Epstein Data Wiki

NBCUniversal

Properties2
tagsentity, press, unsealing, media-intervenor, southern-district-of-new-york, palm-beach, davis-wright-tremaine, new-york
aliasesNBC Universal, NBCUniversal News Group, NBCUniversal Media, LLC, NBC News (NBCUniversal News Group)

28 min read

Corporate names used in the releaseNBCUniversal Media, LLC as a signatory and as a movant12; NBCUniversal News Group (“NBC News”) as a represented party3; NBC Universal in a production signature block4
Where it appears as an actorSignatory to a media coalition letter in United States v. Ghislaine Maxwell, No. 20 Cr. 330 (AJN) (S.D.N.Y.), Dkt. 362, October 20, 202151; represented party on Dkt. 582 and Dkt. 587 in the same case, January 202236; one of the “Media Intervenors” in CA Florida Holdings, LLC v. Sharon Bock, Case No. 50-2019-CA-014681-AG (Fla. 15th Jud. Cir.), June 24, 20242
Counsel of record on its own letterNathan Siegel, Davis Wright Tremaine LLP, for ABC News and NBC News jointly78
What it asked for, January 2022That the Court refuse to seal the defendant’s motion for a new trial and its exhibits, and that a juror’s motion to intervene be unsealed3
How that application was docketedAs Dkt. 582, under a clerk’s banner reading “FILING ERROR – DEFICIENT DOCKET ENTRY – WRONG FILER” and a description reading “LETTER by USA”9
The correctionThe letter was re-dated, re-transmitted and entered by the clerk as Dkt. 587 on January 27, 2022610
A separate 2014 threadA location manager for the NBC series Odyssey asked to film the front door of 9 East 71st Street, was given permission for November 19, 2014, offered a $2,000 location fee, was asked to give it to charity instead, and was refused when the date moved11121314
What this page does not carryThe April 2015 Knick shoot, whose paperwork carries a spaced NBC Universal string that belongs to an assistant location manager’s previous show1516

NBCUniversal appears in the released Epstein files in two entirely separate capacities, and the release makes it easy to confuse them. In the first it is a news organisation that three times went to a court, twice federal and once state, to argue that Epstein-related material should be public. In the second it is a television production company that in the autumn of 2014 wanted to photograph a front door on the Upper East Side, and was told no.

Both are institutional acts, and both are documented. Newsgathering, meaning reporters and producers asking questions of public bodies, is not a decision of the kind this page anchors on, and this page makes no claim about it either way: the searches that would have measured any of it are among those the last section reports as unexhausted. A further, much larger body of hits on the company’s name is not about NBCUniversal at all; it is an assistant location manager’s stale email signature, and it is set out at the end of this page so that the next reader does not have to find that out twice.

October 20, 2021: joining seventeen news organisations on the jury

The first of the three court applications is not NBCUniversal’s own paper. On October 20, 2021, before jury selection in United States v. Ghislaine Maxwell, the Reporters Committee for Freedom of the Press wrote to Judge Alison J. Nathan on behalf of itself “and the 17 undersigned news media organizations”, urging the Court to deny the defendant’s request, made with the government’s consent, to file the parties’ joint proposed juror questionnaire and joint proposed voir dire under seal.5 The letter’s argument is that juror questionnaires attract the same presumption of openness as voir dire itself, and that “the party seeking to restrict press access bears a ‘heavy’ burden” which, the Reporters Committee writes, “the defense manifestly fails to carry”.17 The speculation it answers, though, is quoted from the government’s letter rather than from a defence filing. The sheet reads: “In an effort to justify the defendant’s request, the Letter speculates that ‘media coverage may prejudice the jury selection process.’ Letter 1.” On the first sheet’s own definition, “the Letter” is the “Letter of U.S. Att’y, October 12, 2021 (Dkt. No. 339)”, the paper by which the defendant’s request reached the Court.517 “Such conclusory speculation”, the letter goes on, “cannot overcome the deeply rooted presumption of openness applicable to voir dire.”17

The signatory list runs down the last sheet in two columns of nine and eight, which is seventeen, and seventeen is the number the letter’s own opening paragraph gives. NBCUniversal Media, LLC is the third entry in the right-hand column, between the National Press Club Journalism Institute and The New York Times Company; The Miami Herald and American Broadcasting Companies, Inc. head the left-hand column, in that order.1 The letter is subscribed with a conformed electronic signature: /s/Katie Townsend set in printed italic over a rule, with the name typed beneath. There is no ink on the sheet.17

The first of its interventions recorded here was therefore about jurors, and so was the second.

