmate, Lopez, regarding these events.


document_description: This memo discusses the investigation into the circumstances surrounding Jeffrey Epstein's apparent suicide on August 10, 2019, while in custody at the Metropolitan Correctional Center. It outlines the investigation into MCC staff's actions, including the decision not to reassign a cellmate to Epstein, failure to perform required checks, and falsification of records. The memo proposes interviewing three inmates who were housed near Epstein to gather information on the events of August 9-10, 2019.


document_description: A letter from Bennet J. Moskowitz of Troutman Sanders LLP to Sigrid S. McCawley of Boies Schiller Flexner LLP, addressing inquiries about the proposed Epstein Victims' Compensation Program. The letter discusses the total value of Epstein's Estate, potential liabilities, and the process for compensating victims. It emphasizes the need for further dialogue and input from plaintiffs' counsel to finalize the Program protocol.


document_description: Judge Richard M. Berman writes to Warden Lamine N'Diaye regarding the death of Jeffrey Epstein and questions whether investigations will include the incident at MCC on July 23, 2019.


document_description: A Grand Jury Subpoena issued by the United States District Court for the Southern District of New York, commanding Tova Noel to appear and testify regarding alleged violations of 18 U.S.C. §§ 371, 1001, 1519. The subpoena requires the production of materials related to Jeffrey Epstein, including electronic communications and devices used since July 6, 2019.


document_description: A grand jury subpoena issued by the United States District Court for the Southern District of New York, commanding the Metropolitan Correctional Center to produce documents and testify regarding alleged violations of 18 U.S.C. §§ 371, 1001, 1519, 2. The subpoena includes detailed instructions for document preservation and production, and requests confidentiality regarding the existence of the subpoena.


document_description: A letter from defense counsel for Jeffrey Epstein requesting medical or mental health records related to Epstein, necessary for investigating the circumstances of his death. The letter references a subpoena issued under Rule 17(c) of the Federal Rules of Criminal Procedure.


document_description: A Certification of Identity form submitted by Michael C. Miller to the U.S. Department of Justice, including personal information and a declaration under penalty of perjury.


document_description: The Government requests the Court to seal a portion of the sentencing transcript in the case of United States v. Rayshaun Jones due to ongoing investigations into Jeffrey Epstein's death and potential misconduct at the Metropolitan Correctional Center. The request is to prevent interference with the investigation and preserve confidentiality.


document_description: The New Mexico Office of the Attorney General provides materials related to the investigation of Jeffrey Epstein's co-conspirators to the Southern District of New York. The letter discusses the scope of the investigation, legal considerations, and offers continued cooperation.


document_description: A victim's detailed complaint regarding alleged crimes committed against her and her children, including sexual assault, identity theft, and fraud. The letter accuses Ghislaine Maxwell and others of involvement in a trafficking ring and financial fraud. The victim seeks justice, compensation, and protection for her family.


document_description: The document logs the submission of video evidence from the Metropolitan Correctional Center in New York, related to the death investigation of Jeffrey Epstein. It details the collection of a Seagate 500gb hard drive containing video footage from specific dates and locations within the facility.


document_description: Interview with Edward Jimenez, an inmate at MCC, regarding the events surrounding Jeffrey Epstein's last night. Jimenez provided details about the guards on duty and his observations of Epstein's cell.


document_description: Christopher Santos Felix, an inmate at the Metropolitan Correctional Center, was interviewed regarding the circumstances surrounding Jeffrey Epstein's death. Felix mentioned issues with a CPAP machine, guards not performing checks properly, and described the discovery of Epstein's body. He noted that Epstein had earphones in place when removed by EMS and recounted Epstein's activities prior to his death. Felix also provided information on contraband and inappropriate behavior between staff and inmates.


document_description: The report provides updates on various criminal cases and investigations handled by the DOJ's Criminal Division as of August 2, 2019. It covers topics such as terrorism, international narcotics, complex frauds, cybercrime, securities and commodities fraud, public corruption, violent and organized crime, money laundering, and general crimes. Notable cases include the investigation into Jeffrey Epstein's alleged sexual abuse of minors and various high-profile trials scheduled for the upcoming months.


document_description: Notes detailing observations and events surrounding the time of Jeffrey Epstein's death. The notes mention the presence of a cellphone in the bunkie's room, changes in guard behavior before and after Epstein's death, and inmate reactions. The author describes the view from their cell, including guards' activities and inmate commotion. The notes also mention that the guards treated inmates better after Epstein's death.


document_description: The New York Times Company filed a complaint under the Freedom of Information Act (FOIA) against the Federal Bureau of Prisons (BOP) to obtain records related to Jeffrey Epstein, who died at the Metropolitan Correctional Center. The complaint alleges that BOP failed to meet FOIA deadlines and improperly withheld records. The Times seeks an order for BOP to produce the requested records, which include information about Epstein's housing, suicide risk designation, and communications while at MCC.


document_description: The document is a legal memorandum submitted by the United States Attorney for the Southern District of New York in opposition to Ghislaine Maxwell's pre-trial motions. It argues against the relevance of Jeffrey Epstein's non-prosecution agreement to the case, asserts the timeliness of the indictment under 18 U.S.C. § 3283, and defends the government's actions regarding pre-indictment delay and evidence suppression. The memorandum also addresses the applicability of the Fifth Amendment and Due Process Clause to the case.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to the MDC Legal Department, providing a password for discovery materials related to the case United States v. Ghislaine Maxwell.


document_description: A letter from the U.S. Attorney's Office to defense counsel regarding the production of discovery materials in the case United States v. Ghislaine Maxwell. The letter lists the materials being produced, including records from Deutsche Bank, JPMorgan Chase, Citibank, UBS, and American Express, and provides instructions for accessing certain file types.


document_description: Plaintiff responds to Defendant Ghislaine Maxwell's request for a pre-motion conference regarding her anticipated motion to stay discovery. The response argues against the stay, citing lack of justification due to pending criminal investigations, potential claims resolution programs, and Maxwell's motion to dismiss. The document emphasizes that Maxwell's reasons for staying discovery are meritless and an attempt to delay litigation.


document_description: Virginia Giuffre opposes Ghislaine Maxwell's motion to consolidate her civil and criminal appeals, arguing that the issues in the two cases are unrelated and consolidation would delay the unsealing process of judicial documents. The response emphasizes the importance of public access to judicial documents and argues that consolidation would not serve equity or judicial economy.


document_description: Robert Lewis informs Alexander and Alison about developments in the Epstein case, including media inquiries and potential breaches of confidentiality related to deposition testimony and flight documents.


document_description: A subpoena issued by the State of Delaware Division of Corporations requesting records related to L.S.J, LLC, a Delaware limited liability company. The records requested include Certificates or Articles of Incorporation, business addresses, service of process addresses, and information on Directors, Officers, and Beneficial Owners. The subpoena also requests any regularly filed statements and certificates. The records are to be sent to the FBI at 26 Federal Plaza, New York, NY.


document_description: The document is an opinion and order from the United States District Court, Southern District of New York, regarding a motion to dismiss a case involving Plaintiff and Defendants including Ghislaine Maxwell and executors of Jeffrey Epstein's estate. The Plaintiff filed a motion to dismiss the case with prejudice, which was opposed by Maxwell. The court discusses the conditions of dismissal, including the confidentiality of compensation received by the Plaintiff from the Epstein Victims' Compensation Program and the allocation of attorneys' fees and costs. The court grants the dismissal with modifications to the proposed order, subject to Plaintiff's consent.


document_description: A notice of docket activity for the case United States of America v. Epstein, case number 19-2221, indicating an attorney was added. The document includes redacted information and mentions Reid Weingarten.


document_description: This document is a transcript of a bail hearing for Jeffrey Epstein held on July 15, 2019, in the Southern District of New York. The hearing was presided over by Judge Richard M. Berman. The government sought pretrial detention for Epstein, citing risk of flight and danger to the community, while the defense argued for bail, emphasizing Epstein's compliance with legal obligations and the presumption of innocence. The hearing included discussions on Epstein's financial disclosures, past legal agreements, and allegations of witness tampering. Victims and their representatives were present, with some speaking against granting bail.


document_description: A grand jury subpoena issued to Deutsche Bank AG, New York Branch, in connection with a federal criminal investigation involving Jeffrey Epstein. The subpoena requests a wide range of financial records from January 1, 2010, to the present, including account statements, transaction records, and correspondence. The document emphasizes the confidentiality of the investigation and requests non-disclosure of the subpoena's existence.


