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EFTA00005718.pdf
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EFTA00005718
EFTA00005719
EFTA00005720
EFTA00005721
EFTA00005722
EFTA00005723
EFTA00005724
EFTA00005725
EFTA00005726
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvia I. Motto Building
One Saint Andrew's Plaza
Yew York, New York 10007
July 5, 2019
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in connection with
an official criminal investigation of a suspected felony being conducted by a federal grand jury. The
Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to
any third party. While you are under no obligation to comply with our request, we are requesting you not
to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure
of the existence of this investigation might interfere with and impede the investigation.
Moreover, if you intend to disclose the existence of this subpoena to a third party, please let me
know before making any such disclosure.
Thank you for your cooperation in this matter.
By:
Very truly yours,
GEO
Y S. BERMAN
Assistant United States Attorneys
EFTA00005727
Grand Jury Subpoena
Pnitetratatez Pis-frith arturt
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
July 24, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of:
18 U.S.C. §§ 1591, 2421, 2422, 2423, 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
See attached Advice of Rights
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED:
New York, New York
July 5, 2019
GEOFFREY S. BalifAN
the
ork
Assistant United tates Attorneys
One St. Andrew's Plaza
New York, New York 10007
Telephone:
rev. 02.01.12
EFTA00005728
Advice of Rights
1. You may refuse to answer any question if a truthful answer to the question would tend to
incriminate you.
2. Anything that you do say may be used against you by the grand jury or in a subsequent legal
proceeding.
3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the
grand jury room to consult with your lawyer if you so desire.
4. If you would like a lawyer but do not have funds to retain one, you may make an application to
the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you.
EFTA00005729
1 o I
https://www.ejustice.ny.gov/wps/PA_DMVPhotoService/FetchlmageServlet?imageId=4790... 6/5/2019
EFTA00005730
|
EFTA00007086.pdf
|
Pursuant to a federal investi•ation regarding the
sexual exploitation of m'.•
a victim, was
interviewed by the FBI.
i•en z yang information ;is
xecorded below:
Name:
Race:
Sex:
DOB:
Husband:
Home Address:
Cellular Telephone:
Cellular Telephone:
Work:
Female
Loxahatchee, Florida 33470
aMihusband)
EFTA00007086
|
EFTA00007606.pdf
|
EFTA00007606
amazon.com.
Billing Address:
Jeffrey Epstein
358 El Brillo Way
Palm Beach, Florida 33480
USA
Amazon.coni
amazon.com. 1850 Mercer Rd.
Lexington, KY 40511
Jeffrey Epstein
358 El Brillo Way
Palm Beach, Honda 33480
USA
Ai
rbrd57708/-3-/next/ 2436223 SOR1ExtFastTrae:
Your order of September 4, 2005 (Order ID 103-1737520-450864W
Qty.
Wm
IN THIS SHIPMENT
SM 101: A Realistic Introduction
Wiseman, Jay --- Paperback
f" C-2 "I 0963976389
•
Shipping Address:
Jeffrey Epstein
358 El Brill° Way
Palm Beach, Florida 33480
USA
1
SlaveCraft: Roadmaps for Erotic Servitude--Principles, Skills and Tools
Baldwin, Guy --- Paperback
I" C-2 "/ 1881943143
Training With Miss Abernathy: A Workbook for Erotic Slaves and Their
Owners
Abernathy. Christina --- Paperback
l" C-2 01
1890159077
Item Price
Subtotal
Shipping & I kindling
Order Total
Paid via Amex
Balance due
This shipment •ompletes your order.
Total
http://www.enanen.com
Your Account
For detailed information about this and other orders, please visit
Your Account. You can also print invoices, change your e-mail
address and payment settings, alter your communicatioc
preferences, and much more - 24 hours a day - at
http://www.amazon.com/your-accoun.
Returns Ale Easy!
Visit http://www.amaion.com/retums to return any item -
including gifts - in unopened or original condition within 30
days for a full refund (other restrictions apply). Please have
your order ID ready.
$16.47
$16.47
$15.95
$15.95
I Thanks for shopping at Arnazon.corr, and ple,.se
come again!
$11.95
$11.95
$4437
$24.46
$68.83
$68.83
$0.00 I I .
amazop.co
o'edm:
rbrdi77Rt;
SOR 1 I. x F.t.t 1 ra k/next/2436223/0912-19:30/0911-19,15/mreed Box or Pad: (71.1.B I2X9X2
III III1111111111
IIIIIIIIIIIIIIIIIIIII III
EFTA00007607
FcdEx l Ship Manager l Label
Page 1 of I
From
Origin C'
JEFFREY E. EPSIEIN
4111 FLOOR
NEWYORK. NY 10022
Jeffrey,.
358 El Brillo Way
Palm Beach, FL 33480
E
ELL SENDER
Shio Date 1gggpos
Actual WO 2 LB
Syskiinti It I3e640NEy2200
Account', S .........
REF. mal ll
lit [lilt llll II' I
Oo fiery Ad es Ea Coce Hil 111111
PRIORITY OVERNIGHT
IRO
3348O
-FL-US
RES
I 'SW
)20 I
TUE
Deliver By
20SEP05
FLL
AA
XH LNAA
Shipping Label: Your shipment Is complete
1. Use the 'Print' feature from your browser to send tnis page to your laser or inkjet printer.
2. Fold the printed page along the horizontal line
3. Place label in shipping pouch and affx it to your shipment so that the tarcode portion of the Inset Can be read and scanned.
Warning: Use only the printed original label for shipping. Using a photocopy of this label for shipping purposes is fraudulent
and could result in additional billing charges, along with the cancellation of your FedEx account number.
Use of this system constitutes yow agreement to the service cc ndrOns in the current FecEx Service Guide available on leder corn FedEx will rot
be responsible for any claim it excess of St 00 per package. whether the result of loss, damage, delay. non-delvery.rosdelivery, or misirformabon.
unless you decare a hgher value. pay ar additional charge. document your actual loss and Ile a timely claim. Linstaticns turd in Me cuTent Feats
Service Gude apply. Your right to reCOve- from FedEx for any loss. including intrirsic value or the package. loss of sates. income .ntarest profit.
attorney's fees, costs. and other forms of damage whetter direct. incidental, consequential, or special is limited to tie greater of $100 or Me
authorized declared value. Recovery cannot exceed actual documented loss. maximum for Items of extraordinary value is 550), e g. Jewelry.
predous metals, negotable instrumerts and other items listed in our Service Guide Written claims must be filed within strict time knits. see current
redEx Servos Guide.
littps://www.fedex.corrilegi-bthishiP_Wunity/31iUv5FiRx0kUq2BcRw0HbQr4AgXt6laUr... 9/19/2005
EFTA00007608
|
EFTA00007609.pdf
|
EFTA00007609
Alberto,
I received your short letter with great disappointment. Unfortunately, today, I cannot
accept your "resignation". I'm sorry. but it is not that simple to abandon a "family member", no
matter how frustrating or good-looking he may be.
If my appreciation for both you and your talent has not been adequately expressed as you
and I have not spoken directly, I apologize.
I am sure you have forgotten, but you had initially assured me that the island project
would be done for last Christmas. I have Sways been both gracious and generous in forgiving
the dates that have slipped by. You and I here. I theta a unique understanding.
Jean, who amend se the project would be complete,by the end of July, when in fact, for
example, till this dg dal ate still woodso picking asses far tide tables in the living room, has
yet to contact me. Emus swig opposed to rive, but evenintil today, I have not been told
what and %teethe:pat Ike Seth
Alberto, it is your right to take on only jobs you want. It is both unfair, unfriendly and
unprofessint to simply leave a job undone in the middle. This is not your way. I don't believe
that you would treat a less friendly client with the same disregard.
I would hope that you will reconsider the big house Island project. As you know, we
have bought many things for the interior and have incurred great expense to get permits and
drawings in a Moroccan style, but if you choose not to move forward, I think at a minimum, my
house should not be left in the state of disrepair in which it currently sits and should be brought
to completion as soon as possible. If Jean, who I have great respect for, does not want to
complete it as I believe he is only an employee and as I have my total relationship not with Jean,
but with Cabinet Pinto, the obligation falls on you personally. This is only right, you know it is.
As you are aware, I was told repeatedly that you would call me upon return from your vacation
and both visit and finish the project. You and I have more of a friendship than my receiving, in a
EFTA00007610
frankly impolite way, only a letter and not even the phone call I was repeatedly promised.