January 2022: the company’s own counsel, and a docket entry that named the wrong filer

In January 2022 Ghislaine Maxwell filed a motion for a new trial with supporting exhibits, as Dkt. 578, and sought to have them sealed.3 The Miami Herald objected in a letter entered on January 24 as Dkt. 581, and The New York Times in one entered on January 25 as Dkt. 583.18

On January 25, 2022 a four-sheet letter reached the Court from Nathan Siegel of Davis Wright Tremaine LLP8, opening: “I write on behalf of American Broadcasting Companies, Inc. (“ABC News”) and NBCUniversal News Group (“NBC News”) to join in the requests of The Miami Herald (Dkt. No. 581) and The New York Times to oppose the sealing of the motion for a new trial and supporting exhibits filed by the Defendant (Dkt. No. 578), for all the reasons set forth in those requests.”3 It then asked for something the Herald and the Times had not asked for: that a juror’s motion to intervene, which the Court’s earlier orders record as having been e-mailed to chambers and placed under temporary seal, “now be unsealed”, on the ground that it is a judicial document to which the common-law and First Amendment presumptions of access attach.3 The argument is developed over two further sheets on Lugosch, Amodeo I and Amodeo II, and closes: “For all these reasons, ABC News and NBC News respectfully request that the Court unseal Defendant’s motion for a new trial and Juror No. 50’s motion to intervene.”19

This is the anchor. Two broadcasters retained one firm and put a lawyer’s name on a paper in a federal criminal prosecution; that is an institutional decision, recorded in the instrument that carries it.

What the sheets themselves show. The letter is dated January 25, 2022 on its first sheet and transmitted “VIA ECF”; its running head on sheets 2, 3 and 4 reads “January 24, 2022”.320197 The ECF stamp across the top of every sheet reads Case 1:20-cr-00330-PAE, while the Re: line the firm typed reads USA v. Maxwell, No. 1:20-cr-00330-AJN. The letter is addressed to Judge Nathan, whose initials are the ones counsel typed; the same -PAE stamp sits across the October 2021 letter, which is also addressed to her.35 The subscription on sheet 4 is a conformed electronic signature: /s/ Nathan Siegel in printed type over a rule, the name typed again beneath, and the words “Attorneys for American Broadcasting Companies, Inc. and NBCUniversal News Group” in printed italic. No mark on that sheet is ink.7

And the docket entry does not say what the letter says. The Second Circuit record reproduces the district court docket sheet. Entry 582, dated 01/25/2022, opens with a clerk’s banner in blue capitals reading “FILING ERROR – DEFICIENT DOCKET ENTRY – WRONG FILER –”, and then describes the paper as “LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Nathan Siegel dated 1/25/2022 re: Letter from Nathan Siegel on behalf of American Broadcasting Companies, Inc., and NBCUniversal News Group … Document filed by USA. (Siegel, Nathan) Modified on 1/26/2022 (lb). (Entered: 01/25/2022)”.9

Two broadcasters’ application for access to a sealed record therefore entered the docket of a federal criminal case as a filing by the United States, twice over in the same entry, once as “LETTER by USA” and once as “Document filed by USA”, with the filing attorney’s own name in the parenthetical. The clerk modified the entry the following day.

