Epstein Data Wiki

Cyrus R. Vance Jr.

Properties2
tagsperson, prosecutor, new-york, sora, unsealing, appellate-division-first-department, dany
aliasesCyrus Vance, Cyrus Vance Jr., Cyrus R. Vance, Jr., Cy Vance, District Attorney of New York County

48 min read

OfficeDistrict Attorney of New York County. The released files carry his name in the form the office prints it: “CYRUS R. VANCE, JR., ESQ., / New York County District Attorney / One Hogan Place” on the 2011 hearing transcript’s caption, the slashes standing for its line breaks, and “CYRUS R. VANCE, JR. / District Attorney / New York County” on the cover and in the signature block of the People’s appellate brief123
⚠ Not the Vice PresidentA different person. For J.D. Vance, see J.D. Vance, whose page carries the disambiguation this page answers
The proceedingPeople of the State of New York against Jeffrey Epstein, Indictment No. 30129/2010, a Sex Offender Registration Act risk-level proceeding in the Supreme Court, New York County. His office appeared for the People at the hearing of January 18, 2011 before Justice Ruth Pickholz14
⚠ Who actually appearedJennifer Gaffney, Assistant District Attorney. The transcript names her and no other lawyer for the People, and nothing cited here places him in the courtroom or records a decision he personally took14
The appealPeople v. Epstein, App. Div. No. 6081 (1st Dep’t). The Brief for Respondent was filed in his name in August 2011, with Assistant District Attorneys Gina Mignola and Deborah L. Morse of counsel; the First Department affirmed on November 17, 2011, naming him as counsel for respondent235
What his office asked Florida forTwo letters on his letterhead, dated May 6 and July 15, 2011 and signed by Assistant District Attorney Deborah L. Morse, asking the U.S. Attorney’s Office for the Southern District of Florida for the federal grand jury transcript and then for the signed non-prosecution agreement “including the list of victims”67
The unsealing objection”Affirmation in Response to Motion” of December 28, 2018, signed by Assistant District Attorney Karen Friedman Agnifilo, “of counsel to CYRUS R. VANCE, JR, District Attomey of New York County”. The New York Post’s publisher withdrew its motion in response to it89
His own recorded answerThrough his office and, on one account, in his own words: that the position taken at the hearing was a mistake made by the assistant district attorney without his knowledge101112
Not established hereNo document cited on this page records him personally appearing in the proceeding, signing a filing in it, giving an instruction about it, or meeting or corresponding with Jeffrey Epstein

Cyrus R. Vance Jr. was District Attorney of New York County from January 2010 to the end of 2021.13 He is a subject of this wiki because his office acted on the record in two Epstein matters that the released files document in full: the New York sex-offender registration proceeding People v. Epstein and the appeal from it, and the 2018 to 2019 motion by the publisher of the New York Post to unseal the briefs filed on that appeal, which his office opposed.

⚠ He is a living named public official, and the discipline of this page is that an office is not a person. Everything below is an act recorded in a document: an appearance, a letter, a brief, an affirmation, a statement given to a reporter. Where the record names an assistant district attorney rather than him, the assistant district attorney is named and the act is not promoted. Nothing here is a finding of wrongdoing, and no document cited here charges him with anything or makes an allegation against him.

Two things this page does not do. It does not carry the substance of the January 18, 2011 hearing or of the appellate holdings, which are set out at Ruth Pickholz; and it does not carry the New York Post publisher’s side of the unsealing motions, which is set out at NYP Holdings, Inc.. The federal and Palm Beach unsealing decisions are at Unsealing decisions in the Epstein proceedings, which does not carry this New York state appeal. This page carries what his office did.

The proceeding, and the document that preserves it

The record of the hearing reached the released files inside a federal wrapper, and the two documents must be kept apart. Sheet 1 of the run is a one-page order of Judge Richard M. Berman in United States v. Epstein, No. 19 Cr. 490 (RMB), dated New York, July 15, 2019: “The Clerk is respectfully requested to docket the enclosed documents which were discussed at today’s bail hearing.”14 Sheet 2 is the caption of the document enclosed, which is a transcript of a hearing eight years earlier in a different court.1