document_description: A grand jury subpoena issued to American Express requesting records related to Jeffrey Epstein for an investigation into alleged violations of federal criminal law. The subpoena requests a wide range of financial records and emphasizes non-disclosure due to the ongoing nature of the investigation.


document_description: Email correspondence discussing the availability of clients for interviews regarding victim reports against Jeffrey Epstein. The email also mentions attached photos for review to confirm if the clients are in any of the photographs seized from Epstein's home.


document_description: This document is a verdict sheet for the case against Ghislaine Maxwell, listing six counts related to conspiracy and illegal sexual activity, including sex trafficking. The verdict options for each count are marked as either 'Guilty' or 'Not Guilty'.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to defense counsel regarding the production of materials in the case United States v. Ghislaine Maxwell. The letter outlines the confidentiality designations under the Protective Order and provides an index of the materials produced.


document_description: The court will hold an in-person pretrial conference for Ghislaine Maxwell on November 1, 2021, at the Thurgood Marshall U.S. Courthouse. Access will be provided for alleged victims and family members, with two pool reporters allowed in the courtroom. Overflow rooms will be available for the public with live feeds, subject to COVID-19 protocols.


document_description: An anonymous caller reported information about Jeffrey Epstein's activities, including recruitment by Carolyn Doughtery, interactions with Ghislaine Maxwell, and associations with public figures like Donald Trump. The report details Epstein's behavior, his island activities, and his connections with notable individuals.


document_description: A search and seizure warrant issued by the United States District Court for the Southern District of New York, authorizing the search of electronic devices seized from Jeffrey Epstein's properties and person. The warrant is related to violations of 18 U.S.C. 1591, 18 U.S.C. 2422, 18 U.S.C. 2423, and 18 U.S.C. 371. The warrant lists specific devices to be searched and the types of evidence sought, including communications, documents, and photographs related to sex trafficking and conspiracy offenses.


document_description: A protective order issued by the United States District Court for the Southern District of New York in the case involving Ghislaine Maxwell. The order outlines the handling of confidential information during the discovery process, including the designation, use, and disclosure of such information. It specifies the parties who may access confidential information and the procedures for challenging confidentiality designations.


document_description: The document contains EFTA IDs: EFTA00095527, EFTA00095528, EFTA00095529, EFTA00095530. No additional content or context is provided.


document_description: This document is a declaration by Sigrid S. McCawley, a partner at Boies, Schiller & Flexner LLP, in support of the plaintiff's response to Ghislaine Maxwell's motion for a protective order. It includes references to various exhibits such as deposition notices and email correspondence. The document also contains a proposed protective order to safeguard confidential information in the case, including sensitive personal information, trade secrets, and proprietary information. The order outlines the handling of confidential information and the process for challenging designations of such material.


document_description: The FBI's Palm Beach County Resident Agency (PBCRA) began investigating Jeffrey Epstein for child prostitution. The investigation involved interviews and evidence collection, including telephone message pads indicating sexual activities arranged by Epstein. A search warrant was executed at Epstein's home, but some items, like CPUs, were missing. Epstein's residences in Palm Beach, the U.S. Virgin Islands, New York, and New Mexico were noted. The PBCRA is seeking assistance to establish Epstein's criminal activities involving interstate commerce.


document_description: The DOJ Office of Professional Responsibility (OPR) investigated allegations of misconduct by the U.S. Attorney's Office for the Southern District of Florida in resolving a federal investigation into Jeffrey Epstein through a non-prosecution agreement (NPA). The report examines the negotiation, execution, and implementation of the NPA, as well as the government's interactions with Epstein's victims. The OPR found no professional misconduct but criticized the judgment of U.S. Attorney R. Alexander Acosta in resolving the case through the NPA and in handling victim interactions.


document_description: The U.S. Department of Justice requests assistance from French authorities in the prosecution of Ghislaine Maxwell, related to her involvement in the sexual exploitation and abuse of minors by Jeffrey Epstein. The request includes conducting interviews with a French witness and obtaining records from Epstein's Paris residence.


document_description: The U.S. Department of Justice responds to defense counsel's request for a bill of particulars in the case against Ghislaine Maxwell. The government argues that it has already provided sufficient information through the indictment and discovery, and is not obligated to provide further details. The letter cites legal precedents to support the position that a bill of particulars is not warranted and addresses specific requests made by the defense.


document_description: Chris Dilorio forwards an email discussing SEC corruption and conspiracy related to Knight Capital and other financial entities. He accuses the SEC of obstructing investigations and facilitating illegal activities, while denying him rightful compensation as a whistleblower. The email includes references to various financial entities and individuals involved in alleged fraudulent activities.


document_description: This document is a letter from Mark S. Cohen and Christian R. Everdell of Cohen & Gresser LLP to Judge Alison J. Nathan regarding pretrial motions for the case United States v. Ghislaine Maxwell. The letter outlines several motions to dismiss various counts of the superseding indictment, motions to suppress evidence, and motions for severance and separate trials. It also discusses the handling of confidential information and redactions in accordance with a protective order.


document_description: This document contains various legal and registration forms related to Jeffrey Epstein's status as a sex offender. It includes certification of records, sex offender registration forms, and correspondence regarding his registration status in New York and other jurisdictions. The document also details Epstein's vehicles, boats, aircraft, and internet-related information.


document_description: Prosecutors in the case of United States v. Ghislaine Maxwell are reaching out to discuss potential expert witness testimony for the trial scheduled on July 12, 2021.


document_description: The court orders the Government to confer with MDC legal counsel about Ghislaine Maxwell's transportation to the courthouse and her access to legal mail. The Government must file a letter by November 8, 2021, and the order will be transmitted to Chief Judge Brodie for further discussion regarding pre-trial detainees' access to legal mail.


document_description: The court orders the Government to respond to Ghislaine Maxwell's motions for reconsideration by specified dates. The court also provides details on the juror selection process and peremptory challenges.


document_description: The court orders the Government to confer with MDC legal counsel about Defendant Ghislaine Maxwell's transportation to the courthouse and to ensure she receives her legal mail promptly. The Government must file a letter by November 8, 2021, and the order will be transmitted to Chief Judge Brodie for further discussion on access to legal mail for pre-trial detainees.


document_description: A detailed list of particulars related to the charges against Ghislaine Maxwell, focusing on interactions with Minor Victims-1-3, including grooming, sexual abuse, and interstate travel for illegal activities. The document requests specific dates, locations, and descriptions of alleged criminal activities, as well as identification of other participants and conspirators.


document_description: The document outlines requests for all written and oral communications related to the negotiations of the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein on September 24, 2007, including communications between government entities and Epstein's attorneys. It also requests communications concerning meetings between attorneys for accusing witnesses and SDNY prosecutors regarding Epstein and Ghislaine Maxwell.


document_description: The FBI's Palm Beach County Resident Agency (PBCRA) began investigating Jeffrey Epstein for child prostitution. The investigation involved interviews and evidence collection, including telephone message pads indicating sexual activities arranged by Epstein. A search warrant was executed at Epstein's home, but some items, like CPUs, were missing. Epstein maintained residences in multiple locations, and the investigation aimed to establish his criminal activities across state lines. The PBCRA sought assistance to further the investigation, with a target indictment date of January 2007.


document_description: The DOJ's Office of Professional Responsibility (OPR) investigated allegations of improper resolution of a federal investigation into Jeffrey Epstein by the U.S. Attorney's Office for the Southern District of Florida. The investigation focused on the non-prosecution agreement (NPA) signed in 2007, which ended the federal investigation into Epstein's alleged illegal sexual activities with minors. The report examines the negotiation, execution, and implementation of the NPA, as well as the USAO's interactions with Epstein's victims, particularly in relation to the Crime Victims' Rights Act (CVRA). The report concludes that while no professional misconduct was found, poor judgment was exercised in the handling of the NPA and victim interactions.


document_description: The Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the case against Ghislaine Maxwell. The letter also mentions materials related to individuals not currently intended to be called as witnesses. These materials are governed by a Protective Order.


document_description: This document contains a comprehensive list of non-testifying witness materials related to the case of United States v. Ghislaine Maxwell. It includes various types of reports, letters, interview notes, and other legal documents produced to the defense. The document is subject to protective order paragraphs 7, 8, 9, 10, 15, and 17.