The letter was then sent again, and it is not the same letter. A four-sheet letter with the same body, the same internal document number and the same running head of January 24 was re-dated January 26, 2022, its transmission line changed from “VIA ECF” to “VIA EMAIL AND FED EX”, and a copy line, “cc: Counsel of record (via email)”, added at the foot of the last sheet.621 The clerk entered it on January 27 as Dkt. 587, and the second entry reads simply “LETTER addressed to Judge Alison J. Nathan from Nathan Siegel dated 1/26/2022 … on behalf of American Broadcasting Companies, Inc and NBC Universal News Group (jw) (Entered: 01/27/2022)”. The words “by USA” and “Document filed by USA” are gone, and the entry is initialled by a clerk rather than by counsel.10

Read together, the two entries show one application entering the docket twice: once attributed to the United States, and two days later to the sender’s own clients. What the correction cost, on the face of these sheets, was a re-dated letter and a courier.

June 24, 2024: the Palm Beach grand jury materials

Two and a half years later the company appears in a Florida state court, in the long-running action by the publisher of The Palm Beach Post against the Clerk and Comptroller of Palm Beach County over the Epstein grand jury records. On June 24, 2024 an Unopposed Motion for Limited Intervention was e-filed on behalf of a bloc of national, regional and local broadcasters and publishers (American Broadcasting Companies, Inc.; Bloomberg L.P.; Cable News Network, Inc.; Court TV Media, LLC; Gray Media Group stations; NBCUniversal Media, LLC; The New York Times Company; Scripps Media stations; Telemundo Network Group LLC; Univision Networks & Studios, Inc. and others) who “(collectively, the “Media Intervenors”) move to intervene in this action for the limited purpose of asserting their right of access, pursuant to Section 905.27, Florida Statutes, to any released grand jury materials involving Jeffrey Epstein”.2

The motion recites that “the Fourth District Court of Appeals ordered release of the grand jury materials for an in camera review (which has been completed), and the current State Attorney was a party to this litigation and ultimately adopted a neutral position concerning disclosure”, and records in a footnote that the Court had already let the Associated Press in by an agreed order of February 28, 2024 and the McClatchy Company by another of March 5, 2024.22 It is subscribed /s/ Rachel E. Fugate for Shullman Fugate PLLC, again a conformed signature in printed type over a rule and not ink, with a certificate of service dated “this 24th day of June 2024”.23

For the earlier decisions in the same lineage, including the June 2009 motion by Palm Beach Newspapers, Inc., then the paper’s publisher, to intervene “for the limited purpose of seeking access to documents filed under seal”, see Unsealing decisions in the Epstein proceedings, on which none of the three applications set out here appears: that page was searched for both spellings of the company name and for the bare string NBC, for the three docket numbers given here, and for both case numbers in each of the forms in which they are printed, and it returns nothing for any of them. For the other newspaper publisher that used the same firm in a New York access application, see NYP Holdings, Inc..

The other NBCUniversal: a front door, a fee, and a refusal

On October 31, 2014 Amanda Foley, who signs herself “NBC Universal // “Odyssey” / Location Manager” at a Brooklyn production address, wrote asking to film at 9 East 71st Street. Her description of what she wanted is specific: “THE SCENE: We would need approximately 2 hours of filming. Our actor, playing an influential politician, leaves the building — that we would play as a high end men’s club — and has a conversation with two actors on the street. We would not require any equipment or crew to be inside — only the actor leaving the building.” The date sought was Thursday, November 19.114 The same message was forwarded to Jeffrey Epstein the day it was sent, under a covering line reading “Below re the movie and people who want to use your front door”.24

Permission came on November 3: “the owner of 9 East 71st Street has given permission for you to film his front door on Nov. 19th. Please coordinate with our house manager, Merwin Dela Cruz.”11 Fifteen minutes later Foley offered to pay: “Great!! Thank you …!! We would like to pay a location fee - I have $2000 budgeted for the actor coming out of the door. Is that something I can coordinate with you?”12

The answer took three days. On November 5: “Hi Amanda…I have not forgotten about you!! We are still figuring out who the $2000 check should be written to! Thanks for your understanding…”13 On November 6: “Hi Amanda…my employer would like you to donate the $2000 to a charity of your choice…”, to which Foley replied, “That’s wonderful! Thank you. Let me think about it and get back to you with some choices.”12