That caption reads “SUPREME COURT / NEW YORK COUNTY / TRIAL TERM / PART 66”, gives the parties as “THE PEOPLE OF THE STATE OF NEW YORK” against “JEFFREY EPSTEIN” under “INDICTMENT # 30129/2010”, the place as 111 Centre Street, New York, the date as January 18, 2011, and the judge as “HONORABLE RUTH PICKHOLZ / Justice of the Supreme Court”. Under “APPEARANCES” it prints, for the People, “CYRUS R. VANCE, JR., ESQ., / New York County District Attorney / One Hogan Place / New York, New York 10013 / BY: JENNIFER GAFFNEY, ESQ. / Assistant District Attorney”, and for the defence a firm the sheet renders “KIRKLAND & ELLI, LLP” by Jay Lefkowitz and Sandra Musumeci.1

So the office is named as the party’s attorney and a named assistant district attorney is named as the lawyer who appeared. On the next sheet the clerk calls the case and she identifies herself: “MS. GAFFNEY: Jennifer Gaffney for the People.”4 She is the only lawyer for the People who speaks anywhere in the transcript, and the position she took, the exchanges with the court about it and the court’s ruling are set out at Ruth Pickholz. His name appears on one sheet of the eighteen in this run, the caption, and nothing on any of them places him in the courtroom or records an instruction from him.

The appeal, and the brief filed in his name

Epstein appealed the level three adjudication to the Appellate Division, First Department, as App. Div. No. 6081. On the appeal the office changed the position it had taken at the hearing, and the document that records the change is a brief filed in Vance’s name.

The Brief for Respondent carries on its cover “CYRUS R. VANCE, JR. / District Attorney / New York County / Attorney for Respondent / One Hogan Place”, with “GINA MIGNOLA” and “DEBORAH L. MORSE”, Assistant District Attorneys, below it.2 Its last page closes: “In sum, the decision of the SORA court is absolutely correct. There is no legitimate basis for complaint about either the form or content of that determination.” Under the heading “CONCLUSION” it asks for one thing: “The judgment of conviction should be affirmed.” It is then subscribed “Respectfully submitted, CYRUS R. VANCE, JR. / District Attorney / New York County”, over the two assistants’ names and the date “August 2011”.3 The brief’s own account of why the People had argued for level one below, and the passages Epstein’s brief attacked, are at Ruth Pickholz.

One footnote in that brief matters for what follows, because it is the place where the material the office had been collecting from Florida surfaces. Answering Epstein’s request that the First Department recalculate his points or remand for the parties to present evidence, footnote 7 says that on such a remand “the People will have an opportunity to correct any misimpressions left by defendant, and to provide instead a complete and accurate picture of the circumstances that gave rise to the two single-count accusatory instruments dated fully two years apart.” It then says what that picture would consist of:

The People’s evidence on remand would include proof that defendant had engaged in aggressive negotiations with the Palm Beach State’s Attorney’s Office even before indictment; that, after the State’s Attorney’s Office obtained a single-count indictment, Florida federal authorities convened their own grand jury investigation; and that defendant entered into a federal non-prosecution agreement with the United States Attorney of the Southern District of Florida, under which he agreed to plead guilty to an additional state felony charge that carried a consecutive jail sentence and required registration as a sex offender.15

That is a statement of what the People would prove on a remand, not evidence in the record, and the First Department did not remand.

Both sides asked to argue the appeal. A single-sheet “ORAL ARGUMENT TIME REQUEST” for the September 2011 term records that “[t]he attorneys for the parties in this appeal have consulted pursuant to Rule § 600.11(0 of this Court, and desire to argue. Appellant requests fifteen (15) minutes. Respondent requests fifteen (15) minutes.” It gives “Deborah Morse / New York County District of Attorney’s Office / One Hogan Place” as attorney for respondent; the misprinted rule reference and the transposed firm name are the sheet’s.16

The First Department decided the appeal on November 17, 2011. Its report names counsel in one line: “Cyrus R. Vance, Jr., District Attorney, New York (Deborah L. Morse of counsel), for respondent.” The disposition of Justice Pickholz’s order is that it was “unanimously affirmed, without costs.”5 The holdings are at Ruth Pickholz.

What the office asked Florida for, May to August 2011

The densest documented sequence involving his office is not the hearing but the four months after it, when the office set about getting the federal file on Epstein from the prosecutors who had made the 2008 non-prosecution agreement. It is documented from both ends: the letters the office sent, and the internal emails and notice letters the U.S. Attorney’s Office for the Southern District of Florida generated in response.