(However, I Sow you don't like tension) Please call me at your earliest convenience.
I tail your friend
EFTA00007611
|
EFTA00007680.pdf
|
ITEM
WAS NOT
SCANNED
DESCRIPTION
EFTA00007680
I
EFTA00007681
|
EFTA00006487.pdf
| null |
EFTA00005714.pdf
|
Precedence: ROUTINE
Date: 03/22/2011
To:
Criminal Investigative
Attn:
Violent Crime Section
CAC Unit
International Operations
Attn:
Asia Unit
Miami
Attn:
Squad PB-2
From: Canberra
Sydney Sub Office
Contact:
Approved By:
Drafted By:
Case ID ii: 31E-MM-108062
(Pending)
Title: JEFFREY EPSTEIN;
GHISLAINE MAXWELL;
WSTA - CHILD PROSTITUTION
Synopsis: To document liaison and investigation in Australia
and to cover lead set in referenced serial.
Reference: 31E-MM-108062 Serial 235
Details: On 03/12/2011 in referenced serial, Miami provided
an overview of captioned matter and advised
(PROTECT IDENTITY), a victim of captioned subjects, currently
resides in Australia. On 03/04/2011,
had contacted
the United States Attorney's Office in West Palm Beach,
Florida to express willingness to provide information
pertinent to captioned matter.
An interview of
was subsequently arranged to
occur at the U.S. Consulate in Sydney, Australia. Miami
conducted coordination for
and
1111
to travel to Sydney to conduct the interview of
Miami set a lead in referenced serial for Canberra
EFTA00005714
to facilitate the interview of
in Australia.
On 03/14/2011, Canberra developed a letter to the
Australian Federal Police (AFP) advising of an FBI interview
of
to take place at the U.S. Consulate in Sydney,
Australia on 03/17/2011. The writer contacted
, Coordinator, AFP International Network
Coordination and Support Team, via telephone and confirmed AFP
awareness and concurrence for this interview.
On 03/16/2011, Sydney Sub-Office personnel briefed
and
on logistical arrangements made for
the interview of
On 03/17/2011,
and II
conducted the interview of
at the U.S.
Consulate, Sydney. Following the interview,
advised the writer
had photos at her residence which
could be pertinent to captioned matter.
was willing
to be further interviewed at her residence and provide the
photos.
On 03/17/2011, the writer telephonically contacted
regarding FBI agents conducting a further interview
of
at her residence.
concurred with this
course of action. The writer,
and
then
traveled to
residence,
, Glenning
Valley, New South Wales, Australia, completed the additional
interview and obtained the relevant photos.
Canberra considers covered the lead set in
referenced serial.
LEAD(s):
Set Lead 1: (Info)
ALL RECEIVING OFFICES
Read and clear.
* *
EFTA00005715
|
EFTA00008487.pdf
|
Oras.4t
Evidence Envelope
Enclosure:
el Original
0
Duplicate
0
Enhanced Original
Medium:
0
Magnetic Tape
0
Computer Disk
0
Printed Material
Case Filers 1X - MS1 - tnIa-7
IDA it 4
Cast Agt.
Tape/Disk*:
Agt. Supervising Title III Intercepts:
O Court Authorized Intercept Source/SymboIN:
•
Consensual Monitoring Intercept- CMN (if assigned): Crtii
,64P
piSe Telephonic (TCM) 0
Nontelephonic (NTCM)
If NTCM Specify Device Used:
K Recording of an Interview
K Volunteered/Subpoenaed Medium - Not FBI ELSUR
O Other Type of Recordin Interception, Specify:
Intercept Date:
Place:
Data Transferred for Permanent Storage
Date;
•
Consensual: List Interceptees Below
OM re A hm ibeA( Az FL
1110 3 /0 9
Time: (P. 5 ipm
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Date: )4../#1
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Reason:
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Date:
Reason:
NOLLVOI1S3ANI
30
Signature:
Date:
Reason:
1.1 01.1t,
I'll HI MIMI°
E02782876
EFTA00008487
|
EFTA00008483.pdf
|
tiole alOsody
ED-5041(Rev.
Case File
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ELSUR Erudesx PAWN. Rorie Ender
831.20171
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Enclosure:
Media Type:
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Force
Type:
Date(s): CM
Officer:
O Title III
O Consensual
FISA
la -Video Surveillance
muff
Non-Custodial - Oven interview
O Non-Custodial - Surreptitious Interview
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Cji Enhanced Original
O CD/DVD.13lue Ray
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Date:
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Reason:
Reason.
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Date: _
Print Name:
Signature:
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Print Name:
Signature:
Print Name:
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Ehte:
Isom
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Date:
Reason:
icking ft:
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Tracking
EFTA00008483
|
EFTA00008485.pdf
|
lain of Custody- ELSUR Evidence Envelope
(Rev. $.17A1)
•
Enclosure: k Original
O
Duplicate
O Enhanced Original
Medium:
O
Magnetic Tape
O Computer Disk
O Printed Material
Case Ei RN: 7d-Mtif\--It3311
ION:
/D
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Case Agt.:
Tape/Disk/1:
Av. Supervising Title III Intercepts:
O Court Authorized Intercept- Source/Symbota:
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,
Consensual Monitoring Intercept - CM# (if assigned):
O Telephonic (TCM) pa Nontelephonic (NTCM)
If NTCM Specify Device Used:
CC.,r v
O Recording of an Interview
K Volunteered/Subpoenaed Medium - Not FBI ELSUR
O Other Type of Recording/Interception, Specify:
friga 5644
Intercept Date: iiiO3/01
Place:
Data Transferred for Pemument Storage - Date:
/30ca. 44-inn Fi-
n/03/191
Time. LI:406pm,
04 Consensual: List Interceptees Below
O Court Authorized: Enter" See Log" Below
IfainsieeAdS.
AMQ
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Signatu
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Reason: F v t r f.Lot
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Date:
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Time:
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Signature:
Da
Signature:
Date --
Reason:
jlti .113 II
EFTA00008485
|
EFTA00008484.pdf
|
Chain of Custody-ELSUR Evidence Envelope
FB-504b (Rev. 547.01)
Enclosure:
Medium:
Case Filen:
33?--7
Case Agt.:
Agt. Supervising Title III Intercepts:
O Court Authorized Intercept - Source/Symbolii:
J2f Consensual Monitoring Intercept - CM# (if assigned):
O Telephonic (TCM)
Nontelephonic (NTCM)
If NTCM Specify Device Used:
f:13/fi
Ng Original
O Magnetic Tape
O Duplicate
O Computer Disk
O Enhanced Original
O Printed Material
I DU:
Tapc/Diskft:
Gm 56-41
O Recording of an Interview
O Volunteered/Subpoenaed Medium - Not FBI ELSUR
O Other Type of Recording/Interception, Specify:
Intercept Date: 0/103/D9
Place: ADV., Akebh
Data Transferred for Permanent Storage - Date: I t /03/0 1
Time:
O Consensual: List Intercept= Below
O Court Authorized: Enter " See Log" Below
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Signature:
Date:
Reason:
Signature:
Date:
Reason:
Signatu
Date:
I in milli
kill
E02782875
TIG1i
EFTA00008484
|
EFTA00008488.pdf
|
Intercept Date:
Data Transferred for Permanent Storage - Date:
Chain of Custody-ELSUR Evidence Envelope
Fri-aothotev.
Enclosure:
i
Original
0 Duplicate
0
Enhanced Original
Medium:
0
Magnetic Tape
0 Computer Disk
0
Printed Material
Case Filc4: 1
— AllA/14"113377
I Da:
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Case Agt.:
Tape/Diskth
Agt. Supervising Title III Intercepts:
O Court Authorized Intercept - Souree/Symbol#:
Consensual Monitoring Intercept - CM# (if assigned): &s4 6-5-41
Telephonic (TCM) 0
Nontelcphonie (NTCM)
If NTCM Specify Device Used:
O Recording of an Interview
O Volunteered/Subpoenaed Medium - Not FBI ELSUR
O Other Type of Recording/Inteeption. Specify:
/0/V1101
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Place: Vil/ S
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*64-1-4-c-brA tetaiLni
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Signature
Date:
ReasorTill *SCA
Signature
Date:
Time: L31,2___
!WTI ie, 7 lime:
Reason:
Slot (>1, e —
Signature:
Date:
Reason:
_
Signature:
Date: kr)-7
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Reason:
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Signature.