document_description: This document contains a detailed list of materials related to the testifying witnesses in the case of United States v. Ghislaine Maxwell. It includes notes, interview transcripts, emails, FBI reports, and other legal documents produced to the defense. The document is subject to a protective order and includes various dates and descriptions of the materials.


document_description: The document contains EFTA IDs: EFTA00095826, EFTA00095827, EFTA00095828. No additional information is provided.


document_description: The court reviewed and approved proposed redactions and sealing requests for certain exhibits in the case against Ghislaine Maxwell, ensuring they align with privacy protection standards.


document_description: This document is a legal correspondence from Jeffrey S. Pagliuca of Haddon, Morgan and Foreman, P.C., addressed to the counsel in the case United States v. Ghislaine Maxwell. It outlines the expert witnesses and their expected testimonies for the defense, including Dr. Elizabeth Loftus on memory, Dr. Park Dietz on forensic psychiatry, and others. The document discusses various psychological concepts such as false memories, grooming, hindsight bias, and the halo effect, and how these may relate to the case. It also mentions the potential testimony of experts in computer forensics, financial investigation, and document examination.


document_description: The court addresses the Government's letter motion seeking clarification on cross-examination limits for witnesses testifying under pseudonyms and orders a proposed order on sketch artist depictions.


document_description: This document contains news clippings related to various legal cases and issues, including Michael Avenatti's extortion charges against Nike, Jeffrey Epstein's charges and subsequent investigations, and other legal matters involving public figures.


document_description: The document contains news clips from August 20, 2019, covering various legal cases and issues. It includes articles on Michael Avenatti's legal battles, Jeffrey Epstein's charges being dropped posthumously, and ongoing investigations, as well as other legal matters involving public figures and government actions.


document_description: This document is a legal filing by Reid Weingarten of Steptoe & Johnson LLP, addressed to Judge Richard M. Berman, outlining the grounds for Jeffrey Epstein's pretrial release. It argues against pretrial detention, citing Epstein's compliance with legal obligations, the nonprosecution agreement (NPA), and proposes stringent conditions for release. The document also discusses the legal framework of the Bail Reform Act and challenges the government's indictment under 18 U.S.C. § 1591, arguing that Epstein's conduct does not constitute sex trafficking under federal law.


document_description: The document is a letter from Brenda Smith discussing potential lawsuits and allegations involving high-profile individuals and organizations. It mentions possible health risks associated with NCR paper and implicates figures like Bill and Hillary Clinton, the DNC, and others in a conspiracy. The letter demands a $50,000 deposit to avoid further legal action and public exposure of the claims.


document_description: The document contains a list of EFTA IDs ranging from EFTA00095921 to EFTA00095931. No additional information or context is provided.


document_description: A search and seizure warrant issued for three electronic devices seized from Jeffrey Epstein's residence at 9 East 71st Street, New York, NY. The warrant is related to violations of 18 U.S.C. 1591, 2422, 2423, and 371, concerning sex trafficking and related offenses. The devices are to be searched for evidence of these offenses, including communications, financial records, and photographs.


document_description: The document contains news clippings from various sources covering topics such as public corruption, the Jeffrey Epstein case, and other legal matters. Notable figures mentioned include Prince Andrew, Michael Avenatti, and Harvey Weinstein.


document_description: US Attorney Geoff Berman announces the unsealing of sex trafficking charges against Jeffrey Epstein, detailing the allegations of sexual abuse of underage girls and the legal proceedings following his arrest.


document_description: A grand jury subpoena issued to Facebook, Inc. as part of a criminal investigation, with a non-disclosure order preventing notification of the subpoena's existence for 365 days. The subpoena requests records related to Instagram accounts associated with specific identifiers, including the account name 'ghislainemaxwell6'.


document_description: A Grand Jury Subpoena issued to Amazon.com, Inc. by the United States District Court for the Southern District of New York, dated June 12, 2020. The subpoena requests records related to Ghislaine Maxwell and Ghislaine Borgerson, including subscriber information, IP addresses, order history, and payment methods. A non-disclosure order accompanies the subpoena, prohibiting Amazon from disclosing its existence for 365 days. The document includes a Declaration of Custodian of Records form.


document_description: A grand jury subpoena issued to Citibank N.A. by the United States Attorney for the Southern District of New York, requesting various financial records related to an ongoing criminal investigation. The subpoena includes a request for non-disclosure to preserve the confidentiality of the investigation.


document_description: The document is an amended application submitted by the United States Attorney's Office for the Southern District of New York, requesting a second warrant and order for prospective and historical location information and pen register information for a cellphone associated with Ghislaine Maxwell. The application includes legal justifications and requests for non-disclosure to the subscriber and sealing of the documents.


document_description: A grand jury subpoena issued by the United States Attorney for the Southern District of New York, requesting records related to inmate Jeffrey Epstein, including email correspondence and telephone call records, excluding communications with specified attorneys. The subpoena is part of a criminal investigation into alleged violations of 18 U.S.C. §§ 1591, 1594(c), 2422(b).


document_description: A grand jury subpoena issued to the Metropolitan Correctional Center requesting audio recordings and records of telephone calls to or from inmate Jeffrey Epstein for the period July 6, 2019 through July 11, 2019, excluding communications with specified individuals. The subpoena is part of an official criminal investigation by a federal grand jury.


document_description: This document contains a series of emails from Chris Dilorio to various recipients, including the SEC, regarding his whistleblower claims about financial misconduct involving Knight Capital, UBS, and other entities. Dilorio alleges that the SEC has used his information to both bring and obstruct complaints, denying him rightful compensation. He details extensive trading and money laundering activities involving penny stocks, and criticizes the SEC for failing to investigate thoroughly. The emails also mention various financial entities and individuals involved in these activities.


document_description: The document is a letter from the U.S. Attorney's Office for the Southern District of New York to Judge Henry Pitman, arguing against granting bail to Jeffrey Epstein. It outlines the serious nature of the charges against Epstein, including sex trafficking of minors, and emphasizes the risk of flight due to his wealth, access to private planes, and international ties. The letter also highlights Epstein's history of witness tampering and the potential danger he poses to the community.


document_description: The document contains a list of EFTA IDs ranging from EFTA00096155 to EFTA00096188. No additional information or context is provided.


document_description: An individual was interviewed regarding their interactions with Jeffrey Epstein. The interviewee described being introduced to Epstein through a friend and visiting his house multiple times for massages. They mentioned interactions with Ghislaine Maxwell and noted Epstein's connections to famous people, including Donald Trump. The interviewee discussed the nature of their visits, the payments received, and the pressure to bring friends. They also mentioned Epstein's investigators visiting their parents' home and their own contact with law enforcement. The interviewee kept a box of items related to Epstein and had been contacted by media outlets.


document_description: The document is an FBI interview record of a person who was involved with Jeffrey Epstein. The interviewee describes her background, experiences with Epstein, and the recruitment of young girls for Epstein. She details the nature of the massages, the recruitment process, and interactions with Epstein's associates. The interviewee also discusses her personal life, drug use, and eventual cessation of contact with Epstein.


document_description: The document is an FBI interview record of a witness who was introduced to Jeffrey Epstein at the age of 14. The witness describes being recruited to give massages to Epstein and bringing other girls to him, some of whom were underage. The witness recounts Epstein's preferences and behaviors during these encounters, including his requests for underage girls and his method of payment. The witness also mentions receiving gifts from Epstein and being contacted by his attorney. The document includes details of harassment by Epstein's investigators and media contact following the witness's interview with the Miami Herald.


document_description: A formal request for discovery in the case of United States v. Jeffrey Epstein, submitted by Michael C. Miller and Martin G. Weinberg on behalf of Jeffrey Epstein. The letter requests various documents and information from the government, including statements made by Epstein, documents and tangible objects related to the case, particulars of the indictment, Brady material, Jencks material, and other evidence. The letter also addresses issues related to privileged material and scientific evidence.


document_description: This document provides updates on the legal proceedings in the case of United States v. Jeffrey Epstein, including details of court hearings, bail status, and charges related to sex trafficking of minors. It also includes information about financial transactions linked to Epstein, his business dealings in the Virgin Islands, and connections to political campaigns. Additionally, it discusses the involvement of BDO USVI in disaster recovery projects and the implications of a corruption scandal in Puerto Rico on the Virgin Islands.