The shoot never happened. On November 10 Foley wrote that “We had a schedule change due to actor availability issues” and asked to move to November 25. On November 11 she was told “good morning Amanda…I am so sorry but the date of Nov. 25th will not work. My employer has said no…”, and on November 13, after a second attempt, “Hi Amanda. I’m truly sorry… I did ask again and the date of Nov 25 just will not work out. I hope you are able to find another location!” Foley closed the thread at 12:59:25 UTC that morning, which is 7:59 a.m. Eastern and seventeen minutes after the message she was answering, with “Ok—thank you for asking again.”14

The transaction the searches set out below returned is therefore one that did not complete: a $2,000 location fee, redirected to a charity of the production’s own choosing, for a shoot cancelled from the house’s side.

What this page does not say

The April 2015 shoot at the same address was not an NBCUniversal production. Of the 197 page rows carrying the spaced form “NBC Universal”, 134 also carry the surname of one assistant location manager or an OCR variant of it, and they sit in a thread five months later in which he signs every message “Assistant Location Manager / NBC Universal // “ODYSSEY” / C/O Broadway Stages”. That is a stale signature block, and his own opening sentence says so: “My name is Jose Guerrero and I recently worked with Amanda Foley on the TV show “ODYSSEY” I am currently working on a cable TV series titled “THE KNICK” staring Clive Owen.” The next sentence names Steven Soderbergh as the director.15 The file names point the same way. Two of them print at the foot of the last sheet of that run: “Photo Release 9 E 71st St_LocationAgreement.docx” and “HBO W-9.pdf”.16 The $5,000 that thread directs to a charity, and the $500 to the house manager, are not, on any document cited here, shown to be a payment by this company, and they are set out on other pages rather than on this one.25

A 2011 email chain among NBCUniversal film executives is not about Epstein. It reached his inbox because a producer forwarded it to him with a joke about his own new credit, and the subject throughout the chain is the purchase of a screenplay.26

A 2013 film-fund solicitation describes a Universal agreement it does not contain. An MSP Film Fund LLC commitment letter “As of May 1, 2013” in the files offers equity in a fund raising $275 million to co-finance “the next 100 consecutive motion pictures … released by the US major motion picture studio, Universal Pictures, a division of NBCUniversal, Inc.” under a Co-Financing and Distribution Agreement said to be dated July 14, 2012.27 Every field on its signature page is an empty rule: purchaser name, purchaser signature, date, the dollar amount, and the fund’s own execution line above its printed officer name. Nothing on it is signed and nothing on it is redacted.28 The exhibit that would show what Universal actually agreed is a single sheet reading “EXHIBIT B / UNIVERSAL PICTURES DEFINITIVE AGREEMENT / (Copy Sent Separately)”, and no agreement follows it.29

Nothing here is a finding of wrongdoing by any company or person named.

The searches run for this page

The corpus was searched with the FTS5 index over all productions for "NBCUniversal" (100 pages across 81 documents), "NBC Universal" (197 pages), "NBCUniversal News Group" (14 pages across 6 documents), "NBCUniversal Media, LLC" (8 pages across 8 documents), "NBC News" (927 pages), "MSNBC" (525 pages), "Comcast" (827 pages), "Nathan Siegel" (21 pages) and "Davis Wright Tremaine" (63 pages). Counts are of page rows, not documents, except where documents are stated. Every hit on the two spellings of the company name was read in context; the resolution of the large "NBC Universal" block is given above. "NBC News", "MSNBC" and "Comcast" were not exhausted and no claim is made about them.

Of the four Bates numbers under which the January 2022 letter sits, the two EFTA copies are cited here because they can be rendered. overlap_check.py was run on each identifier cited and on the two identifiers of the docket sheet; the case number 1:20-cr-00330 and the phrase 20 Cr. 330 were run against the published tree separately, because a filing in this release routinely carries more than one stamp and an identifier search cannot see that.