Date:
Reason:
Time.
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Signature:
Date:
Reason:
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I
Signature:
Date:
Reason:
FEDEFU Lr
Time:
--v
Ulgi"
EFTA00008488
|
EFTA00008489.pdf
|
of Custody-ELSUR Evidence Envelope
(Rev 847-00
513 Original
0
Magnetic Tape
Enclosure:
Medium:
Case File/:
Case Agt.:
Agt. Supervising Title III Intercepts:
O Court Authorized Intercept - Souree/Symbolti:
54
Consensual Monitoring Intercept - CM# (if assigned):
pg Telephonic (TCM) 0
Nontelephonic (NTCM)
If NTCM Specify Device Used:
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O
Other Type of Recording/Interception, Specify:
Intercept Date: /0/Th .
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Data Transferred for Permanent Storage - Date: /0 a-6"/o 9
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EFTA00008489
|
EFTA00008442.pdf
|
90A-NY 4151227
1B42
08/2112019 NYC023597 PC MASTER CC°Y
One
FEllaaned Meade 218 Mara Drat
0i lo3i IJPK3EADP09. Sm S9GMOPIF
Parsons; the veined E01 maces NYC023589
t1812) tr/C02359311816) NYC023594
!SIN Ana NrC0235g5, letat
EFTA00008442
|
EFTA00008447.pdf
|
EFTA00008447
|
EFTA00008509.pdf
|
EFTA00008509
|
EFTA00008482.pdf
|
Chain of Custody - ELSUR Evidcatt Mc
Snip Envelope
FD-5044 (Rev. S-31-2017)
Case File #:
7 6 - 04- 3) 5 9 .5q 9
#:
Doc#
Total # ,nitre
Case Agent/Task Force Officer. SR
4
Evidence Type:
0 Title 111
K FISA
0
Consensual Monitoring
0 Computer Trespass
El/Video Surveillance
K PR/IT
K Aerial Survelliance
0 Object T
EI/ Ijon-Custodial — Overt Interview
0 Custodial — Interview
0 Non-Custodial — Surreptitious Interview
0
Other
Enclosure:
ErOriginat
0 Enhanced Original
Media Type:
lia(CD/DVD/Blue Ray
0 Hard Drive
0 SD Card
0
Other
Intercept Date(s):
.eil li RI
Location:
Download Date:
I3. it( 3.2,
Download Time:
1995 pen
Title Ill/CM Interceptees —Er/Listed Below or 0 Sec Attached
'Chat- a is_ 1-1-ar ric
Print Name:
Signature: ,
Date:
T. Mime:
Reason: TR"
Tracking ti -
Print Name:
Signature:
Date:
Reason:
Tracking #:
_Lei., Ye ky
Print Name:
Signature:
Signature:
Print Name:
Date:
IS) 2 i ff
Time:
t O 1 2
Date: 1 //3
Time:
•
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co. LA-lia r (
Reason:
--darinse;$ S2
Reason:
Tracking #:
Print Name:
Signature: n
Date:
Tior:
O
ROYOaC I
VI, pi) r 01(4 ih
MASS
Tracking #:
Print Name:
Signature:
Date: 2— /
Reason:
Tracking #:
EFTA00008482
|
EFTA00008474.pdf
|
PCCIONFISZ/OIMINON01/0
irmayserie
3990a
990 LL •ON
03ZINTORO AOA ON My
aV 31^IS
ontioduted
onv unoothontra tur-pu•r, •
FBI-NY Computer Analysis Response Team
90A-NY-3151227
(Mundtion Two 1) Ultrwm t TO 0 lap'. tent)) ming the CART
Artwork archive ed video images taken horn MCC NY video
Rtnorde/ hard Oren, , as of 06/21/2021 Master Copy
FOR Of Mal USE ONLY -
ENFORCEMENT SENSITIVE
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Page 1
UNITED STATES GRAND JURY
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
-v-
JEFFREY EPSTEIN,
Defendant.
APPEARANCES:
X
August 2018
: Additional
• •
UNITED STATES COURTHOUSE
40 Foley Square
New York, New York 10007
July 2, 2019
12:43 p.m.
Assistant
Assistant
Assistant
ESQ.
United States
ESQ.
United States
ESQ.
United States
Attorney
Attorney
Attorney
Acting Grand Jury Reporter
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7/2/19
(Colloquy Precedes.)
(Witness Enters Room.)
(Time noted: 12:47 p.m.)
called as a witness, having
been first duly sworn by the Foreperson of the Grand
Jury, was examined and testified as follows:
EXAMINATION
BY MS.
Q. Could you please state and spell your name for
the record?
A.
Q. Good afternoon, Special Agent
A. Good afternoon.
Q. Where do you work?
A. The FBI.
Q. What's your title at the FBI?
A. Special agent.
Q. How long have you worked as a special agent
for the FBI?
A. For over two years now.
Q. Did you testify before this grand jury on
June 18th, 2019?
A. I did.
Q. Can you just remind the grand jury about your
background? What types of work do you do at the FBI?
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7/2/19
A. I work on the Violent Crimes Against Children
Squad, so we work child exploitation, human
trafficking, and international parental kidnapping
matters.
Q. Have you participated in an investigation of
Jeffrey Epstein and his associates?
A. Yes.
Q. Have you spoken to other people, including
other law enforcement officers, about this
investigation?
A. Yes.
Q. Have you reviewed reports and documents
prepared by others regarding this case?
A. Yes.
Q. And is your testimony today based in part on
those conversations with other law enforcement officers
and documents that you have reviewed?
A. Yes.
MS.
Ladies and gentlemen, some of the
testimony that you're going to hear today will
include hearsay. As you know, that means that the
witness will not be testifying solely from her own
observations, but that she'll also be reporting
what others have told her and what she's read in
reports and documents prepared by others.
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Page 4
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7/2/19
As you know, hearsay evidence is admissible in
these grand jury proceedings, and you're free to
rely on it in determining whether there is
probable cause to indict the proposed defendant.
If, however, you would like to hear the
testimony of any other witness, you have the right
to request it, and we will make reasonable efforts
to bring that witness before you.
BY MS.
Q. So, Special Agent
I placed in front of
you a stack of exhibits. I want to talk through them
now one by one.
We were discussing earlier that you recall
testifying before this grand jury on June 18, 2019;. is
that correct?
A. Yes.
Q. So, I placed in front of you what's marked as
Grand Jury Exhibit 3. Is that a fair and accurate
transcript of your testimony on that date?
A. Yes.
Q. I've also placed in front of you Grand Jury
Exhibit 1. Is that a PowerPoint presentation that you
reviewed with this grand jury on June 18th, 2019?
A. Yes.
Q. So picking up where we left off last time, I
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Page 5
7/2/19
want to follow up regarding the presentation. If you
could turn to page 28 of that presentation.
Now, Special Agent
do you recall
testifying about your interviews with a young woman
named
A. Yes.
Q. And do you recall that there was a question
from the grand jury about the date on one of the slides
in this presentation?
A. Yes.
Q. Just want to follow up on that. So on this
page, just to orient ourselves, do you recall
testifying about phone records of a call between a
phone number subscribed to
and
's cell phone on January 3rd?
A. Yes.
Q. Have you reviewed the underlying phone records
that are excerpted in this slide?
A. Yes.
Q. Is the call highlighted on this slide from
January 3rd, 2005?
A. Yes.
Q. Directing your attention to the top of the
slide where it says 2004, is that a typo?
A. Yes.
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Page 6
7/2/19
Q. Have you confirmed that the underlying records
are, in fact, from January 3rd, 2005?
A. Yes.
Q. Turning to the next slide, on page 29. So the
header on this slide is January 4, 2005. Is that the
same date that's on the deposit slip excerpted in that
slide?
A. Yes.
Q. So does the date on this slide accurately
reflect the date on the deposit slip?
A. Yes.
Q. So when you testified that based on the phone
records we just discussed and this deposit slip, that
it appears that they were on back-to-back days, was
that in fact accurate?
A. Yes.
Q. All right. So I want to switch gears now and
ask you, do you recall testifying before this grand
jury regarding a woman named
A. Yes.
Q. If you could turn now to what's before you and
marked Grand Jury Exhibit 4. Do you recognize this?
A. Yes.
Q. What is this document?
A. So this is a list of messages that to
that
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•
7/2/19
appear to be left for Jeffrey Epstein.
Q. Taking a step back for a moment, how did the
FBI obtain this document?