document_description: NYPD incident report detailing an ambulance case for a female having difficulty breathing. The incident occurred on 9/4/2013 at 19:21 at an address on a redacted street near 5th Ave and Madison Ave in Manhattan. The case was marked as serious, but both EMS and patrol resources were canceled shortly after.


document_description: A conference call organized by The Bloom Firm regarding Epstein, scheduled for January 23, 2020, from 20:00 to 20:30 UTC. UberConference details provided.


document_description: This document is a comprehensive questionnaire for official foreign travel by United States Attorneys' Offices and the Executive Office for United States Attorneys. It includes detailed travel itineraries, hotel reservations, and questions related to travel arrangements, security clearances, and case details. The document also includes a certificate of completion for a High Threat Security Overseas Seminar and a detailed itinerary for a trip to Stockholm, Sweden, for a judicial assistance matter related to the Jeffrey Epstein case.


document_description: The U.S. Department of Justice's Office of International Affairs requests assistance from Swedish authorities in interviewing a witness related to the investigation of Jeffrey Epstein's associates for sexual misconduct with minors. The request is made under the U.S.-Sweden Mutual Legal Assistance Treaty. The document outlines the offenses under investigation, the need for confidentiality, and the assistance requested, including permission for U.S. authorities to conduct an interview in Sweden.


document_description: A grand jury subpoena issued to National Registered Agents, Inc. for Expedia, Inc. requesting records related to flights purchased, booked, or taken by Ghislaine Maxwell. The subpoena is part of a federal criminal investigation and requests non-disclosure of the subpoena's existence.


document_description: An FBI report documenting a phone call with an individual who provided information about Jeffrey Epstein and Ghislaine Maxwell. The individual did not know Epstein and Maxwell well but recounted an incident involving her daughter visiting Epstein's home. The individual expressed strong negative opinions about Maxwell, describing her as 'evil' and worse than Epstein.


document_description: A letter from Akin Gump Strauss Hauer & Feld LLP to the Assistant U.S. Attorney regarding a grand jury subpoena issued to Deutsche Bank. The letter discusses the submission of documents related to Jeffrey Epstein's accounts and emphasizes the confidentiality of the materials under Federal Rule of Criminal Procedure 6(e).


document_description: A Citrix file sharing notification for a file named DB-SDNY-Prod004.zip, which is 67.4 MB in size. The file is shared by Thomas Moyer using Citrix Files and is set to expire on January 26, 2020.


document_description: WilmerHale, on behalf of JPMorgan Chase, responds to grand jury subpoenas related to Jeffrey Epstein and Ghislaine Maxwell. The letter encloses encrypted zip files with documents and wire data for accounts related to Epstein and Maxwell. It requests confidential treatment under FOIA and discusses exemptions from disclosure.


document_description: Judge Richard M. Berman acknowledges receipt of a letter from the MCC Warden regarding Jeffrey Epstein's death and inquires about the investigation into an incident involving Epstein on July 23, 2019.


document_description: Notice of Docket Activity for the case United States of America v. Epstein, Case Number 19-2221. A FRAP 42(b) Stipulation with Prejudice was received on 08/20/2019. The document was electronically filed and is associated with the transaction filed on the same date.


document_description: Notes from a conversation with a witness regarding her relationship with Leon Black and Jeffrey Epstein. The witness describes an abusive relationship with Leon Black from 2010 to 2014, during which she was raped in various locations and received financial payments. She also mentions meeting Epstein and visiting his house in Florida. The relationship with Black became hostile, and she was threatened when she refused to engage sexually. She still possesses a phone with correspondence and signed an NDA at the end of the relationship.


document_description: The document contains a series of EFTA IDs ranging from EFTA00096434 to EFTA00096441. No additional context or content is provided.


document_description: The document contains a travel itinerary for a trip from New York to Stockholm via Amsterdam and Paris, with hotel reservations in Stockholm. It also includes a detailed questionnaire for official foreign travel by a USAO-SDNY employee, related to the Jeffrey Epstein case, mentioning Ghislaine Maxwell as a subject of investigation.


document_description: This document contains Instagram business records for the account 'ghislainemaxwell', including account details, registration information, and login records.


document_description: Instagram profile for Ghislainemaxwell6 with no posts, 9 followers, and 0 following. The profile has 'Follow' and 'Message' buttons, indicates 'No Posts Yet', and includes a 'Suggested for You' section.


document_description: A sealed order authorizing the FBI to use a pen register and trap-and-trace device on a phone line subscribed to by Ghislaine Maxwell, as part of an investigation into possible violations of federal law. The order allows for the collection of phone numbers, IP addresses, and communication ports associated with the phone line, excluding the content of communications. The order is valid for 60 days and requires AT&T to assist in the installation and operation of the device.


document_description: The court has set November 29, 2021, as the trial start date for Ghislaine Maxwell, with jury selection to occur during the week of November 15. The court grants the Government's motion to exclude time until November 29, 2021, under the Speedy Trial Act. The parties are ordered to meet and confer on pretrial disclosures and submit a joint letter by May 14, 2021.


document_description: The document is a placeholder indicating that no images were produced for the specified EFTA ID.


document_description: Palm Beach Police Department incident report detailing the execution of a search warrant at 358 El Brillo Ave, Palm Beach. The report describes the search of various areas including the garage, kitchen, office, and bedrooms, where items such as a phone message book, massage tables, partial nude photographs, and adult items were seized as evidence. The report concludes with the officer's involvement in the case.


document_description: This document is a legal response from Jeffrey Pagliuca of Haddon, Morgan and Foreman to Judge Alison J. Nathan regarding the government's handling of evidence in the case against Ghislaine Maxwell. It addresses issues with the government's response to a subpoena for evidence controlled by Boies, Schiller, and Flexner, including a journal, boots, and photographs related to the case. The response criticizes the government's selective disclosure of evidence and its reliance on information from lawyers adverse to Maxwell.


document_description: Ghislaine Maxwell renews her motion for pretrial release or, alternatively, requests a remand for an evidentiary hearing. The motion highlights the harsh conditions of her confinement, including sleep deprivation due to frequent flashlight checks, inadequate living conditions, and restricted access to legal resources, which impede her ability to prepare for trial. The motion argues that these conditions are unjustified and requests either her temporary release or a hearing to address these issues.


document_description: A series of letters between Interlochen Center for the Arts and Jeffrey Epstein, discussing donations and contributions made by Epstein, including a $15,000 donation for a scholarship lodge, private jet transportation for Itzhak Perlman, and a $200,000 gift for a new scholarship lodge. The letters also mention Ghislaine Maxwell and the use of the lodge by Epstein and guests.


document_description: This document is a list of various items related to the Jeffrey Epstein case, including original notes, subpoenas, DVDs of monitored phone calls, passports, address books, invoices, phone records, and BOP records.


document_description: This document is a series of emails from Chris Dilorio to various recipients, including Janey, Hoecker, and others, regarding his formal appeal for the denial of a covered action related to Knight Capital TCR & Appendix. Dilorio alleges SEC corruption, obstruction, and misuse of his whistleblower information. He claims that the SEC has used his information to both bring and obstruct complaints, denying him rightful compensation. The emails detail various allegations of fraud, money laundering, and SEC facilitation of illegal activities involving entities like Knight Capital, UBS, and others. Dilorio repeatedly requests updates to his TCRs and expresses frustration with the SEC's handling of his claims.


document_description: The client has agreed to provide information and respond to questions to help the Government make prosecutive decisions. This is not a cooperation agreement, and the Government is not obligated to make a motion on the client's behalf or enter into any agreement (cooperation, plea, immunity, or non-prosecution).


document_description: This report provides an update on child exploitation cases coded 080 or 087, highlighting events within the last 45 days. It includes case numbers, dates, and statuses related to Jeffrey Epstein and Ghislaine Maxwell, among others. The report also lists EFTA reference numbers for tracking purposes.


document_description: This report provides an update on child exploitation cases coded o8o or o87, highlighting events within the last 45 days. It includes case details for Jeffrey Epstein and Ghislaine Maxwell, among others, and instructions for AUSAs to update case statuses.


document_description: This report provides an update on child exploitation cases coded as o8o or o87, highlighting events within the last 45 days. It includes case details for Jeffrey Epstein and Ghislaine Maxwell, noting public corruption and victim/witness flags. The report also lists EFTA reference numbers and instructions for AUSAs to update case statuses.


document_description: A personal meeting scheduled for Epstein T&E on January 10, 2020, from 16:30 to 17:30 at the office.