Timeline

DateEventSource
May 1, 2013MSP Film Fund commitment letter, unexecuted, describing a Universal slate agreement2728
Oct 31, 2014Odyssey film request sent; forwarded to Epstein the same day1124
Nov 3, 2014Permission given for November 19; $2,000 location fee offered1112
Nov 6, 2014Fee redirected: “donate the $2000 to a charity of your choice”12
Nov 11–13, 2014Date moved to November 25; “My employer has said no”; thread closed14
Oct 20, 2021NBCUniversal Media, LLC among 17 signatories opposing sealing of the juror questionnaire and voir dire, Dkt. 36251
Jan 25, 2022Letter for ABC News and NBC News filed; docketed as Dkt. 582 under “FILING ERROR … WRONG FILER” and described as “LETTER by USA”39
Jan 26, 2022Docket entry 582 modified; letter re-dated and re-sent “VIA EMAIL AND FED EX”96
Jan 27, 2022Same letter entered by the clerk as Dkt. 587, without the “by USA” wording10
Jun 24, 2024NBCUniversal Media, LLC among the Media Intervenors moving for access to Palm Beach grand jury materials2

Unsealing decisions in the Epstein proceedings; NYP Holdings, Inc.; Ghislaine Maxwell; 9 East 71st Street; Redacted filings; Maxwell trial exhibits; Darren Indyke; Lesley Groff.

Footnotes

  1. The signatory list, sheet 4. https://epstein-data.com/EFTA02833107 p.4. Read at the image at 400 dpi. The two columns carry nine and eight organisations respectively, seventeen in all, which matches the count in the letter’s own first paragraph. The same letter appears in this release under further Bates numbers, of which this one was used because it renders. ↩ ↩2 ↩3 ↩4

  2. “Unopposed Motion for Limited Intervention”, CA Florida Holdings, LLC, Publisher of The Palm Beach Post v. Sharon Bock, as Clerk and Comptroller of Palm Beach County, Florida, Case No. 50-2019-CA-014681-AG, Circuit Court of the Fifteenth Judicial Circuit, Palm Beach County, Florida, Filing # 201184781, e-filed 06/24/2024 01:09:07 PM, sheet 1. https://epstein-data.com/EFTA02737032 p.1. Read at the image at 400 dpi. The sheet carries a diagonal watermark reading “NOT A CERTIFIED COPY”. Two black blocks on this sheet cover parts of a corporate name and of an official’s name; nothing under them is used or supplied here. The machine reading of this sheet interleaves the caption with the clerk’s footer stamp and drops several movants; the list is taken from the image. ↩ ↩2 ↩3 ↩4

  3. Nathan Siegel, Davis Wright Tremaine LLP, to the Hon. Alison J. Nathan, USA v. Maxwell, No. 1:20-cr-00330-AJN, Document 582, filed 01/25/22, sheet 1. https://epstein-data.com/EFTA02836667 p.1. Read at the image at 400 dpi. The date line reads January 25, 2022 and the transmission line “VIA ECF”. The ECF stamp reads Case 1:20-cr-00330-PAE; the typed Re: line reads 1:20-cr-00330-AJN. The foot of the sheet carries the firm’s web address, which prints as DWT.COM, and its internal document number 4863-7911-5787v.1 0019918-000033; the machine reading of that number differs from the print and the print is used. Two solid black blocks, clean-edged at 400 dpi, stand in the letterhead immediately above the words “Tremaine LLP”. The cause of those blocks is not established, and this page does not assert that anything is withheld by them. The counsel telephone and email lines are not reproduced here. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  4. The same thread, sheet 3, carrying the sender’s signature block. https://epstein-data.com/EFTA00359056 p.3. Read at the image at 400 dpi. The block reads “Amanda Foley / NBC Universal // “Odyssey” / Location Manager” over a Brooklyn business address. A contact value in the block is covered and is not reproduced. Two further bars sit on this sheet, and the extraction closes both of them and drops words adjacent to them. ↩ ↩2