May 6, 2011. A letter on the letterhead of the “DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK”, carrying Vance’s name and signed “Deborah L. Morse / Assistant District Attorney”, went to an Assistant United States Attorney at the West Palm Beach office. It opens: “As I explained during our telephone conversation last week, I am currently working on an appeal brought by defendant Jeffrey Epstein.” It then recites the Florida history: “The underlying sexual misconduct at issue was the subject of an investigation and/or prosecution by your Office, as well as the Florida State’s Attorney Office in Palm Beach County.” Then it makes the request: “I know that you handled the matter on behalf of your office when the case was presented to the federal grand jury. Those grand jury proceedings would be of assistance to us in fashioning our response on appeal, and I would appreciate it if you would send us a transcript of those proceedings.” It adds a proposal about what would happen to the minutes: “If we furnish the minutes to the appellate court, we would do so under seal for the purpose of an in camera review.”6

May 12, 2011. An internal email inside the Southern District of Florida, headed “Inquiry from Manhattan DA’s Office re Epstein”, reports the approach to colleagues. The writer begins: “I got a call last week right as I was leaving for the funeral from Deborah Morse in the appellate division at the Manhattan DA’s office.” The email then sets out what was asked for: “Ms. Morse has asked us for a copy of the signed NPA, a list of the victims in our case, and a copy of the transcript of the state plea proceedings. She also was going to talk to her supervisor about possibly asking to get a copy of our grand jury transcripts.” The writer adds, of the list, “I told her that our list of victims (the list we provided to Epstein) has never been made public.” Then comes a sentence that does not sit easily with the letter dated six days earlier: “I had expected Ms. Morse to put her request in a formal letter, but I haven’t received one.” The email closes with the writer’s own view: “In any event, before we turn this over, I think that we need to advise Epstein’s counsel of the request, at least with regard to the NPA, which is still confidential by its terms.”17 Nothing cited here resolves that gap. A letter dated May 6 and a federal prosecutor writing on May 12 that no formal letter had arrived cannot both be a complete account of the transmission, and this page does not choose between them.

July 15 to 17, 2011. A second letter on the same letterhead, again signed by Morse, narrows the request to one document: “The non-prosecution agreement between defendant and your Office would be of assistance to us in fashioning our response on appeal. I would appreciate it if you would send us a copy of that agreement, including the list of victims.”7 The copy in the release that carries the office’s own fax coversheet is addressed in the salutation to “Dear Ms. Villafalia,” which is how this extraction renders the surname of Assistant United States Attorney A. Marie Villafaña; the other copies black the name out.18 The federal side dates its receipt to July 17.19

July 19, 2011. The U.S. Attorney’s Office began giving Epstein the notice the agreement required. A letter to Roy Black recites: “On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement.” It then states the authority and the deadline: “Pursuant to 5 U.S.C. § 552a(b) (7), the Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at the close of business on Thursday, July 21, 2011.” It closes: “Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure.”19 Two letters dated July 19 are in the release and they do not say the same thing: a second version gives the time as “5:00 p.m. on Thursday, July 21, 2011” rather than the close of business.20 An internal email timed 01:30 UTC on July 20, which is the evening of July 19 in Florida, shows how the request was being classified inside the federal office. Under the subject “FOIA Request” it says: “I received the attached letter from an Assistant District Attorney in New York regarding the investigation of Jeffrey Epstein. She is asking for two discrete items that she needs to prepare her response to an appeal of his sex offender registration status in New York, which is directly related to these items. I have prepared the attached letter to Mr. Epstein’s counsel regarding Section 552.”21

July 21, 2011. The letter actually sent to Black on that date drops the statute. It reads: “Pursuant to the District Attorney’s request, the U.S. Attorney’s Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011.” Morse is on its copy line.22 An internal email of the same day, transmitting a revised draft, records that the change was made on a recommendation “removing the reference to the Privacy Act”; the sheet’s text layer prints the short message’s lines out of order and does not legibly give the name of whoever recommended it.23

July 22, 2011. Epstein’s counsel Martin G. Weinberg objected, by letter to Villafaña. He wrote: “Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York.” He went on: “We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA.” He added a second ground: “Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order.” The hyphens standing where dashes would be are the sheet’s.24

July 27, 2011. The U.S. Attorney’s Office answered Weinberg and overruled him. It confirmed that it had held off: “In order to review and address the objections that you raised in that letter, the Office deferred making its planned disclosure to the District Attorney of the County of New York of the Non-Prosecution Agreement (‘Agreement’) and the list of identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after completing a full review of your objections, the Office still intends to proceed with the planned disclosures.” On the character of the New York request it said this, and it is the only place in the material cited here that records a commitment given by his office:

Here, moreover, the District Attorney of the County of New York, as a local law enforcement agency, has provided a legitimate request for disclosure of the requested information, as well as a promise to maintain the confidentiality of the information … 25

The clause the ellipsis stands for names the category of information the promise was said particularly to cover, which is the complainants’ names, and it is left out here rather than quoted because of the rule this wiki applies to that language.25

On the grand jury objection it held: “The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney’s Office will not violate Rule 6(e).” It then set a fresh deadline: “Otherwise, seeing no obstacle to the previously-planned disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New York at 5:00 p.m. on July 29, 2011.”26 The promise of confidentiality is the federal office’s characterisation of what his office had said. No document cited here contains the promise itself, in the office’s own words, and none records what the office proposed to do with the list.

August 15, 2011. The last letter in the sequence runs the other way. On the same letterhead, again signed by Morse, it says: “Pursuant to our conversation, I have enclosed copies of the brief and appendix filed by defendant Jeffrey Epstein on appeal, as well as a copy of our brief in response.” It ends with one line: “I look forward to hearing your opinion.”27

What this sequence does not establish. No document cited here shows that the non-prosecution agreement or the victim list was in fact delivered on July 29 or at all; that the federal grand jury transcript, asked for on May 6, was ever produced or refused; that Weinberg supplied the further authority the July 27 letter invited before its deadline; that the Florida prosecutor answered the August 15 invitation to give an opinion on the briefs; or that Vance personally knew of, approved or directed any of it. The letters are signed by an assistant district attorney and carry his name only as the office’s.

The unsealing motion, December 2018 to March 2019

Seven years later the sealed briefs became the subject of a motion, and here his office was the respondent to somebody else’s application rather than the applicant.

The direction of the motion. NYP Holdings, Inc., publisher of the New York Post, moved the Appellate Division as a non-party on December 21, 2018 for an order unsealing both parties’ briefs on the 2011 appeal with victims’ names redacted. His office opposed. Epstein’s own counsel did not.928

The filing. The opposition is an “Affirmation in Response to Motion” whose cover sheet carries “CYRUS R. VANCE, JR. / District Attomey / New York County / One Hogan Place” with “Karen Friedman Agnifilo / Assistant District Attomey / Of Counsel” beneath, and whose first paragraph opens: “I am an Assistant District Attorney, of counsel to CYRUS R. VANCE, JR, District Attomey of New York County, and I submit this affirmation on behalf of the People in response to a motion filed by non-party movant NYP Holdings, Inc.”829 It was dated at New York on December 28, 2018 and signed above the typed name.30 Its two grounds were that the newspaper had not given the notice New York Civil Rights Law § 50-b requires and that the offices entitled to that notice were the prosecuting agencies in Florida, and that the office could not agree to production of its own brief even with victims’ names redacted, though it would not oppose a redacted production if the court were inclined to grant the motion. Those grounds are set out in full, with the affirmation’s own words, at NYP Holdings, Inc..31

What the filing produced. The newspaper withdrew its motion on January 4, 2019 and said in the withdrawal letter why: “The Post intends to refile its motion for an order unsealing the briefs (with appropriate redactions), but has withdrawn its pending motion in response to an affidavit submitted by the office of the Manhattan District Attorney on December 28, 2018.”9 It refiled on January 11, 2019 with notice to the Florida prosecutors. The office objected again, through a different assistant district attorney, on the same notice ground; that second affirmation is not itself among the documents in the release, and what is known of it comes from the newspaper’s account.32 By March 12, 2019 the newspaper’s supplemental affirmation recorded that neither Florida office nor any victim had objected, and stated: “Indeed, the Manhattan DA is the only party to object.”28

No order. Nothing cited on this page, and nothing cited at NYP Holdings, Inc., records an order of the Appellate Division granting or denying either motion. The last dated act in the sequence is the newspaper’s filing of March 12, 2019.