document_description: Event details for a meeting titled 'Epstein T&E Meeting' scheduled on January 10, 2020, from 16:30 to 17:30 at the office. The event was created and modified on January 9, 2020. Priority level is 5.


document_description: Ghislaine Maxwell was charged with conspiring with Jeffrey Epstein to sexually abuse minors and perjury. The indictment alleges that between 1994 and 1997, Maxwell and Epstein exploited minors, enticing them to travel for illegal sex acts. Maxwell is accused of grooming and facilitating the abuse of minors, and making false statements in 2016 depositions. She faces multiple charges, each carrying significant prison sentences.


document_description: The court has scheduled an arraignment, initial appearance, and bail hearing for Ghislaine Maxwell on July 10, 2020. Due to COVID-19, the proceedings may be conducted remotely if the defendant waives her physical presence. The court outlines the protocol for remote proceedings and requires defense counsel to confer with the defendant regarding this option.


document_description: An arraignment, initial conference, and bail hearing for Ghislaine Maxwell is scheduled for July 14, 2020, via remote video/teleconference. The order outlines the procedures for accessing the video and audio feeds, COVID-19 protocols for courthouse entry, and the rights of crime victims to be notified and heard. The order also addresses the exclusion of time under the Speedy Trial Act.


document_description: The indictment charges Ghislaine Maxwell with multiple counts related to the sexual exploitation and abuse of minor girls by Jeffrey Epstein. The charges include conspiracy to entice minors to travel for illegal sex acts, enticement of a minor, conspiracy to transport minors for criminal sexual activity, transportation of a minor for criminal sexual activity, and perjury. The document details Maxwell's role in recruiting, grooming, and abusing minors, as well as her efforts to conceal her conduct through false statements under oath.


document_description: The document contains multiple USAA credit card statements for Scott Borgerson and Ghislaine Maxwell, detailing transactions, payments, and account summaries over several months in 2020. It includes information on purchases, payments, and credits, as well as interest rates and payment conditions. The statements also provide details on the USAA Rewards Program and instructions for addressing errors or disputes.


document_description: The memo discusses updates to a prosecution memo with minor changes from previous versions. It highlights a section for accuracy review and mentions the exclusion of 'endangering the welfare of a minor' due to a circuit split issue.


document_description: This document is an application for delivery of mail through an agent, specifically for Ghislaine Maxwell. It includes terms and conditions for mail delivery, identification requirements, and authorization details for mail handling by The UPS Store #5768 in Boston, MA.


document_description: SDNY Grand Jury Subpoena issued on July 5, 2019, with an event scheduled for November 7, 2019.


document_description: A Skype meeting event related to the civil forfeiture matter in the case of US v. Epstein.


document_description: A grand jury subpoena issued to Deutsche Bank AG and Deutsche Bank Securities Inc. in connection with a federal criminal investigation involving Jeffrey Epstein. The subpoena requests a wide range of financial records from January 1, 2010, to the present, including account statements, transaction records, and correspondence. The document emphasizes the confidentiality of the investigation and requests non-disclosure of the subpoena's existence.


document_description: A grand jury subpoena issued to American Express requesting records related to Jeffrey Epstein for an investigation into alleged violations of federal criminal law. The subpoena requests a wide range of financial records from January 1, 2010, to the present and emphasizes non-disclosure due to the ongoing nature of the investigation.


document_description: The court denies Ghislaine Maxwell's motion to modify the protective order to use discovery materials in civil cases. The court finds no good cause for modification and notes that the information Maxwell seeks to disclose is already publicly available. The court permits Maxwell to provide certain information under seal to relevant courts and allows her to make unsealing applications to those courts.


document_description: Postage mark from Pitney Bowes with a postage amount of $3.50, mailed from zip code 33301. Associated with Farmer, Jaffe, Weissing, Edwards, Fistos at Lehrman, P.L. Specializes in mass torts, class action, personal injury, wrongful death, whistleblower claims, and commercial litigation.


document_description: A letter from the law firm Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. regarding various legal services including mass torts, class action, personal injury, wrongful death, whistleblower claims, and commercial litigation.


document_description: Inmate Nicholas Tartaglione was found in possession of a cell phone on July 2, 2019. The report includes a reference to telephone numbers found in the phone's history.


document_description: The U.S. Department of Justice requests TD Bank to keep certain accounts open for a month to avoid jeopardizing an ongoing investigation. The accounts are associated with Butterfly Trust and Aviloop LLC. The letter outlines the conditions under which the accounts should remain open and the legal obligations of TD Bank.


document_description: This document is an official FBI collected item log detailing the execution of a search warrant at Jeffrey Epstein's residence at 9 East 71st Street, New York, NY. Various digital devices were collected, including computers, hard drives, USB drives, and other electronic storage devices.


document_description: A subpoena issued to Capital One Bank requesting comprehensive financial records for specific accounts and individuals. The request includes transaction files, documents reflecting account activity, identification proofs, account opening documents, wire transfer records, safe deposit records, trust accounts, monthly statements, credit card statements, checks, prepaid debit cards, loan applications, online banking information, corporate resolutions, and correspondence related to the accounts.


document_description: A grand jury subpoena issued to JP Morgan Chase Bank N.A. for records related to a criminal investigation. The subpoena requests various financial documents and records from account inception to present, including checks, wire transfers, and correspondence. The document emphasizes non-disclosure to third parties to maintain confidentiality of the investigation.


document_description: A subpoena issued to JP Morgan Chase Bank N.A. and its affiliates requesting comprehensive financial records related to certain accounts and individuals. The request includes documents such as checks, wire transfers, account statements, and identification records. The subpoena also seeks information on online banking activities and any correspondence related to the accounts.


document_description: Notes from a call with Matt Schwartz at BSF regarding a client negotiating to buy a helicopter owned by Hyperion Air LLC, a JE company. Concerns about forfeiture implications were discussed. The purchase price is $3.5 million, and the deal is likely to close by 11/15. Negotiations are with Darren Indyke. No action will be taken before hearing back from the Assistant United States Attorney's team.


document_description: Chris Dilorio discusses his allegations of SEC corruption and obstruction related to Knight Capital and other entities involved in money laundering and illegal naked shorting. He criticizes the SEC's handling of his whistleblower claims and the lack of investigation into his allegations.


document_description: Ghislaine Maxwell's legal team argues for the severance of perjury counts from Mann Act counts, claiming improper joinder and potential prejudice. The memorandum discusses the dissimilarity of the counts, the lack of logical connection, and the potential introduction of prejudicial evidence. It also addresses the implications of the advocate-witness rule and the potential impact on Maxwell's right to a fair trial.


document_description: Cohen & Gresser LLP, on behalf of Ghislaine Maxwell, filed multiple reply memoranda with exhibits in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (MN). The memoranda address various motions including dismissal of the superseding indictment, suppression of evidence, and requests for severance and a bill of particulars. Some memoranda contain redactions due to confidential information.


document_description: Ghislaine Maxwell's legal team argues for the suppression of evidence obtained through a government subpoena to Boies Schiller Flexner LLP, citing violations of the Fourth and Fifth Amendments and the Martindell principle. The memorandum challenges the government's standing, good faith, and inevitable discovery claims, and argues for Maxwell's reasonable expectation of privacy. It also addresses the government's alleged misconduct and lack of due process in modifying a protective order without notice to Maxwell.


document_description: Ghislaine Maxwell, through her attorneys, filed a motion to compel the plaintiff to disclose any ongoing criminal investigations related to her or to stay the proceedings. The motion argues that the plaintiff has claimed to be part of an investigation and has withheld documents under alleged privileges. Maxwell's counsel argues that the information is necessary for her defense and that the plaintiff's claims are unfounded. The motion requests the court to order the plaintiff to disclose the information or stay the proceedings.


document_description: Ghislaine Maxwell's legal team argues for the severance of perjury counts from Mann Act counts in her indictment, claiming improper joinder and potential prejudice. The memorandum outlines the dissimilarity between the counts, the lack of logical connection, and the potential for prejudicial evidence introduction. It also discusses the implications of the advocate-witness rule and the potential disqualification of Maxwell's counsel.