A. We received this from the Palm Beach Police
Department.
Q. What is your understanding, based on your
review of law enforcement reports and your review of
the case file, of how the Palm Beach Police Department
obtained this document?
A. They would have received it from a trash pull.
So a trash pull is, one of the detectives had gone to
the residence and went through the trash that was left
on the curb.
Q. Is this document from one of those trash
pulls?
A. Yes.
Q. Approximately when was this pulled from the
trash, based on your review of law enforcement reports?
A. April 13, 2005.
Q. In a previous presentation, you discussed a
number of residences. Do you know specifically where
this was pulled from the trash?
A. The Palm Beach residence.
Q. Did you personally participate in gathering
this evidence?
y
•
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Page 8
7/2/19
A. I was not a part of the trash pull, but I have
received the evidence since.
Q. So let's talk through this document.
Looking first at the first page at the top,
what does this document appear to be?
A. It's records listed for Jeffrey Epstein,
4/11/2005 to 4/11/2005.
Q. What are the fields at the top?
A. So the left side has who it's from, the middle
has the message, and then on the right it has -- some
of them have phone numbers listed.
Q. Does the name
appear in this document?
A. Yes.
Q. Let's turn to the fourth page of this
document. Focusing on the last line, do you see where
it says callers?
A. Yes.
Q. What is listed in the field to the right?
A. It lists
Q. Turning to page 2 of this document, focusing
on the bottom three lines, can you point out to the
grand jury where you see the name
at the bottom
of this document?
A. So
is listed twice.
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(Indicating.)
Q. What are the messages to the right of the name
A. The first message lists, I'm back in New York.
Q. What's the second one?
A.
is back.
Q. Is there a phone number listed next to the
message?
A. Yes.
Q. And what is the area code for that phone
number?
code?
A.
Q. Does that appear to be a New York City area
A. Yes.
Q. In your interviews with
have
you asked her whether or not she recognizes this phone
number?
A. Yes.
Q. What did she tell you?
A. She did not recognize it.
Q. What, if anything, did she tell you about the
phones that she was using during this time period?
A. She said that she was using a lot of different
phones, that she'd gone a lot of different places, so
_
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39 West 37th Street • New York, New York 10018
Page 10
7/2/19
she didn't recall all the numbers that she had used in
the past
Q. Have you obtained phone records for this phone
number?
A. Yes.
Q. Who was listed for the subscriber in 2005?
A. It came back to an individual in Maspeth.
Q. Based on your participation in this
investigation, does that particular individual have any
significance to this investigation, as far as you can
tell?
A. No.
Q. If these messages had been left by
in
New York, would some type of communication have had to
occur across state lines in order for these messages to
have been found in Florida?
A. Yes.
Q. Do you recall testifying about
and
having remembered receiving phone calls
from Epstein's assistant, Mt
A. Yes.
Q. Did they recall that occasionally when they
would get phone calls from MB
that she would say
that she was calling from New York?
A. Yes.
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Q. If
7/2/19
and
were in Florida when they
got those calls and those calls had, in fact, been
placed from New York, would those calls have traveled
across state lines?
A. Yes.
Q. A few final questions about
In your conversations with her, did she ever describe
to you receiving phone calls regarding the massages
that she was scheduling?
A. Yes.
Q. Who would call her?
A. MM.
Q. Did she recall speaking to anyone else on the
phone?
A. Epstein.
Q. And did she explain the context in which she
would receive calls and speak to Epstein?
A. Yes. She said that when she spoke with
Epstein on the phone, it would always be through
IIIIII/ So
would contact her and then put him
on the phone to speak with her.
Q. What was her understanding of who
was?
A. His assistant.
Q. In these conversations with
and
Epstein, did
recall whether or not either of
Fink & Camcy Reporting and Video Services
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39 West 37th Street • New York, New York 10018
Page 12
7/2/19
them had ever asked her to bring a particular girl to
the house?
A. Yes.
Q. Did she recall whether
ever asked her
to bring a particular girl?
A. Yes.
Q. What does she remember about that?
A. That
would ask her, do you have this
particular girl or can this girl come tonight or on
whatever day that they had chosen.
Q. When she would speak with Epstein on the
phone, did she recall whether or not Epstein would ever
ask her to bring a particular girl?
A. Yes.
Q. What did she remember about that?
A. Along the same lines, can you bring this girl.
Q. Just one moment.
Special Agent
have you told the grand
jury everything that you know about this case, or have
you just answered the questions that I've asked?
A. I've just answered the questions you've asked.
Q. When you testified about the documents you
reviewed or the conversations that you had with.others,
were you testifying to the exact words that were used
or just the substance of the documents or
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Page 13
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7/2/19
conversations?
A. Substance.
Q. Are you willing to return to the grand jury if
the grand jury has any further questions for you?
A. Yes.
MS.
With the Foreperson's permission, I
would ask that Special Agent
be excused.
THE FOREPERSON: You're excused.
(Witness Excused.)
(Time noted: 1:00 p.m.)
(Colloquy Follows.)
Fink & Carney Reporting and Video Services
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Page 14
CERTIFICATE
STATE OF NEW YORK
COUNTY OF KINGS
)
)
hereby certify
that the foregoing is a true and accurate
transcript, to the best of my skill and ability,
from my stenographic notes of this proceeding.
Active Grand Jury Reporter
Fink & Carney Reporting and Video Services
39 West 37th Street * New York, New York 10018
(800) NYC-FINK * (212) 869-3063
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Messages
Page I o(4
•
•
Records Listed For: JEFFREY EPSTEIN from 04/11/2005 to 04/11/2005
From
reminders
7:43AM
Message
1. Call Gabriel Perahla
Gowen
Thursday 4. Pinto in Pans this week
er
2. Call William
an e son in Paris on
Just j
i lt
info:
end me Jetblue 623 arriving 12.20pm
WPB.
678 jetblue, leaving WPB 11.10 am, arriving JFK
1.45pm. Citicar picking up
Cecilia
UN for Emad to talk to Paul Gandy re phone system and electric
9:35AM
distribution.
Cecilia
9:35AM
Mlles
9:37AM
Jean Luc
9:55AM
10:13AM
warren
Elsenstein
10:17AM
Yanush is picking upMend
Will email photos of beach house floor.
I lost my cell phone, but will be in the office after 10:30.
You had wanted me to put the tiles on the Midnight express for
the cabana - the midnight express has not left yet as you know -
should I wait for the boat to come to FLA or orgnalse for the tiles
o be sent to PB
Where should I mall the DVD7
'm available all week except for Thum, if you're around.
Ira
Zicherman
Bought 50 000 CELL at $437.068
10:22AM
Pis call.
Looking In a realestate magazine - there are 2
w/ direct ocean front - Christine COndon in PB
10:27AM
another Carole Koeppel
they w re in
times realestate mag
Cecilia
10:33AM
Ira
Zicherman
10:35AM
Cecilia
10:49AM
Lm for G to just send the tiles.
Stock is trading at 36.79. I understand there are some
additional shares, sou blocks available in this area. Do you
have any interest?
Jean bought bought the two vases (6.500 Euros) and the large
11:06AM
console 4.200 Euros - nice surprise).
ii
http://domsrv0lgoichaven/wc.dinGmax—MsgAisplay
Phone
4/11/2005
GM_GLSDNY_00000342
EFTA00008870
Meisager
Pagc 2 of 4
•
•
lean Luc
11:07AM
Call me at the office (I tried to connect you).
Prof. Camhi
11:16AM
Pis call
Miles
Schnitman
11:24AM
Just calling to see where we stand.
Eric
11:34AM
Dr. Landon's $25k quartly payment is due, please approve.
Den
Sperber;
11:38AM
Collin• re meetin I'm in NY until Mon. Pis email your reply.
George
Reenstra
11:40AM
Via email re photos of other 7G s: That Is on temp hold,
apparently we are now painting all black with a camel stripe
Cecilia
12:17PM
Naomi
Campbell
12:18PM
LM for
back?
re is any of her friends
Via email: Hello, naorn1 here would like to know when I can
speak with Jeffery, regarding my swimsuit line.For a meeting
with VS to see,I have pia and some of the sults with me.. Hope
IS well
Cecilia
12:26PM
LM and emeiled Dan Sperberg to call.
Bill Karr
12:27PM
I will email the plans later today.
Dr. Jerecki
12:33PM
Please call.