One earlier refusal is on the record too. The newspaper’s memorandum of law recites that on December 4, 2018 a Post reporter asked the office’s Director of Communications for a copy of the People’s appellate brief, offering that victims’ names could be redacted first, and that the request was refused because the office took the position that the brief had been sealed in its entirety under section 50-b and could not be released without an order of the court. The memorandum then records that the office said it “will not oppose” a motion asking that a redacted brief be produced. That is not quite what the affirmation said three weeks later. The affirmation stated that the office could not agree even to a production with the victims’ names and initials redacted, and offered not to oppose a production only if the court were inclined to grant the motion, and then only with substantial further redactions. The memorandum’s account of that exchange, and the office’s later explanation of the discrepancy, are at NYP Holdings, Inc..33

Registration, monitoring and the office

The registration machinery itself ran through the New York City Police Department’s Sex Offender Monitoring Unit and the State Division of Criminal Justice Services rather than through the District Attorney, and the documents recording Epstein’s registration, his address verifications and his reporting obligations are addressed to those bodies. What the released files add about the District Attorney’s part in monitoring is one reported allegation and no document of the office’s own. Judge Berman’s decision of July 18, 2019 remanding Epstein records it: “Notwithstanding Judge Pickholz’s order, according to a July 10, 2019 investigative report by the New York Post, as noted. Mr. Epstein has never reported as a sex offender to New York law enforcement.” The full stop after “noted” is the sheet’s. The decision then quotes the report itself: “The NYPD cop assigned to monitor Epstein has repeatedly complained to [the New York County District Attorney’s] Sex Crimes Unit that Epstein wasn’t in compliance, according to a source familiar with the matter.”34 That is a newspaper’s unnamed source, quoted in a judicial opinion, and the competing account of why he was never made to report is at Ruth Pickholz. No record of any such complaint, and no response to one, appears in any document cited here.

The same decision is also the place where the direction of the 2011 application is described one way and the transcript shows it another, which is worth stating precisely because it is the kind of thing that gets reversed in retelling. Berman wrote that “[a]t the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel’s appeal to review and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein’s sex offender status.”35 On the transcript it runs the other way, and the sheet says so in one line. The assistant district attorney states the People’s position first and the court’s astonishment is directed at her for making it; then, six sheets later, it is Epstein’s counsel who joins the People. Ms. Musumeci, for Epstein: “Your Honor, we would join in the prosecutor’s application.” The court answers: “I am sure you would.”36 The exchanges and the ruling are at Ruth Pickholz.4 The paragraph immediately before it dates the hearing “January 11, 2018” in its text and then cites the transcript as “dated Jan. 18, 2011”; the transcript’s own caption gives January 18, 2011.351

The office in other people’s filings

Three documents in the release touch the office outside the registration proceeding. None of them is a filing of his, and only two of the three record an act of the office at all.

August 6, 2019: the federal prosecutors refuse to sweep the office in. After Epstein’s arrest his counsel wrote to the U.S. Attorney’s Office for the Southern District of New York on July 26 and August 1, 2019 demanding preservation and production of seven categories of documents held by a long list of bodies, among them “the Manhattan District Attorney’s Office”. The Government refused. It would take reasonable steps as to documents already in its own possession, but it would go no further: “Other than documents already within the possession, custody, or control of the Office, we will not be directing any other office or agency, local, state, federal, or foreign … to institute such preservation.” Its reason was that those bodies “are not parties to this litigation, they are not a part of the prosecution team … ” Of the demand itself it wrote: “The scope of these requests is outlandishly overbroad.” Both ellipses in that passage are this page’s; the second marks a cut before the letter’s sentence ends.37

July 12, 2020: the office relays an anonymous tip. An email inside the Southern District of New York, subject “RE: tip to the Manhattan DA’s office”, records: “I got a call last week from the Manhattan DA’s office, conveying that they had received a brief tip on their voicemail system, without a name or phone number (and not traceable via phone number on their system)”. The remainder of that sentence, which is the tip’s substance, runs into a redaction on the sheet and this page does not reproduce it. The writer adds: “Passing this along pursuant to our practice.”38

An undated entry in an FBI chronology. A Criminal Investigative Division briefing document, approved on July 17, 2024, sets out a chronology headed “Post Epstein’s suicide” in which one bullet reads in full: “The Manhattan District Attorney’s office looked into allegations against Leon Black.” The document gives that bullet no date, says nothing about what the office looked at or what came of it, and records no charge. Leon Black has not been charged in any document cited on this page.39

His congressional testimony, as a civil expert reports it

One document in the release attributes testimony to him by name, in a matter about Epstein’s banking rather than about the registration proceeding. An expert report served in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. argues that the financial services industry met the standards of its time and cites him for it:

Similarly, Mr. Cyrus Vance, District Attorney for New York County, also testified about “working closely with banks and financial institutions.” Mr. Vance remarked that the collaborative partnerships with banks were so effective that traffickers had turned to “alternative methods of payment” to “allow them to remain anonymous, such as prepaid gift cards and cryptocurrencies.” Unlike the traditional banking industry, some members of the cryptocurrency community were “specifically catering to traffickers,” according Mr. Vance, who requested legislative and regulatory solutions to address trafficking facilitation from cryptocurrency.40

The inner quotation marks are the report’s, and “according Mr. Vance” for “according to Mr. Vance” is on the sheet. Its footnote gives the source as the hearing “Following the Money: How Human Traffickers Exploit U.S. Financial Markets” before the Subcommittee on Oversight and Investigations of the House Committee on Financial Services, January 30, 2018.40 What is in the release is the expert’s characterisation of that testimony, not the transcript of it, and the hearing record itself is not among the documents cited here. The report is a retained expert’s opinion in contested civil litigation and nothing in it is stated here as established.

A fundraiser for his 2009 candidacy, in Epstein’s inbox

The earliest document on this page predates his taking office and is not an act of his at all. It is an act of Epstein’s.

On August 26, 2009, six weeks before the election, Gerald B. Lefcourt, a New York criminal defence lawyer who had acted for Epstein during the federal investigation, circulated an invitation to a reception he was hosting: “I hope you will join me on Wednesday, September 9th at a reception for Cy Vance and his candidacy for Manhattan District Attorney (invite and NYT & Daily News endorsements attached).” It named two guests, listed endorsements, and closed: “I am honored to be hosting this event and appreciate your help to make Cy the next Manhattan DA.”41

On August 28 the invitation was forwarded to Epstein from an address the production gives as “gmax”, over one line: “Would you like me to go, not go, or you don’t care?”41 Epstein’s reply the same morning is one word: “no”.42

That is the whole of it. Nothing cited here shows that anybody attended on Epstein’s behalf, that any money was given, or that Vance or his campaign knew of the forward or of Epstein’s answer. The invitation went to a mailing list of lawyers and its host was one of them.

Press criticism, circulated inside Epstein’s office, April 2011

Ten weeks after the level three adjudication and while the appeal was pending, Epstein’s own staff were circulating and annotating an article attacking the District Attorney over it.

On the morning of Sunday, April 3, 2011 Scott Denett, a member of Epstein’s staff, sent his assistant Lesley Groff the plain text of the piece under the subject “raw text”. Groff forwarded it to Epstein and to his lawyer Darren Indyke, writing that the attachments had arrived without the highlighting: “Scott was able to send me the attachments below but there are no highlights. Darren, if you want to call me and read me the highlights, I can type them on a Word Doc as you dictate … ” Indyke replied: “I also could only open 1st doc and don’t have Je’s highlights from the other does.” The last word is the sheet’s.43 That afternoon Epstein forwarded the text himself.44

The passage about Vance is the article’s central question, and it is the writer’s commentary and not a finding by anyone: “Which brings me to the big question of the day. Why did Cyrus R. Vance Jr., the Manhattan D.A., allow a Level 3 sex offender (the most dangerous kind) to reside — even for ten minutes — in a house that is right next to Central Park and a school? Isn’t that unlawful given the housing guidelines for sex offenders?” The doubled hyphens are the sheet’s. A few lines later the writer records his own attempt to ask: “When I rang Vance (twice) to discuss Epstein’s residential guidelines he did not take my calls.”44 The author is not named on the sheet, the piece carries no publication masthead, and this page takes nothing else from it.

Response

His answer to the criticism of the 2011 hearing is on the record in three places, and in each of them it is the same answer.

