Text extracted via OCR from the original document. May contain errors from the scanning process.
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I would do three days before the arrest, so...
Sent from my iPhone
On Aug 9, 2020, at 7:32 PM,
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Ok. Not sure that's what we're going to do but will let you know tomorrow.
Sent from my iPhone
On Aug 9, 2020, at 7:17 PM,
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> wrote:
I> wrote:
No, it's three days. No mention of business. So technically three days would be Friday but as told to me at
least the thinking was dropping this Friday afternoon could be perceived as poor form, so we're gonna do late
Thursday instead.
Sent from my iPhone
On Aug 9, 2020, at 7:07 PM,
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> wrote:
Will confirm in morning. UMR is 3 business days no? And we'd want it ready to go upon sending umr
which would mean a draft about a day in advance.
Sent from my iPhone
On Aug 9, 2020, at 7:02 PM,
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I> wrote:
Laura said Thursday and late in the day. Can you confirm and let me know?
Sent from my iPhone
On Aug 9, 2020, at 6:58 PM,
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> wrote:
Ok. I think umr would go down to do on Wed so we'd want it in shape then.
Sent from my iPhone
On Aug 9, 2020, at 6:53 PM,
(USANYS)
I> wrote:
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They did. I haven't looked at it yet but will do and we can circulate before Thursday.
Sent from my iPhone
On Aug 9, 2020, at 6:51 PM,
Ok, understood.
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> wrote:
Did the team ever do a short form memo re WBTW in case we have to send something down?
Sent from my iPhone
On Aug 9, 2020, at 4:10 PM,
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wrote:
Okay. Among the timing pressures on this, I think we need to have a plan in place so we can make a
disclosure to the Court in connection with the first discovery deadline, which I believe is August 21.
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Some but still working on it.
has been swamped but I need to get his attention.
Sent from my iPhone
On Aug 6, 2020, at 6:47 PM,
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> wrote:
Have we made any progress on the plan on this?
Sent from my iPhone
On Aug 4, 2020, at 4:05 PM,
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> wrote:
Great, thank you.
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These are all the 302s from the Florida investigation. May want to just CTRL+F for Maxwell.
should be in there.
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And can you have someone send theM302 from FBI investigation?
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One of the difficulties in answering this question is that we don't have the pros memo. Here's what I've
been able to learn from what we do have:
We do have the transcripts of their grand jury testimony (although not the AUSA preamble). She is not
mentioned in the introductory part of the agent's testimony where the are walking through the various
targets and subjects of the investigation. By contrast, Epstein,
and l
are (pp. 5-6).
In fact, she only comes up once in the entire grand jury presentation, namely in the context of the
agent's summary of how
met Epstein. Specifically, the agent testifies as follows:
I'm sorry, the question you asked me was: How did they meet? They met by a friend of Mr.
Epstein's. Jane Doe Number One was working at Mar-a-Lago and a friend of Mr. Epstein's,
Ghislaine Maxwell.
Would you like the spelling?
THE REPORTER: Yes, please.
THE WITNESS: G-H-I-S-L-A-I-N-E, Maxwell, who was a friend of Mr. Epstein, met Jane Doe
Number One at Mar-a-Lago and Jane Doe Number One soon after began working and providing
massages for Mr. Epstein
The fact that she has to spell it strongly suggests the name also didn't come up during whatever
preamble the AUSA provided. But either way, that's it.
As you know, she is not mentioned in the NPA and, according the lawyer at OPR who is running the NPA
investigation, Maxwell does not come up much, if at all, in the documents they have reviewed in
connection with that issue.
There were no federal search warrants, so there would be no applications in which target subjects would
be identified. There was a local search warrant, but we don't have a copy because we don't have the
SDFL file and we haven't asked Palm Beach county for theirs. Presumably we will get that at some point.
Maxwell was added to the caption of the FBI file at some point, and she does come up in some of the
302s (including the
and
interviews in a manner we're now familiar with).
That said, we have the FBI file, including all of their 302s, and we plan to produce those.
I think the proposal to get the physical file from SDFL makes sense and is manageable. We'll have to
work through how to do that, but OPR has at least some of that material which we could get quickly and
start with (including the pros memo), and once we figure out how to get the rest, 24 boxes of material is
a doable project.
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Thanks — yes, having an understanding of how (if at all) Maxwell fits into the Florida evidence and
investigation (beyond just the simple view that she wasn't the focus) would be helpful.
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Asking the team to look into this. We don't have their pros memo (although OPR does and if we wanted
to make a more targeted ask, we could conceivably start with that). We do have the one (state) search
warrant application for the Palm Beach residence, team will check that now. Team is not aware of any
other search warrant applications done as part of the SDFL investigation, but will take a look to confirm.
We also have the grand jury testimony and I'm asking team to confirm that Maxwell was not mentioned
in that testimony.
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Subject:
Do you know, or can you find out, whether Maxwell was identified as a target / subject / target subject or
whatever the lingo may have been in any warrants or other materials from the SDFL case, to the extent
we know?
Counsel to the Acting U.S. Attorney
United Stotes Attorney's Office
Southern District of New York
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