Cecilia
LM for Jerry Goldsmith re has lawyer letter been sent out yet,
12:43PM
Amy Evans
12:50PM
Calling for Congressman Tom Reynolds regarding the lune 14th
annual dinner with Bush. NRCC Business Advisory.
G
12:51PM
Spoke to Miles re sending the blue tiles for the cabana to PB -
you sd to him last week to keep them for the Tiki house kitchen
- plse advise
Kenneth
Cole
12:51PM
:4 PM
Melanie
From Dr. MoskovItz' office. We're trying to find some place in NY
2:04PM
wherellecan have her heart test done.
2:29PM
IS
back.
Returning your call.
I'm back in NY.
Call me re what we talked about.
http://domsrv0 lifoxhaveniwc.di I7Gmaz—MseDisplay
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4111/2005
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Messages
Page 3 of 4
•
•
I2:38PM
C.
Fiona
2:39PM
From Dr. Jareckrs. P15 call.
Melanie
2:43PM
From Dr. Moskowitz's office.
n get the heart test done
on Fri in NV. Appt at 3.30pm,
ec -In 3.15pm. Faculty practice
stave, G elevator to 13th floor, $1656 total,
Is there a check for me?
C
Eric
2:54PM
Please confirm that I am wiring S3mm from your account to MJ
Lit.
' Can Danielle and I work this week?
Jerry
Goldsmith
2:57PM
Gowdy was out of town, but the letter will be delivered today.
G
3:02PM
Leighton Chandler doesn't know if she can organize for me to
see the mansion this week as it Is just getting on the market.
She will check to see if she get me in tomorrow. If not, it will
have to De the next time I'm in town. nt Copied From
GHISLAINE MAXWELL *** Original Date and Time: 04/11/2005
at 2:19P
r
Greg Hersch
3:08PM
via my email: Please let Jeffrey know that If he intends to
participate in the Emerging Market Special Opportunities fund
that the deadline for subscription dots is next Wednesday, April
20 for May 1 trading. Thanks'
G
km--
iCecilla
3:11PM
Jed° will pick up■s prescription. WHere should 1 fedex it,
r
Eric
3:11PM
FYI: on the Dr. Landon quarterly payments, we (NYSG) billed
LHW/Abigall In advance as we have In prior years.
Pis call.
Larry
Newman
3:39PM
I just need a few more minutes If you have time.
4:17PM
Just calling to check in.
G
4:21PM
----..
The Tel Aviv ticket was not a fraud. It was to get a renewal for
your 2nd valid passport. We're getting a refund for It.
manu
4:26PM
The pool specialist can't come tomorrow in P8. He can only come
on WedneSday morning if it's ok for you. Pls advice
r
Cecile
4:27PM
Fro the power symposium, we are looking at 4 days between
January 6, 2006 and January 17th or 18t.h. The participants
working on their schedules and need to know ASAP We also
need to let the hotel so we don't lose our $20000 deposit.
C
I
Cecilia
•
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4/11/2005
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•
Messages
Page 4 of 4
•
I4:27PM
I had
on the line for you.
Dr. victor
4:28PM
Pls call.
I 0
can work tomorrow at 4pm.
Cecilia
4:41PM
I had Dan Sperberg on the line for you. He will call back since he
has no reception In the library.
r;
Cecilia
4:45PM
I forwarded helicopter pictures from George Reenstra to your
yahoo.
r
Cecilia
4:47PM
I had Dr. larecki on the line.
r
G
4:50PM
Lydia got her aesthetician license and can not do facials.
F
menu
4:54PM
GYM works In Paris: 3 weeks 1/2 to finish. Pinto waiting for a
starting date ( possibly 8 days of advance to organize It).
IT
Bill Karr
4:55PM
The mail server Is down, but I will email the plans as soon as I
can.
n
Outstanding
did not can bac
4:56PM
ri
Callers
Prof. Camhi, Miles Schnitmen,
4:56PM
Dr. Victor.
n
•
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Copyright (c) 2000-2004, Postern interests, Inc. Al Rights Reserved
•
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UNITED STATES GRAND JURY
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
-v-
GHISLAINE MAXWELL
(2018R01618)
APPEARANCE
S:
: November 19, 2019 Additional
-x
United States Courthouse
300 Quaroppas Street
White Plains, New York
July 8, 2020
10:05 a.m.
Assistant United States Attorney
Acting Grand Jury Reporte.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
GNLGUDNYJX000(1208
EFTA00008708
United States v. Ghislaine Maxwell
07/08/20
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(10:05 a.m.)
MS.
Let the record reflect that there are
17 grand jurors present and that the foreperson is present.
Good morning, ladies and gentlemen. My name is
and I am an Assistant United States Attorney
here in the Southern District of New York.
Can everyone hear me okay? All right. I see
everybody's heads nodding. Thank you.
I am here today to present for your consideration
a proposed superseding indictment charging Ghislaine Maxwell
in six counts. This indictment is virtually identical to
the indictment that you returned last week charging Maxwell
in those same six counts except that it corrects two
clerical errors, or two typographical errors that were
contained in Counts Five and Six which are the perjury
charges.
As a result, I will not be presenting any new
evidence or new witnesses today. Instead, I will identify
for you those two clerical errors in the indictment. I will
point out the portion of the exhibits that you saw last week
that provide the correct information. Then I will identify
the corrected portion of the superseding indictment in the
proposed superseding indictment.
Before I do that though, I must ask you all the
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
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United States v. Ghislaine Maxwell
07/08/20
same preliminary questions that we went over last week.
First, do any of you believe that you personally know or
have met the proposed defendant, Ghislaine Maxwell? I see
no hands.
Next, have you any heard or read about, or learned
anything Ghislaine Maxwell, Jeffrey Epstein or anyone else
related to this case, if you could just raise your hand? I
see a number of hands. Virtually every hand is in the air.
You can all put your hands down. Thank you.
As you know, you must make your determination as a
grand jury based on the evidence presented before you in the
grand jury, in this room alone. Accordingly, you must set
aside any other knowledge you may have about this case or
the people involved in it, and base your decision solely on
the evidence presented to this grand jury to determine
whether there is probable cause to believe that the charges
in the proposed indictment were committed.
Is there any grand juror here today who cannot
follow these instructions? I see no hands. Just to be
sure, is there any grand juror here who would have any
difficulty setting aside the outside information you may
have about the defendant or the facts of this case? I see
no hands.
Finally, do any of you believe you know me in
anything other than my professional capacity? I see no
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
GM_GLSDNY_00000210
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United States v. Ghislaine Maxwell
07/08/20
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hands.
Now, as I mentioned, I will not be calling any
witnesses today. Instead I will present you with the
exhibits from last week, the transcript of the testimony you
heard from last week and the proposed superseding
indictment. I will then walk you through the error that the
superseding indictment seeks to correct.
Please keep in mind though that what I say is not
evidence. Only the testimony of the witnesses and the
exhibits are evidence. So as I'm walking you through these
exhibits, your understanding of them and your understanding
of the evidence controls. I am just trying to provide you
with an overview.
With that instruction in mind, I am going to put
up onto the Elmo what was previously received and marked as
Grand Jury Exhibit 1. That is the proposed six-count
indictment that you voted to return last week. A copy of it
will be available for review when you deliberate.
You also received what has been marked as Grand
Jury Exhibit 2, which I will not put up on the Elmo. Thar
was a PowerPoint presentation containing photographs anc
excerpts of certain documents that was shown to you during
the testimony last week. You also heard testimony from FBI
Special Agent
Today I am marking, as Grand Jury Exhibit 3, a
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
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United States v. Ghislaine Maxwell
07/08/20
copy of the transcript of that testimony. It is up on the
Elmo now and it will be available for you to review if you
would like as you deliberate. I will not read it back to
you now, but you can read through it as you deliberate.
Finally, I am marking, as Grand Jury Exhibit 4,
the proposed superseding indictment, which I have now placed
up on the Elmo. As I mentioned, this proposed superseding
indictment corrects two clerical errors and is otherwise
identical to the original indictment, Grand Jury Exhibit 1.
I'm now going to walk you through the errors that
we're going to correct starting on Grand Jury Exhibit 1.
Page 15 contains the beginning of Count Five which charges
Maxwell with perjury. Paragraph 21 on that page refers to
the civil case in which Maxwell gave deposition testimony on
April 22nd, 2016, as 15 Civ. 7344. That is the error we are
going to correct.
