From: "Bourtin, Nicolas" MIN
Summary
From: "Bourtin, Nicolas" MIN NIIMMMIM To: ' Cc: "Seaman, Gillian P." Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED Date: Thu, 21 Nov 2019 23:39:15 +0000 Perfect. Thanks. From: Sent: Thursday, November 21, 2019 6:38 PM To: Bourtin, Nicolas Cc: Seaman, Gillian P. Subject: (EXTERNAL] RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED Can we plan for 4:30pm tomorrow? Happy to call you, just let me know the best number. Thanks, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 From: Bourtin, Nicolas Sent: Thursday, November 21, 2019 5:05 PM To: Cc: Seaman, Gillian P. • Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED Thanks, Would tomorrow 9-10 am or after 4 pm work? If not, we can look for times next week. Nic From: Sent: Thursday, November 21, 2019 3:39 PM To: Bourtin, Ni
Persons Referenced (4)
“...ending you those statements tonight), there is another account associated with Richard Kahn. This one is in the name of "JSC Interiors LLC," and Kahn is the authorized si...”
United StatesUnited States AttorneyThe author“...with Richard Kahn. This one is in the name of "JSC Interiors LLC," and Kahn is the authorized signer. Can you let us know if you'd like us to produce the statements for that account and hold it open...”
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EFTA DisclosureRelated Documents (6)
To: "Bourtin, Nicolas" czl
From: To: "Bourtin, Nicolas" czl Cc: "Seaman, Gillian P." Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED Date: Thu, 21 Nov 2019 20:39:02 +0000 Hi Nic, This is to confirm that TD can close out the accounts referenced in our prior hold-open letter. We are no longer requesting that the accounts remain open. Thank you very much for your assistance. In connection with our ongoing investigation, we are planning to subpoena records from other TD accounts related to Epstein. Would you be available for a call to discuss in the next few days? Thanks, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 From: Bourtin, Nicolas Sent: Wednesday, November 20, 2019 2:06 PM To: Cc: Seaman, Gillian P. Subject: RE: October 3, 2019 Grand Jury Subpoena to . CONFIDENTIAL TREATMENT REQUESTED Following up on our call on Friday, I just wanted to check in on the government's timing. Please
Thursday, May 21, 2020
Thursday, May 21, 2020 VIA EMAIL ONLY: OFFICE OF THE LIEUTENANT GOVERNOR OFFICE OF GENERAL COUNSEL by -,Esq. District Court of the Virgin Islands 55O0 Veteran's Drive, rd Floor St. Thomas, VI 00802 RE: Response to Subpoena (2020R00037 - 003): Southern Country International Dear Attorney The Office of the Lieutenant Governor, Division of Banking, Insurance and Financial Regulation ("Division") received a subpoena dated April 7, 2020, from the District Court of the Virgin Islands to provide any and all documents pertaining to Southern Country International Ltd. ("SCI" or "the Company"). The Division's response is to include his applications, renewals and associated documents submitted by SCI to obtain the approval to operate as an International Financial Services Entity ("IFSE") formerly known as an International Banking Entity ("IBE"). SCI was licensed on December 22, 2014 to conduct the statutorily permissible activities outlined in 9 V.I.C. § 726 of transaction•re
FD-302 (Rcv. 5-8-10)
FD-302 (Rcv. 5-8-10) -1 of 15- 7111 111(111A: no UNCLASSIFIEDHFOUO FEDERAL BUREAU OF INVESTIGATION AMANDA KIRBY[KIRBY], date of birth (DOB) WEBEX conference b FBI S•ecial A•ents and of the United States Attorneys Office. Also present for the interview were Barry Pollack and Carolyn Forstein, of ROBBINS RUSSELL. After being advised of the identity of Date of entry 08/23/2021 was interviewed via and the interviewers and the nature of the interview, KIRBY provided the following information: KIRBY'S Background information- KIRBY worked at Universal Music group as an assistant to the CFO of corporate finance prior to starting at DEUTSCHE BANK [DB]. KIRBY eventually wanted to leave that role and applied to DB. KIRBY never worked at a bank prior to starting at DB. KIRBY could not recall the precise details regarding the training she received when she started at DB. KIRBY recalled attending an onboarding session that included an overview of the bank when she started. Re
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-2413, Document 40, 08/20/2020, 2913550, Page2 of 74 Table of Contents Table of Authorities iii Introduction 1 Jurisdictional Statement 2 Issues Presented 3 Statement of the Case and the Facts 3 The defamation action and the Protective Order 3 The motion to unseal and the first appeal 6 The remand, the arrest,
Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44
Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the unsealing of the Sealed Items contained in: • DE 143 (and related DEs 142, 144, 144-1, 149, 150, 150-1, 151, 152, 153, and 153- 1); • DE 172 (and related DEs 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211, 212, 212-1, and 224) and; • DE 199 (and related DEs 200, 200-1, 228,2 29,
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
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