document_description: This document is a legal reply memorandum filed by Ghislaine Maxwell's attorneys in support of her motion to dismiss counts five and six of the superseding indictment. The memorandum argues that the alleged misstatements are not perjurious as a matter of law, citing various legal precedents and cases. It discusses the ambiguity and immateriality of the questions posed to Ms. Maxwell during depositions and argues that the questions were fundamentally ambiguous and the answers were literally true. The document also addresses the defamation action related to the Crime Victims' Rights Act (CVRA) and the involvement of media and public figures.


document_description: Ghislaine Maxwell's legal team opposes the plaintiff's motion to exceed the ten deposition limit, arguing that the request is premature and the proposed depositions are cumulative, duplicative, and irrelevant to the central issues of the defamation case. The response highlights that the plaintiff has not justified the need for additional depositions and that the information sought is not pertinent to the defamation claim against Maxwell.


document_description: The court denied the motions by Jane Doe 3 and Jane Doe 4 to join the case under Rule 21 and to amend the pleadings under Rule 15. The court found that justice does not require the amendment or joinder as the claims are duplicative and the addition of new parties would not materially advance the resolution of the litigation. The court also struck certain impertinent details from the record.


document_description: Notes from a meeting involving Brad Edwards and Stan Pottinger discussing the long history of litigation involving Jeffrey Epstein. The notes cover various aspects of Epstein's criminal activities, including his modus operandi, involvement of co-conspirators, and legal proceedings. It mentions the involvement of public figures and celebrities, as well as details about victims and potential evidence.


document_description: The document is a Non-Prosecution Agreement (NPA) involving Jeffrey Epstein, detailing the terms under which prosecution for certain offenses will be deferred. It outlines Epstein's obligations, including pleading guilty to charges in Florida, serving a specified sentence, and waiving certain legal rights. The agreement also includes provisions for compensating victims and conditions under which the United States may resume prosecution if Epstein violates the agreement. An addendum clarifies the role of an attorney representative for victims and Epstein's financial obligations towards them.


document_description: This document is a letter from Reid Weingarten of Steptoe & Johnson LLP to Judge Richard M. Berman, arguing for the pretrial release of Jeffrey Epstein. The letter outlines the conditions under which Epstein would be released, emphasizing his compliance with legal obligations and arguing against the presumption of danger or flight risk. It discusses Epstein's past legal issues, the nonprosecution agreement (NPA), and the legal grounds for his release. The letter also addresses the potential conditions for release, including home detention, electronic monitoring, and financial securities.


document_description: The document is a superseding indictment against Ghislaine Maxwell, detailing charges related to her involvement in the sexual exploitation and abuse of minor girls by Jeffrey Epstein. The indictment outlines multiple counts, including conspiracy to entice minors to travel for illegal sex acts, enticement of a minor, conspiracy to transport minors for criminal sexual activity, transportation of a minor, sex trafficking conspiracy, sex trafficking of a minor, and perjury. It describes Maxwell's role in recruiting, grooming, and facilitating the abuse of minors, as well as her efforts to conceal her conduct through false statements under oath.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to the Legal Department of the Metropolitan Detention Center, providing discovery materials for inmate Ghislaine Maxwell.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to the MDC Legal Department regarding the case United States v. Ghislaine Maxwell. It includes a password for a drive containing discovery materials.


document_description: The letter from the U.S. Attorney's Office for the Southern District of New York to defense counsel in the case of United States v. Ghislaine Maxwell outlines the production of discovery materials. It includes an index of financial records from Deutsche Bank, JPMorgan Chase, Citibank, UBS, and American Express related to Ghislaine Maxwell and Jeffrey Epstein. The letter also provides instructions for accessing various file types and reaffirms the government's ongoing discovery obligations.


document_description: The U.S. Attorney's Office for the Southern District of New York is producing discovery materials in the case United States v. Ghislaine Maxwell. The materials include financial records from Deutsche Bank, JPMorgan Chase, Citibank, UBS, and American Express related to Ghislaine Maxwell and Jeffrey Epstein. The letter outlines instructions for accessing various file types and reaffirms the government's ongoing discovery obligations.


document_description: The U.S. Department of Justice requests a one-week extension for submitting a status report in a FOIA case involving the New York Times and the Federal Bureau of Prisons related to Jeffrey Epstein. The extension is needed to review interviews conducted with defendants in a related case.


document_description: The Office of Professional Responsibility (OPR) Report of Investigation into the U.S. Attorney's Office for the Southern District of Florida's handling of the 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and its interactions with victims. The report is being shared with the United States Attorney's Office for the Southern District of New York due to its potential relevance to ongoing litigation. The Executive Summary is being publicly released, but the full report will only be provided to Congress upon request.


document_description: The court grants a short continuance of Ghislaine Maxwell's trial to fall 2021 due to the late filing of the S2 Superseding Indictment, which added new charges and a fourth alleged victim. The defense needs additional time to prepare. The court rejects requests for longer continuances and emphasizes the need for a timely trial considering the interests of justice and the public.


document_description: Incident report regarding Jeffrey Epstein's self-mutilation and suicide attempt on July 23, 2019. The report includes details about Epstein's status and pending disciplinary hearing for code 228 self-mutilation.


document_description: An interview conducted by the FBI with a victim who was involved with Jeffrey Epstein. The victim recounts her experience of being introduced to Epstein through a friend, being taken to his house, and being paid for a massage. She also mentions Ghislaine Maxwell's presence during the incident. The victim later filed a civil suit and got involved after reading about Epstein in the news.


document_description: Ghislaine Maxwell's legal team argues for the suppression of evidence obtained from a subpoena to Boies Schiller Flexner LLP, claiming violations of the Fourth and Fifth Amendments and the Martindell principle. The memorandum challenges the government's actions, asserting lack of standing, good faith, and inevitable discovery. It also highlights due process violations and requests an evidentiary hearing.


document_description: A scheduled call with the Southern District of New York (SDNY) to discuss discovery related to the Epstein investigation.


document_description: A search and seizure warrant issued by the United States District Court for the Southern District of New York, authorizing law enforcement to search a multi-story single-family residence at 9 East 71st Street, New York, NY. The warrant is related to violations of Title 18, United States Code, Sections 371 and 1591, concerning sex trafficking of minors and conspiracy. The warrant allows for the seizure of computer devices, storage media, and related items that may contain evidence of the offenses. The warrant is to be executed by July 12, 2019, and includes provisions for the search and seizure of electronically stored information.


document_description: The document contains a list of EFTA IDs ranging from EFTA00097681 to EFTA00097782. These appear to be reference numbers, possibly related to a legal or administrative process in the Southern District of New York.


document_description: The document is a superseding indictment against Ghislaine Maxwell, detailing charges related to her involvement in the sexual exploitation and abuse of minor girls by Jeffrey Epstein. It outlines Maxwell's role in recruiting, grooming, and facilitating the abuse of minors, as well as her efforts to conceal her conduct through false statements under oath. The indictment includes multiple counts, such as conspiracy to entice minors to travel for illegal sex acts, enticement of a minor, conspiracy to transport minors for criminal sexual activity, transportation of a minor, and perjury.


document_description: This document is an FBI report detailing an interview with Anthony Luis Zac Figueroa regarding his involvement with Jeffrey Epstein. Figueroa discusses his relationship with Epstein through his girlfriend, who worked as Epstein's personal assistant. He describes transporting females to Epstein's residence for massages, some of whom were recruited by Ghislaine Maxwell. Figueroa also mentions financial transactions and his eventual cessation of work for Epstein.


document_description: Notes from an interview or deposition with Anthony Figueroa, discussing his past interactions with Jeffrey Epstein (JE) and Ghislaine Maxwell (GM). Figueroa mentions being asked to recruit girls for massages, his relationship with a woman connected to JE, and financial transactions involving JE. He also describes his living situation and interactions with GM and JE.


document_description: The U.S. Department of Justice, Southern District of New York, discloses notes and 302s related to the case United States v. Ghislaine Maxwell, designating them as 'Confidential' under the Protective Order.


document_description: Anthony Figueroa was interviewed regarding his past interactions with Jeffrey Epstein and Ghislaine Maxwell. He discussed his recruitment of girls for Epstein, his relationship with a woman who worked for Epstein, and his limited interactions with Maxwell. Figueroa also mentioned Epstein's financial support and his own recruitment activities.


document_description: An individual was interviewed in West Palm Beach, Florida, regarding a federal investigation involving Jeffrey Epstein and the sexual exploitation of minors. The interviewee described their relationship with Epstein, including living arrangements, financial transactions, and involvement in recruiting females for Epstein. The interviewee also mentioned interactions with Ghislaine Maxwell and described Epstein's instructions regarding the age of females brought to him.