A court filing records it first. The newspaper’s memorandum of law of December 2018, reciting its own reporting of the previous three weeks, states:

In response to questions from the Post, the District Attorney’s Office insisted that ADA Gaffney simply “made a mistake.” Id. A spokesman also claimed that Manhattan District Attorney Cyrus Vance “‘was not aware’ of the hearing until years later and had nothing to do with it.”10

The nesting of quotation marks in the second sentence is the memorandum’s, and the “Id.” is its citation to its own exhibit. The memorandum does not leave that answer standing on its own: the sentence immediately after it reports that “[s]ome law enforcement sources don’t believe Vance had no clue that his office had a sex-offender case involving a Manhattan mogul with close ties to Democrats.” That is a newspaper’s account of what unnamed sources believed, it names nobody, and no document cited here either supports or contradicts it. The same memorandum records that the newspaper’s earlier attempt, in 2015, produced no detailed response on the record and a referral to a passage of the decision instead.10

A news digest held in the release records it at two removes, as a paraphrase of what he had said rather than a quotation of him: summarising a New York Times report of July 2019, it says that “[d]uring a hearing in 2011, a seasoned sex-crimes prosecutor from Mr. Vance’s office argued forcefully in court that Mr. Epstein, who had been convicted in Florida of soliciting an underage prostitute, should not be registered as a top-level sex offender in New York,” and then: “Mr. Vance has said the request was a mistake and had been made by Ms. Gaffney without his knowledge. Still, his office’s decision to take Mr. Epstein’s side in the hearing drew renewed criticism this week.” The sheet’s rendering of the prosecutor’s name in the preceding sentence is destroyed by transmission damage.11

And a Wall Street Journal piece of August 18, 2019, reproduced in a federal news-clips compilation, records the office’s account of who handled the matter: “A spokesman for Manhattan District Attorney Cyrus Vance Jr. said Mr. Epstein’s lawyers dealt only with two prosecutors in the office on the sex-offender designation: Jennifer Gaffney, the deputy chief of the sex crimes unit, and Patrick Egan.”12

These are reported statements by him and by his spokesman, not documents of his own. No letter, memorandum, testimony or affidavit from him about the Epstein matters appears in any document cited on this page. This page did not search published reporting for any further comment from him or a representative and does not assert that none exists.

What could not be established

  • No personal act. No document cited here records him appearing in the proceeding, signing a filing in it, giving or receiving an instruction about it, or being told of it at the time.
  • No contact with Epstein. No document cited here records any meeting, call, letter or message between him and Jeffrey Epstein, in either direction.
  • The May 6 letter’s transmission. A federal prosecutor writing on May 12, 2011 recorded that no formal letter had arrived. The letter in the release is dated May 6. Nothing cited here reconciles them.
  • Whether the Florida material was produced. Nothing cited here shows that the non-prosecution agreement, the victim list, the federal grand jury transcript or the state plea transcript reached his office, on July 29, 2011 or at any other date.
  • Whether anyone answered the August 15 letter. Nothing cited here records a reply to the invitation to give an opinion on the two briefs.
  • The confidentiality promise. It is recorded only as the federal office’s description of it.
  • The disposition of the unsealing motions. No order of the Appellate Division on either motion is among the documents cited here, and the second affirmation his office filed in January 2019 is not in the release at all.
  • The registration complaints. No record of the complaints a newspaper reported reaching his office’s Sex Crimes Unit, and no response to any, appears in any document cited here.
  • The Leon Black entry. The FBI chronology gives it no date, no scope and no outcome.
  • The oral argument. Both sides asked for fifteen minutes; nothing cited here shows whether the appeal was argued or who appeared.

Timeline

DateEventSource
Aug. 26 to 28, 2009A fundraiser invitation for his candidacy, hosted by one of Epstein’s lawyers, is circulated and forwarded to Epstein, who answers “no”4142
Jan. 18, 2011SORA hearing, Ind. No. 30129/2010; his office appears for the People by ADA Jennifer Gaffney14
Apr. 3, 2011An article criticising him over the level three designation is circulated inside Epstein’s office4344
May 6, 2011Letter on his letterhead, signed by ADA Deborah L. Morse, asks the Southern District of Florida for the federal grand jury transcript6
May 12, 2011An internal federal email records the approach and the items asked for, and that no formal letter had arrived17
July 15 and 17, 2011Second letter asks for the signed non-prosecution agreement “including the list of victims”; the federal office dates receipt to July 17719
July 19, 2011The U.S. Attorney’s Office notifies Epstein’s counsel of an intended disclosure to Morse, under 5 U.S.C. § 552a(b) (7)192021
July 21, 2011A revised notice drops the Privacy Act reference and sets the disclosure for 5:00 p.m. on July 222223
July 22, 2011Martin G. Weinberg, for Epstein, objects under paragraph 13 of the agreement and Rule 6(e)24
July 27, 2011The U.S. Attorney’s Office rejects the objections and sets the disclosure for 5:00 p.m. on July 292526
Aug. 2011The Brief for Respondent is filed in his name, Mignola and Morse of counsel2315
Aug. 2 and 15, 2011Both sides ask for fifteen minutes of argument; Morse sends the Florida prosecutor both briefs and the appendix1627
Nov. 17, 2011The First Department affirms, naming him as counsel for respondent5
Dec. 4 to 28, 2018A Post request to his communications director is refused; his office files an affirmation opposing the newspaper’s unsealing motion3382930
Jan. 4 and 11, 2019The newspaper withdraws its motion in response to that affirmation, and refiles932
Mar. 12, 2019The newspaper’s supplemental affirmation states that his office is the only objector28
Aug. 6, 2019Federal prosecutors refuse Epstein’s demand that they direct preservation by his office and others37
July 12, 2020His office relays an anonymous voicemail tip to the Southern District of New York38