  5. Letter of the Reporters Committee for Freedom of the Press and seventeen news media organisations to the Hon. Alison J. Nathan, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), Document 362, filed 10/20/21, sheet 1. https://epstein-data.com/EFTA02833107 p.1. Read at the image at 300 dpi. The ECF stamp on this sheet reads Case 1:20-cr-00330-PAE. Black blocks on this sheet cover parts of personal names and of firm names; nothing under any of them is used or supplied here. ↩ ↩2 ↩3 ↩4 ↩5

  6. The same body of letter, Document 587, filed 01/27/22, sheet 1. https://epstein-data.com/EFTA02836681 p.1. Read at the image at 400 dpi. The date line reads January 26, 2022 and the transmission line “VIA EMAIL AND FED EX”; the internal document number is the same as on Document 582. This is therefore not a re-filing of an identical paper: the date and the transmission line differ, and a copy line is added on the last sheet. ↩ ↩2 ↩3 ↩4

  7. The same letter, sheet 4. https://epstein-data.com/EFTA02836667 p.4. Read at the image at 400 dpi. The running head reads “January 24, 2022 / Page 4”. Between “Sincerely,” and the printed capitals “TREMAINE LLP” stand two solid black blocks of the same kind as those in the letterhead of sheet 1; see the note there. The subscription is /s/ Nathan Siegel in printed type over a rule with the name typed beneath: a conformed electronic signature, not a manuscript one. There is no ink on the sheet. ↩ ↩2 ↩3

  8. The firm’s name prints in full, as “DAVIS WRIGHT TREMAINE LLP”, in the subscription to the “Notice of Motion to Unseal Appellate Briefs” filed for non-party movant NYP Holdings, Inc. in The People of the State of New York v. Jeffrey E. Epstein, App. Div. No. 6081 (N.Y. App. Div. 1st Dep’t), dated New York, December 21, 2018, with the names Robert D. Balin and John M. Browning typed beneath the By: rule. https://epstein-data.com/EFTA00806708 p.1. Read at the image at 400 dpi. The January 25, 2022 letter prints DWT.COM at the foot of its first sheet; the firm behind that web address is named here on that basis, which is this page’s identification and not a document’s statement. ↩ ↩2

  9. The same docket sheet, entry 582, dated 01/25/2022. https://epstein-data.com/EFTA02844213 p.181. Read at the image at 300 dpi. The banner is printed in blue capitals and uses spaced en dashes, which are reproduced as printed. The machine reading of this page destroys the docket numbers in this column; the numbers are taken from the image. This docket also exists in the release under a second Bates number that cannot be rendered, and this copy is page-aligned with it. ↩ ↩2 ↩3 ↩4

  10. The same docket sheet, entries 586, 587 and 588. https://epstein-data.com/EFTA02844213 p.182. Read at the image at 300 dpi. Entry 587 gives the company’s name with a space, as “NBC Universal News Group”, where entry 582 gives it without one. ↩ ↩2 ↩3

  11. Email thread, subject “Re: ODYSSEY - NBC Universal - Film Request”, sheet 2, carrying the messages of November 3, 2014 at 10:16 a.m. and October 31, 2014 at 2:08 p.m. https://epstein-data.com/EFTA00359056 p.2. Read at the image at 400 dpi. Five values on this sheet are covered by black bars, all of them names or contact values, and the extraction closes every one of those gaps, so a reader working from the text layer alone would not know the bars are there. Nothing under any of them is used or supplied here. The house manager’s name and role are quoted as the sheet gives them. ↩ ↩2 ↩3 ↩4 ↩5

  12. The same thread as continued, subject “Re: ODYSSEY - NBC Universal - Film Request”, dated Thu, 06 Nov 2014 21:34:06 +0000, sheet 1, carrying the messages of November 6 at 4:20 p.m. and 4:32 p.m. and of November 3 at 10:31 a.m. https://epstein-data.com/EFTA00359497 p.1. Read at the image at 400 dpi. Black bars on this sheet cover names, sign-offs and address values; nothing under them is used or supplied here. The ... marks inside the message of November 6 at 4:20 p.m. are the writer’s own. ↩ ↩2 ↩3 ↩4 ↩5