Similarly, page 16 contains the beginning of Count
Six which charges another count of perjury. Paragraph 23 on
that page refers to the civil case in which Maxwell gave
deposition testimony on July 22nd, 2016, under the sare
number, 15 Civ. 7344.
Turning now to Grand Jury Exhibit 2. Slue 22 el
that exhibit contains the first page of the deposition
transcript from the testimony that Maxwell gave on
April 22nd, 2016. As you can see here, the docket number
FREE STATE REPORTING, INC.
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D.C. Area 301-261-1902
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United States v. Ghislaine Maxwell
07/08/20
for that case is in fact 15 Civ. 7433 not 7344.
Similarly, slide 25 contains the first page of cite
transcript from the July 22nd, 2016 deposition that Maxwell
gave. As you can see here, again, the docket number for
that case is 15 Civ. 7433 not 7344.
Finally, I will turn to the proposed indictment,
Grand Jury Exhibit 4. On page 15, you have again the same
perjury count with one change. Paragraph 21 corrects the
docket number for the civil case to be 15 Civ. 7433.
Similarly, on page 16, which contains the second
perjury count for the July 22nd, 2016 deposition, the docket
number is corrected to 15 Civ. 7433. There are otherwise no
changes to the substance of this indictment.
That is my presentation. Before I leave you to
deliberate, would anyone like me to read the full proposed
superseding indictment out loud? I see no hands.
I must advise you that you must independently find
probable cause, again, for each count in the superseding
indictment. The evidence before you in support of the
charges in the superseding indictment is the same evidence
that was before you when you considered the indictment last
week.
Does anyone have any questions about that
evidence? I see no hands.
The legal instructions that you received before
FREE STATE REPORTING, INC.
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United States v. Ghislaine Maxwell
07/08/20
7
voting on the indictment last week are the same instructions
that apply to your consideration of the proposed superseding
indictment. Would anyone like me to read those instructions
out loud for you again? I see no hands.
Does anyone have any questions about the legal
instructions? I see no hands.
I will leave you now with the exhibits to
deliberate. As always, if you have any questions or
concerns about the proposed indictment, please let me know
before you vote so that I may answer any questions you may
have on the law, or bring any additional evidence before you
to consider. Thank you, all.
(Matter concluded)
(Time Noted: 10:14 a.m.)
FREE STATE REPORTING, INC.
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D.C. Area 301-261-1902
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CERTIFICATE
I hereby certify that the foregoing is a true and
accurate transcription, to the best of my skill and ability,
from my electronic notes of this proceeding.
July 22, 2020_
Date
Acting Grand Jury Reporter
Free State Reporting, Inc.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
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EFTA00008529.pdf
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EFTA00008863.pdf
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United States v. Ghislaine Maxwell
March 29, 2021 Grand Jury Presentation
GM_GLSDNY_00000216
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Federal Express Record
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JEFFREY E EPS- EIN
457 MADISON AVE
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JEFFREY E EPSTEIN
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Message Pads from Epstein's Palm Beach Residence
IMPORTANT MESSAGE
FOR
A.M.
DATE
TIME_
PM
OF
PHONE . -AREA ••
EXTENSION
TELEPHONED
\
PLEASE CALL
I
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WANTS TO SEE YOU
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SPECIAL ATTENTION
MESSAGE
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FIMPORTANT MESSAGE
FOR
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SIGNED
GM_GLSDNY_0000022 I
EFTA00008868
Message Pads from Epstein's Palm Beach Residence
IMPORTANT MESSAGE
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DATE
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PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
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SPECIAL ATTENTION
MESSAGE
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IMPORTANT MESSAGE
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WANTS TO SEE YOU
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EFTA00008874.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
GHISLAINE MAXWELL,
Defendant.
x
x
SEALED
INDICTMENT
20 Cr.
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2.
As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
GM_GLSDN Y_00000346
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Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
GM_GLSDNY_00000347
EFTA00008875
4.
Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a.
MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b.
Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
c.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
3
GM_GLSDNY_00000348
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massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d.
In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e.
Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5.
GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
4
GM_GLSDNY_00000349
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directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6.
Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a.
A a multi-story private residence on the
Upper East Side of Manhattan, New York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
GM_GLSDNY_00000350
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6
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
c.
A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
GNI_GLSDNYJMNB51
EFTA00008879
d.
MAXWELL's personal residence in London,
England.
7.
Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
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and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b.
MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
8
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an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
c.
MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8.
In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
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EFTA00008882
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
10
GM_GLSDN Y_00000355
EFTA00008883
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
c.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
•
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
11
GM_GJ_SDNY_00000356
EFTA00008884
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
12
GM_GJ_SDNY_00000357
EFTA00008885
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423(a).
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423(a).
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
13
GM_GLSDNY_00000358
EFTA00008886
New York Residence, in violation of New York Penal Law, Section
130.55.
c.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
14
GM_GLSDN Y_00000359
EFTA00008887
aided and abetted the same, to wit, MAXWELL arranged for Minor
victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423(a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you're talking about.
•
•
•
15
GM_GLSDN Y_00000360
EFTA00008888
Q•
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall. . .
Q•
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A.
No.
16
ONLGLSDNY2WENBM
EFTA00008889
Q.
Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q•
I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A.
That is my testimony, that is correct.
• • •
Q.
Is it your testimony that you've never given
anybody a massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
Q•
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
FOREPERSON
17
AUDREY S RAUSS
Acting nited States Attorney
GM_GLSDNY_00000362
EFTA00008890
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
GHISLAINE MAXWELL,
Defendant.
INDICTMENT
(18 U.S.C. §§ 371, 1623, 2422, 2423(e),
and 2)
AUDREY STRAUSS
Acting United States Attorney
Foreperson
18
GM_GLSDNY_00000363
EFTA00008891
|
EFTA00008744.pdf
| null |
EFTA00008892.pdf
|
GRAND JURY_,
EXHIBIT
(7
United States v. Ghislaine Maxwell
June 29, 2020 Grand Jury Presentation
GNI_GLSDNY_00000364
EFTA00008892
I
GM_OLSDNY_00000365
EFTA00008893
9 East 71St Street, New York, New York
GM_OLSDNY_00000366
EFTA00008894
358 El Brillo W , Palm Beach, Florida
GM_G,S.Y,ON)0367
EFTA00008895
49 Zorro Ranch Road, Stanley, New Mexico
GM_GLSDNY_00000368
EFTA00008896
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GM_GLSDNY_00000369
EFTA00008897
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GM_GLSDNYANX)0370
EFTA00008898
Interlochen Arts Camp
Filtered By
Show: All accounts
School equals Interlochen Center for the Arts
Completion year greater or equal 1994
Completion Year less cr equal :998
Completion Year t
First Name
1994
Last Name
Education Type
8
GM_GLSDNY_00000371
EFTA00008899
O Interlochen
February 9, 1994
Mr. Jeffrey Epstein
J. Epstein and Company, Inc.
The Villard House
457 Madison Avenue
New York, NY 10022
Dear Jeffrey:
I have talked to you and Ghislaine on several occasions to
say thank you. But, I wanted to express in writing my
personal and professional gratitude for the very generous
gift gf $20O.O_00 for a new scholarship lodge. It is truly
an extraordinarl-ge§ture.
Under the charitable contribution act, you are
permitted use of the lodge for two weeks each
year, without any negative implications in respect
to the full tax deductibility of your gift.
Naturally, we would like you to visit the new
lodge this summer. So that we might begin to book
the lodge, I would ask you to consider what two
weeks you would like reserved for your use.
Perlman will be giving his concert on August 7,
1994. I have enclosed the appropriate tax code
for your file.
4)
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December 23, 1994
Ghislaine Maxwell
c/o J.
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Nal
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457 Madison Avenue
New York, NY 10022
Dear Ghislaine:
Enclosed is the envelope we recently found in cleaning the
Epstein Lodge. Apparently it lodged between the wall and
the dresser. It was not discovered until the unit was moved
for cleaning.
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SECTION A.
Name of student algal name)
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permanent addrecs
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SECTION E.
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19
GMJ3J_SDNY_00000382
EFTA00008910
GNI_Cd_SDNY_000oo3S3
EFTA00008911
I
GM_GLSDNY_00000384
EFTA00008912
April 22, 2016 Deposition
UNITED STATES DISTRICT COURT
EOUTHEAN DISTR/CT OF NEW YORK
Plaintiff,
Case No.:
-a7aLn5t-
SHISLAINE MAXWELL,
Derengants.
x
.ACONFIDENTILL*0
Videotaped denosicion of GHISLAINE
MAXWELL, taken pursuant to aubpoena, was
held at the law etrices of BOIES
5CEILLER & FLEXNER, 575 Lexington
Avenue, Now York, New York, commencing
April n2, 2016, 9:C4 a.m., on the above
date, before Leslie Faqir., a Court
Reporter and Notary Public In the State
of Now York.