document_description: An individual was interviewed via video conference regarding their past interactions with Jeffrey Epstein and Ghislaine Maxwell. The interviewee discussed their previous deposition by Brad Edwards, their knowledge of Epstein's activities, and their involvement in recruiting girls for Epstein. They also mentioned interactions with Maxwell and Epstein, including travel and financial arrangements.


document_description: This document is a response from Jeffrey S. Pagliuca, representing Ghislaine Maxwell, addressing the Government's failure to produce discovery materials in a timely and accessible manner. It highlights issues with the Government's handling of discovery, including delays, incomplete and unreadable documents, and lack of exculpatory evidence. The response criticizes the Government's redefinition of its discovery obligations and the impact on Maxwell's ability to prepare her defense. It also addresses logistical issues faced by Maxwell in reviewing discovery materials while detained.


document_description: The document contains notes related to an individual who was involved with Jeffrey Epstein (JE) and Ghislaine Maxwell (GM). It includes personal background information, interactions with JE and GM, and involvement in recruiting girls for massages. The individual mentions being paid by JE, interactions with GM, and receiving calls from JE. There are references to other people involved, including a friend who passed away and a girl who went to Thailand. The notes also mention media inquiries and fact-checking for a book.


document_description: A list of EFTA IDs from the Southern District of New York.


document_description: A search and seizure warrant issued by the United States District Court for the Southern District of New York for electronic devices belonging to Jeffrey Epstein. The warrant covers devices seized from Epstein's person, his New York residence, and his private island in the Virgin Islands. The warrant is related to violations of 18 U.S.C. 1591, 18 U.S.C. 2422, 18 USC 2423, and 18 U.S.C. 371, concerning sex trafficking and related offenses. The warrant authorizes the search for evidence of these offenses, including communications, financial records, and photographs.


document_description: This letter from Bobbi C. Sternheim to Judge Nathan addresses ongoing interference with attorney-client communication between Ghislaine Maxwell and her counsel at the MDC. It details issues with the VTC platform being changed from WebEx to Zoom, breaches of confidentiality, and restrictions on legal document sharing, all of which are impacting Maxwell's ability to prepare for trial.


document_description: This letter from Bobbi C. Sternheim to Judge Nathan addresses ongoing interference with attorney-client communication between Ghislaine Maxwell and her counsel at the MDC. It details issues with the VTC platform being changed from WebEx to Zoom, breaches of confidentiality, and restrictions on legal document sharing, impacting Maxwell's trial preparation.


document_description: Notification of new office address and preferred email address for Bobbi C. Sternheim, Esq. The message includes a confidentiality notice.


document_description: The memo discusses the expected delivery of the Maxwell memo by the end of the week, incorporating the Farmer interview. It also updates on the estate's steps to sell illiquid assets to meet a tax deadline, and the IRS's refusal to delay tax enforcement. The team did not engage with the trustees' counsel on maintaining forfeiture interest.


document_description: An FBI report detailing an interview with a Lieutenant at the Metropolitan Correctional Center (MCC) regarding the circumstances surrounding Jeffrey Epstein's death. The report covers the Lieutenant's responsibilities, the hierarchy within MCC, and the procedures for inmate checks and counts. It also describes the events on the morning of Epstein's death, including the failure to conduct required rounds and the discovery of Epstein's body. The report notes discrepancies in the documentation of rounds and inmate movements, and mentions the absence of a cellmate for Epstein, which was against policy.


document_description: A subpoena issued by the United States District Court for the Southern District of New York, commanding Amazon.com, Inc. to appear and produce records related to the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).


document_description: A memo discussing an ex parte order issued by Judge Karas directing the disclosure of documents to Government firewall counsel upon the request of all defense counsels. The memo also notes that Mr. Barket has until May 5, 2020, to file any additional response, and that the upcoming hearing will be rescheduled.


document_description: This document contains a series of email exchanges among members of the US Attorney's Office for the Southern District of New York (USANYS) regarding Touhy requests related to Jeffrey Epstein. The emails discuss the handling of requests for documents and information, the involvement of other districts like SDFla and NDGA, and the legal considerations under the Touhy regulations. The emails also mention coordination with the Maxwell team and responses to requests from Epstein victims.


document_description: A court subpoena issued by the United States District Court for the Southern District of New York, commanding appearance and testimony in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). The subpoena requires the production of subscriber records for certain phone numbers between 2000-2005.


document_description: A court subpoena commanding appearance and evidence production in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), at 40 Foley Square, Courtroom 906, on November 29, 2021, at 9:00 a.m. The subpoena demands testimony and documents related to Jeffrey E Epstein's account 0043811863 for the billing cycle ending May 2, 2004.


document_description: A court subpoena commanding appearance and evidence production in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), at 40 Foley Square, Courtroom 906, on November 29, 2021, at 9:00 a.m. The subpoena demands documents related to Jeffrey E Epstein's account 0043811863 from January 1, 2001, through December 31, 2004.


document_description: This document is an AT&T Wireless invoice for Jeffrey E Epstein, detailing the charges for the billing cycle ending on May 02, 2004. The total amount due is $403.56, which includes monthly service charges, usage charges, and taxes. The document provides a detailed breakdown of voice usage, roaming charges, and data usage.


document_description: Brian Faulkner, a Legal Compliance Analyst at AT&T, declares under penalty of perjury that after a thorough search, no information responsive to the request was found.


document_description: Declaration by Brian Faulkner, Legal Compliance Analyst at AT&T, stating that no information was found responsive to a request after a thorough search of records.


document_description: The court orders David Markus to comply with Local Criminal Rule 23.1 following an op-ed he authored about the Ghislaine Maxwell case. Markus, associated with the defense, argued he is not subject to the rule as he does not currently represent Maxwell in any proceedings. The court clarifies that the rule applies to lawyers associated with pending criminal litigation, regardless of formal appearance. Markus is ordered to comply with the rule to avoid prejudicing the trial. The court does not discipline Markus but emphasizes the importance of compliance to ensure a fair trial.


document_description: The letter provides additional information in response to the Court's inquiry about the Government's plan to review investigative files related to the case against Ghislaine Maxwell. It outlines the Government's approach to reviewing files from other agencies, particularly those from the Florida Investigation into Jeffrey Epstein, and details the Government's ongoing efforts to meet its disclosure obligations under Rule 16, Brady, and Giglio.


document_description: This document is a bank account application for Jeffrey Epstein with JPMorgan Private Bank. It details the account type, primary accountholder information, and various account options and agreements. The application includes sections on account linking, check and card delivery, and tax information. It also contains signature fields for Jeffrey Epstein, Ghislaine Maxwell, and Harry Belik.


document_description: The document appears to be a set of notes or a memo discussing various topics including employment, housing, and financial matters. It mentions someone trying to justify their actions, a person named Lakewone trying to help, and a situation involving money in a desk drawer. There is also a mention of photographs of girls in a house and debts recorded in books.


document_description: This document is a witness log from a Crimes Against Children Investigation related to Jeffrey Epstein. It details the proceedings of a court session on July 19, 2006, including witness testimonies, direct and cross-examinations, and jury questions. The document includes references to various individuals, some redacted, and mentions of illegal activities involving minors. Jeffrey Epstein is a key figure mentioned throughout the document.


document_description: This document is a bank statement for Ghislaine Maxwell's JPMorgan Private Bank account for the period of June 1, 2007, to June 29, 2007. It details the transactions, including deposits, checks paid, and electronic funds transfers. The statement shows an opening balance of $149,704.20 and an ending balance of $121,241.53. Notable transactions include a $7,400,000 credit from Jeffrey Epstein and various checks paid to entities such as the United States Treasury and NYS Income Tax.


document_description: The memo contains questions and discussions about handling various PDF documents related to a legal case. It includes considerations for redacting certain information, organizing documents in folders, and handling victim files. The memo is from an Assistant United States Attorney in the Southern District of New York.


document_description: The U.S. Department of Justice, Southern District of New York, issued a letter to defense counsel regarding the production of discovery materials in the case United States v. Ghislaine Maxwell. The letter details the provision of a hard drive and CD containing confidential materials, governed by a protective order. It includes an index of the materials and a chart of devices searched under warrants, with production dates for responsive materials.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell at MDC Brooklyn, regarding the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). The letter includes a password for discovery materials, with most content redacted.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell, enclosing discovery materials related to her case.