  13. The same thread, dated Wed, 05 Nov 2014 16:27:37 +0000, sheet 1. https://epstein-data.com/EFTA00359286 p.1. Read at the image at 400 dpi. The extraction of this sentence garbles the words “about you” and the sheet is used. Black bars on this sheet cover names and address values. ↩ ↩2

  14. The same thread, dated Thu, 13 Nov 2014 12:59:25 +0000, sheet 1, carrying the messages of November 13 at 7:42 a.m., November 12 at 8:48 a.m., November 11 at 9:31 a.m. and November 10 at 2:02 p.m. https://epstein-data.com/EFTA00359056 p.1. Read at the image at 400 dpi. The top-of-message Date: field carries an explicit +0000 offset, so the zone is stated rather than inferred; the in-thread times are local, and 12:59:25 UTC on 13 November 2014 is 7:59 a.m. Eastern Standard Time, seventeen minutes after the 7:42 a.m. message being answered. Black bars on this sheet cover names, sign-offs and address values; nothing under them is used or supplied here. ↩ ↩2 ↩3

  15. Jose Guerrero, “Scout 9 east 71st Street”, Tue 4/7/2015 3:05:27 PM, sheet 1. https://epstein-data.com/EFTA02080848 p.1. Read at the image at 400 dpi. The quotation is given as the sheet prints it, including “staring”; the sheet also doubles several word spaces, which are not reproduced here, and prints a film title elsewhere on it as “ERIN BROCKOFICH”. Its signature block gives the show as “ODYSSEY” while its body gives the current production as “THE KNICK”. Black bars on this sheet cover address values, a name and contact values; nothing under them is used or supplied here. This is a one-sheet run, which makes any pin to it structurally untestable by page displacement. ↩ ↩2

  16. The same run, sheet 4, the last sheet, carrying two file names at its foot. https://epstein-data.com/EFTA02080633 p.4. Read at the image at 400 dpi. They print as “Photo Release 9 E 71st St_LocationAgreement.docx” and “HBO W-9.pdf”; the doubled word space in the first is on the sheet and is not reproduced in the body of this page. Which message in the chain they hang from is not stated on the sheet and is not asserted here. Black bars on this sheet cover a sender value and a contact value; nothing under them is used or supplied here. ↩ ↩2

  17. The same letter, closing argument and subscription, sheet 3. https://epstein-data.com/EFTA02833107 p.3. Read at the image at 300 dpi and again at 400 dpi. The italic on may inside the phrase quoted from the Letter is as the sheet prints it, and the machine reading of this sheet prints Letter I. where the sheet prints Letter 1.; the sheet is used. The subscription is a conformed electronic signature: /s/Katie Townsend set in printed italic over a rule with the name typed beneath. There is no ink on the sheet. ↩ ↩2 ↩3 ↩4

  18. District court docket sheet in United States v. Maxwell, as reproduced in the Second Circuit record, entries 580, 581 and 583. https://epstein-data.com/EFTA02844213 p.181. Read at the image at 300 dpi. Entry 581 is the Miami Herald letter of Christine N. Walz, Sanford L. Bohrer and Cynthia A. Gierhart dated 1/21/22, entered 01/24/2022; entry 583 is the letter of David E. McCraw dated 1/24/2022, entered 01/25/2022. ↩

  19. The same letter, sheet 3, including the closing request. https://epstein-data.com/EFTA02836667 p.3. Read at the image at 400 dpi. The running head reads “January 24, 2022 / Page 3”. The machine reading of the closing sentence prints “masons” where the sheet prints “reasons”; the sheet is used. ↩ ↩2

  20. The same letter, sheet 2. https://epstein-data.com/EFTA02836667 p.2. Read at the image at 400 dpi. The running head reads “January 24, 2022 / Page 2”. Nothing on this sheet is covered. The corpus row for this sheet also carries a transcript of sheet 4 appended to it, which is an artefact of the extraction and is not on the sheet. ↩