GM_GLSDNY_00000385
EFTA00008913
Q.
Did Jeffrey Epstein have a scheme
to recruit underage girls for sexual
massages?
MR. PAGLIUCA: Objection to the
form and foundation.
Q.
If you know.
A.
I don't know what you are talking
about.
GM_GJ_SDNY_00000386
EFTA00008914
Q.
List all the people under the age
of 18 that you interacted with at any of
Jeffrey's properties?
A.
I'm not aware of anybody that I
interacted with, other than obviously
who was 17 at this point?
24
GM_GJ_SDNY_00000387
EFTA00008915
July 22, 2016 Deposition
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORE
Plaintiff,
-against-
GMISLAINE MAXWELL,
Defendant.
Case No.:
l5-ev-07422-RWS
•"CONFIDENTIAL""
Continued Videotaped Deposition of
GHISLAINE MAXWELL, the Defendant herein,
taken pursuant to subpoena, was held at
the law offices of Boies, Schiller 6
Flexner, LLP, 575 Lexington Avenue, New
York, Now York, commencing July 22,
2016, 9:04 a.m., on the above date,
before Leslie ragin, a court Reporter
and Notary Public in the State of New
York.
25
GM_O_SDNY_00000
388
EFTA00008916
Q.
Were you awarla of the presence of
sex toys or devices used in sexual activities
in Mr. Epstein's Palm Beach house?
MR. PAGLIUCA: Objection to form
and foundation.
A.
No, not that I recall.
Q.
Do you know whether Mr. Epstein
possessed sex toys or devices used in sexual
activities?
MR. PAGLIUCA: Objection to form
and foundation.
A.
No.
26
GM_GLSDNY_00000389
EFTA00008917
I
O.
Other than yourself and the blond
and brunette that you have identified as
having been involved in three-way sexual
activities, with whom did Mr. Epstein have
sexual activities?
MR. PAGLIUCA: Objection to form
and foundation.
A.
I wasn't aware that he was having
sexual activities with anyone when I was with
him other than myself.
O.
I want to be sure that I'm clear.
Is it your testimony that in the 1990s and
2000s, you were not aware that Mr. Epstein
was having sexual activities with anyone
other than yourself and the blond and
brunette on those few occasions when they
were involved with you?
A.
That is my testimony, that is
correct.
27
GMJILSDNY_00000390
EFTA00008918
Q.
Let's just tie that down. It is
your testimony that you've never given
anybody a massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a
massage, is that your testimony?
A.
That is my testimony.
Q.
You never gave
a
massage is your testimony?
A.
I never gave
a
massage.
28
GM_GJ_SDNY_00000391
EFTA00008919
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EFTA00008920.pdf
| null |
EFTA00008631.pdf
| null |
EFTA00008998.pdf
|
GRAND JURY
EXHIBIT
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
UNITED STATES OF AMERICA
SUPERSEDING INDICTMENT
GHISLAINE MAXWELL,
Defendant.
x
S1 20 Cr. 330 (AJN)
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 16.
2.
As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
GM_GLSDN Y_00000470
EFTA00008998
2
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
' 3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
GIA_GLSDNYJKENM71
EFTA00008999
4.
Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a.
MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b.
Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
c.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
3
GM_GLSDN Y_00000472
EFTA00009000
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d.
In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e.
Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5.
GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
4
GM_GJ_SDNY_00000473
EFTA00009001
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6.
Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a.
A a multi-story private residence on the
Upper East Side of Manhattan, New. York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
GM_GJ_SDNY_00000474
EFTA00009002
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
c.
A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
6
GM_GJ_SDNY_00000475
EFTA00009003
d.
MAXWELL's personal residence in London,
England.
7.
Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
GM_GLSDNY_00000476
EFTA00009004
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b.
MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 16 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
8
GM_GLSDN Y_00000477
EFTA00009005
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
c.
MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8.
In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
GM_GLSDN Y_00000478
EFTA00009006
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
10
GM_GLSDN Y_00000479
EFTA00009007
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
c.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
11
GM_GLSDNY_00000480
EFTA00009008
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
12
GM_Gl_SDN Y_0000048 I
EFTA00009009
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423(a).
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423(a).
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
13
GM_GLSDN Y_00000482
EFTA00009010
New York Residence, in violation of New York Penal Law, Section
130.55.
c.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
14
GM_GLSDNY_00000483
EFTA00009011
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423(a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you're talking about.
•
•
•
15
GM_GLSDN Y_00000484
EFTA00009012
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with,
other than obviously (the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall. . .
Q•
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A.
No.
16
GM_GJ_SDNY_00000485
EFTA00009013
Q•
Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q.
I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A.
That is my testimony, that is correct.
•
•
•
Q.
Is it your testimony that you've never given
anybody a massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
Q.
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
FOREPERSON
AUDREY STRAUSS
Acting United States Attorney
17
GM_GJ_SDNY_00000486
EFTA00009014
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v .
GHISLAINE MAXWELL,
Defendant.
SUPERSEDING INDICTMENT
S1 20 Cr. 330 (AJN)
(18 U.S.C. §§ 371, 1623, 2422, 2423(a),
and 2)
AUDREY STRAUSS
Acting United States Attorney
Foreperson
18
GM_GLSDN Y_00000-187
EFTA00009015
|
EFTA00008599.pdf
|
United States v. Jeffrey Epstein
June 18, 2019 Presentation
GM_GLSDNY_00000001
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9 East 71st Street, New York, New York
GM_GLSDNY_00000002
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358 El Brillo Way, Palm Beach, Florida
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GM_GLSDNY_000000 B
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IMPORTANT MESSAGE
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IMPORTANT MESSAGE
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Her new phone 4,
SIGNED
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GM_GLSDNY_000000 15
EFTA00008613
IMPORTANT MESSAGE
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7/reeve /
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SIGNED
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GM_GLSDNY_000000 16
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IMPORTANT MESSAGE
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GM_GLSDNY_00000020
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GM_GLSDNY_00000022
EFTA00008620
23
GM_GJ_SDNY_00000023
EFTA00008621
24
GM_GJ_SDNY_00000024
EFTA00008622
October 12, 2004 Deposit
10 1.: o.
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GM_GLSDNY_00000025
EFTA00008623
November 9, 2004 Deposit
kiemsER'S COPY
GOiDORSI
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(56 )965.1000
Drivers License Number
Other I.D.
Members Signature
NCUA
Check deposits are subject to your
Credit Union check hold policy.
