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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
S2 20 Cr. 330 (AJN)
UNITED STATES OF AMERICA
v.
GHISLAINE MAXWELL,
Defendant.
x
MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SU
HADDON
M OR C A N
FOREMAN
November 8, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
I St. Andrew's Plaza
New York, NY 10007
Haddon, Morgan and Foreman, P.0
Jef
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 1 of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833(PAE)
v.
FEDERAL BU
Case 1:20-cv-00833-PAE Document 21 Filed 08/05/20 Page 1 of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833(PAE)
v.
FEDERAL BU
From:
To:
(USANYS) [Contractor]"
Cc:
Subject: Fwd: STATEMENT ON DOJ OFFICE OF PROFESSIONAL RESPONSIBILITY REPORT ON
JEFFREY EPSTEIN 2006-2008 INVESTIGATION
Date: Thu, 12 Nov 2020 18:59:52 +0000
U.S. Department of Justice
United States Attorney
Southern District of New York
The Sihlo J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 23, 2021
BY ECF
The Honorabl
Case 1:20-cr-00330-AJN
Document 214 Filed 04/19/21 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America,
—v—
Ghislaine Maxwell,
Defendant.
USDC SDNY
From:
To: ac
Caro a
Cc
Subject: Judge Nathan Order
Date: Wed, 21 Apr 2021 15:45:22 +0000
Attachments: 2020.07.23_Order re_Local_Rule_23.1.pdf; SDNY_Local_Rules.pdf
Hi Jack,
Because the United
From: Jack Scarola
To: '
Cc:
)"
(USANYS)"
>, fl
>, Michael Danchuk
Subject: Re: United States v. Ghislaine Maxwell
Date: Mon, 19 Apr 2021 16:33:18 +0000
will not attend the scheduled conference,
Case 1:20-cr-00330-AJN
Document 214 Filed 04/19/21 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America,
—v—
Ghislaine Maxwell,
Defendant.
USDC SDNY
Case 1:19-cr-00490-RMB Document 32 Filed
19 1 o4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
- against -
JEFFREY EPSTEIN,
Government,
Defendant.
—x
•
LIST OF EXHIBITS - INTRODUCTION
1. Predicating information.
2. Office of Chief Medical Examiner, City of New York, Autopsy Report, dated August 11, 2019,
regarding the autopsy of Jeffrey Epstein.
U.S. Department of Justice
Federal Bureau of Prisons
Progam
Sea
OPI: CPD/CPB
NUMBER: P5264.08
DATE: 1/24/2008
SUBJECT: Inmate Telephone
Regulations
"CORRECTED COPY 2/11/2008"
Boxed Bold - Fe
go
U.S. Department of Justice
Federal Bureau of Prisons
PROGRAM STATEMENT
OPI:
OGC/ELE
NUMBER:
3420.11
DATE:
12/6/2013
Standards of Employee Conduct
Is/
Approved: Charles E. Samuels, Jr.
D
LIST OF EXHIBITS - CHAPTER 2
1. Federal Bureau of Prisons (BOP) Psychological Reconstruction dated September 17, 2019,
regarding inmate Jeffrey Epstein (previously exhibited in Introduction).
2. In
BUSINESS RECORD CERTIFICATION OF APPLE INC. CUSTODIAN OF
RECORDS
I, Lesley Ahlberg, hereby declare:
1.
I am employed by Apple Inc. and that my official title is Legal Specialist. I am a
duly auth
1
XJ49HGJS
SEALED - DO NOT DOCKET
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
In Re
To Be Filed Under Seal
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
IN RE GRAND JURY SUBPOENA
x
C
19 Misc. 149 (CM)
SEALED MEMORANDUM DECISION AND ORDER GRANTING
THE GOVERNMENT'S
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mono Building
One Saint Andrew's Plaza
New York. New York 10007
February 28, 2019
TO BE FILED UNDER
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
IN RE APPLICATION TO UNSEAL CIVIL : SEALED AFFIRMATION AND
DISCOVERY MATERIALS,
APPLICATION
USAO Reference No. 2018R01618.