  21. The same letter, sheet 4. https://epstein-data.com/EFTA02836681 p.4. Read at the image at 400 dpi. The running head again reads “January 24, 2022 / Page 4”. The subscription is again a conformed /s/ Nathan Siegel over a rule with the typed name beneath, with no ink; the same two black blocks precede “TREMAINE LLP”; and the foot of the sheet carries “cc: Counsel of record (via email)”, which the January 25 version does not. ↩

  22. The same motion, sheet 3, paragraph 5 and footnote 1. https://epstein-data.com/EFTA02737032 p.3. Read at the image at 400 dpi. The sheet prints “Fourth District Court of Appeals” and “[DIN 183]” and “[DIN 187]” as quoted, and carries the same diagonal watermark. The machine reading of this sheet is heavily disordered and the text is taken from the image. One value on this sheet is covered by a black block; nothing under it is used or supplied here. ↩

  23. The same motion, sheet 4, subscription and certificate of service. https://epstein-data.com/EFTA02737032 p.4. Read at the image at 400 dpi. The subscription is /s/ Rachel E. Fugate in printed italic over a rule with the name typed beneath — a conformed signature, not ink. Counsel email addresses print on this sheet and are not reproduced here. ↩

  24. Forward of the same request, subject “Fwd: ODYSSEY - NBC Universal - Film Request”, to Jeffrey Epstein, dated Fri, 31 Oct 2014 18:14:43 +0000, sheet 1. https://epstein-data.com/EFTA00359522 p.1. Read at the image at 400 dpi. A sender value on this sheet is covered. The sheet prints an email address, which is not reproduced here. ↩ ↩2

  25. The same run, sheet 1, Thur 4/16/2015 3:06:15 PM, subject “Re: Jeffrey Epstein”, carrying the $5,000 and $500 figures. https://epstein-data.com/EFTA02080633 p.1. Read at the image at 400 dpi. The sender value on the message carrying those figures is covered by a black bar, and no name is supplied for it here. The transmission of the signed agreement and the W-9 is a different message by a different person: the sheet prints, in the clear, a message it times at 10:29 a.m. the same day reading “Attached please find a PDF of the signed Agreement and W9.”, over a signature block in printed type giving Bebe Avdiu, Legal Assistant, Darren K. Indyke, PLLC. ↩

  26. Barry Josephson, “Fw: Update”, Fri 3/4/2011 6:02:48 PM, forwarding a chain among named NBCUniversal executives of 3 March 2011, sheet 1. https://epstein-data.com/EFTA01836684 p.1. Read at the image at 300 dpi. Black bars cover the address values throughout the chain; the extraction of this sheet prints “Sam” where the sheet prints “8am”. The subject matter throughout is the purchase of a screenplay. ↩

  27. “MSP FILM FUND LLC / COMMITMENT LETTER / As of May 1, 2013”, sheet 1. https://epstein-data.com/EFTA01134802 p.1. Cited from the extraction and not verified at the image; the two sheets of this document on which a field state is asserted were rendered and are cited separately below. ↩ ↩2

  28. The same document, “Signature Page to Commitment Letter”, sheet 7. https://epstein-data.com/EFTA01134802 p.7. Read at the image at 300 dpi. Purchaser name, purchaser signature, date, legal form, jurisdiction, address, the equity amount and the fund’s own By: line are empty rules: unsigned and uncompleted, with nothing covered anywhere on the sheet. The fund’s officer name and title are printed type beneath its empty rule. ↩ ↩2

  29. The same document, sheet 29. https://epstein-data.com/EFTA01134802 p.29. Read at the image at 300 dpi. The sheet carries three printed lines and nothing else: “EXHIBIT B”, “UNIVERSAL PICTURES DEFINITIVE AGREEMENT” and “(Copy Sent Separately)”. The agreement is absent from the run by the document’s own design; nothing on the sheet is covered. ↩

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