26
CiNl_al_SDNYJXXXXX)26
EFTA00008624
Financially Liable Party
Name:
JEFFREY E EPSTEIN
%
Credit Address: 457 MADISON AVE, NEW YORK NY 16022-6843
Customer Since: 04/03/2004
Photo ID Type:
Photo ID Number:
DOB:
05/05/1950
Contact Name:
Contact Nome Phone:
Contact Home Email:
Account Number:
Name:
Billing Address:
JEFFREY E EPSTEIN
'pato ID State:
4
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457 MADISON AVE. NEW YORK NV:10022-6843
Account Status:
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7
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User Infdimation
IMSI:
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457 MADISON AVE , NEW YORK Ni 10022-6843
•
GM_GLSDNY_00000027
EFTA00008625
January 3, 2004 Calls
952 01103 11:33A
NEW YORK NY
1 MIN
•Citi Ciao BIN' asibibiL
953 01103 11:34A
INCOMING
1 MIN
INCLUDED MINUTES
954 01/03 11:49A
BOYNTONBCH FL
1 MIN
INCLUDED MINUTES
955 01/03 12:19P
BOYNTONBCH FL
1 MIN
INCLUDED MINUTES
956 01103 1221P
WPALMBEACH FL
1 MIN
UNLIM MOBL TO MOBL
957 01/03 12:24P
WPALMBEACH FL
1 MIN
INCLUDED MINUTES
958 01103 12:24P
BOYNTONBCH FL
1 MIN
INCLUDED MINUTES
959 01103 12:27P
BOYNTONBCH FL
1 MIN
INCLUDED MINUT S
960 01/03 12:45P
INCOMING
6MIN
INCLUDED MINUTES
961 01/03 12:53P
BOYNTONBCH FL
1 MIN
INCLUDED MINUTES
962 011O3 12:54P
INCOMING
1 MIN
INCLUDED MINUTES
963 01103 01.0% •
NEW YORK NY
1 MIN
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29
GM_GLSDNY_00000029
EFTA00008627
September 16, 2004 Calls
VOICE USAGE FOR
Continued
Qnty
Charge
Number
Item Date Time
Calls To
Used
Rate Description
125 09115 08:45P
WPALMBEACH FL
OWN
300 ADD'L ANYTME MN
126 09115 08:52P
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2MI II
300 ADD'L ANYTME MN
127 09/1$ 09:04e
128 09/15 09:32P
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129 09115 10:39P
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130 09/16 11:14A
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131 09/18 02:07P
WPALMBEACH FL
1MIN
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132 01'16 02-05P
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133 09/16 02:44P
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134 09/16 02:45P
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300 ADM ANYTME MN
135 09/16 02:46P
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2 MIN
300 A001. ANYTME MIN
136 09/16 02:48P
WPALMBEACH FL
4 MIN
300 ADM. ANYTME MIN
131 09/16 02:54P
BOYNTONBCH FL
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138 09/16 02:55P
BOYNTON BCH FL
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139 09/16 03:44P
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140 09/16 07:46P
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141 09/16 09:55P
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142 09/17 07:21A
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1MAN
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143 09/17 12:21
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144 09/17 03:16P
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GM_GJ_SDNY_00000032
EFTA00008630
|
EFTA00008716.pdf
|
United States v. Ghislaine Maxwell
June 29, 2020 Grand Jury Presentation
GM_GLSDNY_00000103
EFTA00008716
GM_GJ_SDNY_00000104
EFTA00008717
9 East 71st Street, New York, New York
3
GM_GLSDNY_000001 05
EFTA00008718
358 El Brillo Wa , Palm Beach, Florida
GM_GUON,O00O01.
EFTA00008719
49 Zorro Ranch Road, Stanley, New Mexico
GM_GLSDNY_00000107
EFTA00008720
GM_GLSDNY_00000108
EFTA00008721
GM_GLSDNY_00000109
EFTA00008722
Interlochen Arts Camp
Filtered By
Show: All accounts
School equals Interlochen Center for the Arts
Completion Year greater or equal 1994
Completion Year less or equal 1998
Completion Year t
First Name
1994
Last Name
Education Type
GM_GLSDNY_00000110
EFTA00008723
O Interlochen
February 9, 1994
Mr. Jeffrey Epstein
J. Epstein and Company, Inc.
The Villard House
457 Madison Avenue
New York, NY 10022
Dear Jeffrey:
I have talked to you and Ghislaine on several occasions to
say thank you. But, I wanted to express in writing my
personal and professional gratitude for the very generous
gift f $20
0 for a new scholarship lodge. It is truly
an extraordinary
sture.
Under the charitable contribution act, you are
permitted use of the lodge for two weeks each
year, without any negative implications in respect
to the full tax deductibility of your gift.
Naturally, we would like you to visit the new
lodge this summer. So that we might begin to book
the lodge, I would ask you to consider what two
weeks you would like reserved for your use.
Perlman will be giving his concert on August 7,
1994. I have enclosed the appropriate tax code
for your file.
GM_GLSDNY_000001 I I
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August 18, 1994 Flight
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EFTA00008726
Interlochen
December 23, 1994
Ghislaine Maxwell
c/o J.
House
457 Madison Avenue
New York, NY 10022
Dear Ghislaine:
Enclosed is the envelope we recently found in cleaning the
Epstein Lodge. Apparently it lodged between the wall and
the dresser. It was not discovered until the unit was moved
for cleaning.
GM_GLSDNY_000001 14
EFTA00008727
November 11, 1996 Flight
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GM_GLSDNY_00000115
EFTA00008728
Teterboro Airport
GN1_al_SDN Y_000001 16
EFTA00008729
May 9, 1997 Flight
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GM_GUDNY_00000117
EFTA00008730
May 3, 1998 Flight
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16
GM_GLSDN Y_UOUOUI I
EFTA00008731
SECTION A.
Name of student (legal name)
Date 42
519f
( ) Male SI I Female
SSN
Grade applied for
(2—
(month/year) q/92
For entrance
Date of birth
Birthplace (city/state)
Permanent address
I address
City/state/zir
City/state/zip
SECTION E.
Who has financial responsibility? M.r. lefirej
cs-te_n
Ep
;
Address 95 -7- Itotoutitson Ave .
Cityfstate/zip 1464 16r i N Y. ino2:2
Bank reference (name and branch) J. P lvimigun) 5"' tivt. •
Do you expect to apply for financial assistance? [ ] Yes IQ No
GM_GLSDNY_00000119
EFTA00008732
January 3, 1995 Flight
Date
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18
GM GJ SDNY_OOD00120
EFTA00008733
February 12, 1995 Flight
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19
GM_GJ_SDNY_00000121
EFTA00008734
GM_GLSDNY_00000122
EFTA00008735
GM_GLSDNY_00000123
EFTA00008736
April 22, 2016 Deposition
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
-against-
GHISLAINE MAXWELL,
Defendants.
Case No.:
15-cv-07433-RWS
""CONFIDENTIAL•"
X
Videotaped deposition of GHISLAINE
MAXWELL, taken pursuant to subpoena, was
held at the law offices of BOIES
SCHILLER a, FLEXNER, 575 Lexington
Avenue, New York, New York, commencing
April 22, 2016, 9:04 a.m., on the above
date, before Leslie Fagin, a Court
Reporter and Notary Public in the State
of New York.
22
GM_GLSDNY_00000124
EFTA00008737
Q.
Did Jeffrey Epstein have a scheme
to recruit underage girls for sexual
massages?
MR. PAGLIUCA: Objection to the
fcrm and foundation.
Q.
If you know.
A.
I don't know what you are talking
about.
23
GM_GJ_SDNY_00000125
EFTA00008738
List all the people under the age
of 18 that you interacted 0.rith at any of
Jeffrey's properties?
A.
I'm not aware of anybody that I
interacted with, other than obviously
who was 17 at this point?
24
CALGLSMY_00000126
EFTA00008739
July 22, 2016 Deposition
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
-against-
GHISLAINE MAXWELL,
Defendant.
x
Case No.:
15-cv-07433-RWS
"CONFIDENTIAL"
x
Continued Videotaped Deposition of
GHISLAINE MAXWELL, the Defendant herein,
taken pursuant to subpoena, was held at
the law offices of Boies, Schiller &
Flexner, LLP, 575 Lexington Avenue, New
York, New York, commencing July 22,
2016, 9:04 a.m., on the above date,
before Leslie Fagin, a Court Reporter
and Notary Public in the State of New
York.
25
GM_GLSDNY_000001 27
EFTA00008740
Q.
Were you awar
of the presence of
sex toys or devices used in sexual activities
in Mr. Epstein's Palm Beach house?
MR. PAGLIUCA: Objection to form
and foundation.
A.
No, not that I recall.
Q.
Do you know whether Mr. Epstein
possessed sex toys or devices used in sexual
activities?
MR. PAGLIUCA: Objection to form
and foundation.
A.
No.
26
GM_Gl_SDN Y_00000I 28
EFTA00008741
Q.
Other than yourself and the blond
and brunette that you have identified as
having been involved in three-way sexual
activities, with whom did Mr. Epstein have
sexual activities?
MR. PAGLIUCA: Objection to form
and foundation.
A.
I wasn't aware that he was having
sexual activities with anyone when I was with
him other than myself.
Q.
I want to be sure that I'm clear.
Is it your testimony that in the 1990s and
2000s, you were not aware that Mr. Epstein
was having sexual activities with anyone
other than yourself and the blond and
brunette on those few occasions when they
were involved with you?
A.
That is my testimony, that is
correct.
27
GNI_GLSDN Y_00000129
EFTA00008742
Q.
Let's just tie that down. It is
your testimony that you've never given
anybody a massage?
A.
Q.
massage,
A.
I have not given anyone a massage.
You ne*r gave Mr. Epstein a
is that your testimony?
That is my testimony.
Q.
You never gave
massage is your testimony?
A.
I never gave
massage.
a
a
2S
GM_GLSDN Y_00000 1 30
EFTA00008743
|
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