X
ALEX
AO 93C (0VISISDNY Rev. Warrant by Telephone or Other Reliable Electronic Means
O Original
O Duplicate Original
UNITED STATES DISTRICT COURT
In the Matter of the Search of
(Briefly describe the pr
AO93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
AO 93 (SONY Rev. 01117) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
In the Matter of the Search of
(Briefly describe the property to be searched
or ident6 the person by name and address)
Six binders with various CDs
AO 93 (SONY Rev 0 In 7) Scazch and Seizure Warra
AO 91 (Rev. I I/B) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
District of Virgin Islands
In the Matter of the Search of
(Briefly describe the property to be searched
or iden
AO 93 (SDNY Rev. 01 /17) Seareh end Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Sri* describe the property to be searched
o
AO 93 (SDNY Rev. 01/17) Starch and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
1 9MAG 6 39
(Briefly describe the property to
AO 93 (SONY Rev. 01117) Search and Seizure Warrant
ORIGINAL
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be
U.S. Department of Justice
United States Attorney
Southern District of New York
Prosecution Memorandum
Privileged and Confidential - Attorney Work Product
Do Not Disseminate Outside of the SDNY U
PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS
CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e)
MEMORANDUM
TO:
Geoffre S. Berman. U.S. Attorne
FROM:
AUSAs
DATE:
RE:
December 5, 2019
RON WAVY OREGON. (MAIRMAN
DEW STARENDLY.NIONGAPI
MIKE CRAP°. IDAHO
MARIA CANTWELL WASHINGTON
MUCK GRASSIER. IOWA
ROBERT MENTNITRZ RIEW ARMY
ANN comenE TEXAS
DE IMAMIN L. CAR IN. MPAYLANO
SHERK
EX-99.1 2 d118102dex991.htm EX-99.1
Exhibit 99.1
DecheLLPrt
MEMORANDUM
DATE
January 22, 2021
TO
Apollo Conflicts Committee
FROM
Dechen LLP
RE
Investigation Of Epstein/Black Relationship And
probation. Mandatory probation; solicitation is one of the few statues that has such
a designation. The local police chief, however, met this charge with great disdain.
He believed something untoward
The AUSA decided that she would protect the young women of Palm Beach. She saw
a need for child safety everywhere she looked. She has been chastised twice by local
judges for hiding information from a
Palm Beach Police Chief Michael Reiter is reported to say: “This is
bigger than Rush Limbaugh,” who, in a storm of publicity, has just been
arrested in Palm Beach for possession of controlled drugs.
38.
39.
40.
41.
42.
43.
44.
Yugoslavia when she was about fifteen. said that Mr. Epstein would take naked
photographs of her and other girls and display the photographs in the house.
In a lett
45. In May 2009, EEEESued Mr. Epstein, as Jane Doe No. 3. In her complaint, Zz
| stated that she had been sexually abused by Mr. Epstein and also was “required to
be sexually exploited by Mr. Epstein’
16.
17,
18.
19,
exploited by not only Epstein but also Epstein’s “adult male peers, including royalty,
politicians, academicians, businessmen, and/or other professional and personal
acquaintances”
‘present during acts of sexual abuse by Epstein. In any event, ALL of thase individuals have also invoked
- their 5" amendment rights against self-incrimination, and thus have left Plaintiff with-no
1. lam an attomey in good standing with the Florida Bar and admitted to practice in the
Southern District of Florida. 1am currently a partner in the law firm of Farmer, Jaffe,
Weissing, Edwards, Fisto
aa a Doe any substantive testimony re lated her. allegations.
7 AFFIDAVIT OF BRADLEY JAMES EDWARDS
L- 4 am. an n attorney in good standing with the Florida Bar and admitted to. practice i in the
- S
From: J [[email protected]]
Sent: 2/5/2019 5:44:43 PM
To: jeffrey epstein [[email protected]]
Importance: — High
https://www.vox.com/2019/2/5/18211600/trump-inauguration-investigation-subpoe
From:
Sent: 11/29/2018 3:57:47 AM
To: [email protected]
Subject: Shared Article from AOL: Report: Trump aide helped sex abuser get cushy plea deal
Importance: — High
They try to keep this story
22
be, it is unclear that the newcomers would follow the Assads'
cautious-use doctrine and refusal to share chemical weapons with non-
state groups, or that the new leaders would be able to maintain
From: ee
Sent: 2/7/2019 3:36:37 AM
To: [email protected]
Subject: From Fox News - DOJ to investigate plea bargain awarded to Clinton-linked sex offender Jeffrey Epstein, but
watchdogs say probe
From: J [[email protected]]
Sent: 11/29/2018 3:59:27 AM
To: David Schoen as
Subject: Re: Shared Article from AOL: Report: Trump aide helped sex abuser get cushy plea deal
yes, every outlet needs
A Justice Department spokeswoman declined to comment. Christopher Clark, an attorney
for Broidy, declined to comment.
Broidy’s alleged activities were detailed in news reports earlier this year that
IT'S HAPPENING: Trump Insider TURNS On Trump, Asks For Plea Deal to Expose Trump.
But these new leaks fly in the face of all this. They suggest that Pence knew about all of Flynn’s dealingswith forei
COVINGTON
The Honorable Richard Burr
The Honorable Mark R. Warner
May 22, 2017
Page 5
the existence of any particular responsive documents. See United States v. Doe, 465 U.S. 605,
613 n.12 (1984) (
COVINGTON
The Honorable Richard Burr
The Honorable Mark R. Warner
May 22, 2017
Page 3
A. If the government fails to demonstrate prior knowledge of requested
subpoenaed documents, the act of produci