document_description: Notes and thoughts from a jury exercise related to the Jeffrey Epstein case, including observations from deliberation and a Q&A session. The document discusses jurors' perceptions of witness credibility, the role of Ghislaine Maxwell, and the impact of various pieces of evidence on the jury's views.


document_description: The New York Times Company filed a complaint against the Federal Bureau of Prisons under the Freedom of Information Act (FOIA) to obtain records related to Jeffrey Epstein's incarceration and death at the Metropolitan Correctional Center. The complaint alleges that the BOP failed to meet FOIA deadlines and improperly withheld records. The Times seeks an order compelling the BOP to release the requested documents.


document_description: An interview with INMATE 2 at the Metropolitan Correctional Center regarding the events surrounding Jeffrey Epstein's death. INMATE 2 described the actions of a guard who found Epstein unresponsive and attempted resuscitation. The report details the sequence of events and observations made by INMATE 2, including the presence of a female guard, a lieutenant, and a male nurse. INMATE 2 noted that Epstein did not have marks around his neck and described the handling of Epstein's body and the scene by MCC personnel.


document_description: This document contains observations and statements from an inmate regarding the night of Jeffrey Epstein's death. It includes details about the inmate's location, observations of the cell area, and interactions with guards and Epstein. The document also describes the attempts to revive Epstein and the scene in the cell after his death.


document_description: The document details the investigation by the United States Attorney's Office for the Southern District of New York into the events at the Metropolitan Correctional Center on August 9-10, 2019, when Jeffrey Epstein committed suicide. It highlights the failure of prison officers Michael Thomas and Tova Noel to conduct required counts and rounds, their falsification of records, and the lack of a cellmate for Epstein contrary to policy.


document_description: Notes from an inmate regarding their time in the SHU, observations about guard behavior, and reactions to Jeffrey Epstein's death. The inmate describes the routine in the SHU, including rounds and counts, and mentions contraband issues. They also note hearing about Epstein's death from the news and discuss the guards' actions that night.


document_description: The document is a report of a meeting with an inmate on 9/13/14, discussing contraband activities within the facility. It mentions an inmate named Chris Rene caught with contraband items like phones and cigarettes. The report details how contraband is smuggled into the facility, including using sanitation workers and a town driver with a gate pass. It also mentions payment methods for contraband, such as Western Union and Cash App. The document includes references to other inmates and officers but lacks specific details about their involvement.


document_description: FBI interview with INMATE 3 at MCC regarding Jeffrey Epstein's activities and housing prior to his death.


document_description: Notes from an inmate detailing conditions and events in the prison, including officer behavior, inmate treatment, and the night of Jeffrey Epstein's death. The notes describe irregularities in officer rounds, inmate interactions, and specific incidents involving officers Noel and others. The document also mentions the aftermath of Epstein's death and the behavior of officers and inmates.


document_description: An interview conducted by FBI agents with INMATE 4 at the Metropolitan Correctional Center regarding the events surrounding Jeffrey Epstein's last night. INMATE 4 provided details about the guards on duty, the last time he saw Epstein, and his observations of the night Epstein was found unresponsive.


document_description: The document discusses significant developments in the investigation of Jeffrey Epstein, focusing on allegations of sexual abuse of minors and the involvement of co-conspirators. It mentions the 2008 Non-Prosecution Agreement and ongoing efforts to identify victims and gather information from the original investigation.


document_description: The court is planning logistics for the trial of Ghislaine Maxwell and requires the parties to estimate the length of the trial. Jury selection will be complete by November 19, and opening statements will occur on November 29. The court requests an estimate of when jury deliberations will begin to assess if the trial may continue after the Christmas holiday.


document_description: The document contains a series of faxes detailing work hours and tasks performed by employees related to Jeffrey Epstein's properties. It includes specific dates, hours worked, tasks such as house sitting, cleaning, and coordinating with various service providers. Payments are calculated based on hours worked at a rate of $20 per hour. The document also includes instructions for mailing checks and mentions interactions with Ghislaine Maxwell.


document_description: The letter addresses the request for spreadsheets containing links to photo files on hard drives reviewed at the FBI office in Denver. The government cannot provide copies with embedded photographs due to child exploitation content but provides a version without photos. The materials are governed by a Protective Order and marked as confidential.


document_description: The letter addresses the request for spreadsheets on hard drives reviewed at the FBI office in Denver. The government cannot provide copies with embedded photographs due to child exploitation materials. A version without photographs is provided, marked with control numbers SDNY GM 02765031 through SDNY GM 02765061. The letter and materials are governed by a Protective Order and marked as confidential.


document_description: The court orders the Government to respond to the Defendant's letter regarding the deadline for filing a motion under Federal Rule of Evidence 412 by 5:00 p.m. on October 15, 2021.


document_description: The Co-Executors of Jeffrey E. Epstein's estate filed a motion for an expedited order to establish a voluntary claims resolution program to address sexual abuse claims against Epstein. The program aims to provide a confidential, non-adversarial alternative to litigation, designed by independent claims administration experts. The motion outlines the proposed mechanics, administration, and the credentials of the program designers, seeking the court's authorization to proceed with the program's development.


document_description: Proffer session related to the Epstein investigation scheduled on September 9, 2019, from 17:30 to 18:30 at 1 St. Andrews - 303.


document_description: A Grand Jury Subpoena issued to S. Shakir by the United States District Court for the Southern District of New York, commanding appearance and testimony regarding alleged violations of 18 U.S.C. §§ 371, 1001, 1519. The subpoena requires the production of materials related to Jeffrey Epstein.


document_description: A memo from the Metropolitan Correctional Center in New York regarding inmate movements and cell arrangements. It mentions Inmate Reyes and Inmate Epstein, with specific instructions about their status and needs.


document_description: The court has set November 29, 2021, as the trial start date for Ghislaine Maxwell, with jury selection to occur during the week of November 15. The court grants the Government's motion to exclude time until November 29, 2021, under the Speedy Trial Act. The parties are ordered to meet and confer on pretrial disclosures and submit a joint letter by May 14, 2021.


document_description: Bruce A. Green clarifies his role in relation to the Epstein case, stating he has never been counsel to Epstein or his estate. He served as an expert witness in a related defamation case involving Professor Dershowitz.


document_description: Judge Richard M. Berman addresses Professor Bruce A. Green regarding his role as an expert on legal ethics in the Dershowitz case following the public hearing in US v. Epstein. The letter discusses the non-disclosure of Green's advocacy for David Boies' disqualification and comments on transparency in criminal cases.


document_description: The document contains a list of EFTA IDs ranging from EFTA00098172 to EFTA00098304. These IDs are likely used for tracking or referencing specific documents or items within a larger dataset or system.


document_description: A letter from the U.S. Attorney's Office for the Southern District of New York to the Legal Department of the Metropolitan Detention Center, regarding discovery materials for inmate Ghislaine Maxwell.


document_description: A letter from the United States Attorney for the Southern District of New York to the Legal Department of the Metropolitan Detention Center regarding discovery materials for Ghislaine Maxwell's case.


document_description: A list of person encounters recorded by U.S. Customs and Border Protection, detailing various flights and passenger statuses from 1997 to 2016. The document includes information such as document type, document number, date-time, carrier code, carrier number, status, arrival and departure locations.


document_description: A letter from the School District of Palm Beach County, Florida, regarding the release of student records in response to a subpoena or records request.


document_description: Event related to the court case United States v. Ghislaine Maxwell.


document_description: This document is the trust agreement for the Jeffrey E. Epstein 2019 Trust, detailing the terms and conditions under which the trust is to be administered. It includes provisions for disbursement of income and principal during Epstein's lifetime, specific rights reserved by Epstein, and instructions for the distribution of assets after his death. The document also outlines the roles and responsibilities of the trustees, Darren K. Indyke and Richard D. Kahn, and includes various bequests and conditions for beneficiaries.


document_description: This document is a series of emails from whistleblower Christopher J Dilorio to various SEC officials, detailing allegations of SEC corruption and obstruction in handling his whistleblower claims related to Knight Capital and other entities. Dilorio accuses the SEC of using his information to both bring and obstruct complaints, denying him rightful compensation. He highlights issues of naked shorting, money laundering, and SEC's failure to investigate thoroughly. The emails also mention various financial entities and individuals involved in alleged fraudulent activities.