Coverage

  • New York Post, January 7, 2015, December 1, 2018 and July 10, 2019, as recited in a court filing and a judicial opinion.
  • Miami Herald, November 28, 2018, as recited in a court filing.
  • New York Times, July 2019, as summarised in a federal news digest.
  • The Wall Street Journal, August 18, 2019, as reproduced in a federal news-clips compilation.

Sources

Footnotes

  1. SORA hearing transcript, The People of the State of New York against Jeffrey Epstein, Indictment # 30129/2010, Supreme Court, New York County, Trial Term, Part 66, 111 Centre Street, January 18, 2011, before the Hon. Ruth Pickholz; the caption sheet, enclosed with the order cited above. https://epstein-data.com/EFTA01659328 p.2. Quoted from the document’s text layer. The sheet renders the defence firm “KIRKLAND & ELLI, LLP” and the court reporter’s name twice in different forms; the damage is in the extraction of this sheet. Separately produced copies of the same transcript carry the same appearances, among them https://epstein-data.com/EFTA00205712 p.2 and https://epstein-data.com/EFTA00704714 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  2. “Brief for Respondent”, People v. Epstein, Appellate Division, First Department, cover page. https://epstein-data.com/EFTA00792500 p.1. The cover also carries the Civil Rights Law § 50-b sealing legend, which is quoted at Ruth Pickholz and is not reproduced here. Separately produced copies of the same brief are at https://epstein-data.com/EFTA00602338 p.1 and https://epstein-data.com/EFTA01177413 p.1. ↩ ↩2 ↩3 ↩4

  3. The same brief, last page, printed “-63-”, carrying the closing passage, the heading “CONCLUSION” and the signature block. https://epstein-data.com/EFTA00792500 p.67 ↩ ↩2 ↩3 ↩4

  4. The same transcript, transcript p.2, the sheet on which the clerk calls the case and counsel state their appearances. https://epstein-data.com/EFTA01659328 p.3 ↩ ↩2 ↩3 ↩4 ↩5

  5. People v Epstein, 2011 NY Slip Op 08293 (1st Dep’t, decided November 17, 2011), the sheet carrying the counsel lines and the affirmance. https://epstein-data.com/EFTA00614180 p.2; the first sheet, carrying the panel and the appellate and indictment numbers, is at p.1 of the same run. The decision and order as entered is at https://epstein-data.com/EFTA00208154 p.1. The court’s holdings are set out at Ruth Pickholz and are not repeated here. ↩ ↩2 ↩3

  6. Letter of May 6, 2011 on the letterhead of the District Attorney of the County of New York, One Hogan Place, carrying “CYRUS R. VANCE, JR.” beneath the office name, to an Assistant United States Attorney at the Office of the United States Attorney, Southern District of Florida, 500 S. Australian Avenue, Suite 400, West Palm Beach. https://epstein-data.com/EFTA00208125 p.1. The addressee’s name is redacted on this copy. A second copy, in a defence file, prints the signature “Deborah L. Morse / Assistant District Attorney” and also prints two of the sentences with characters dropped: https://epstein-data.com/EFTA00181217 p.16. The clean text is quoted from the first copy and the signature from the second. ↩ ↩2 ↩3

  7. Letter of July 15, 2011 on the same letterhead, signed “Deborah L. Morse / Assistant District Attorney”, to the same Assistant United States Attorney. https://epstein-data.com/EFTA00181217 p.14. The addressee’s name is blacked out on this copy and the fax banner has eaten several digits of the street address. ↩ ↩2 ↩3

  8. “Affirmation in Response to Motion”, The People of the State of New York against Jeffrey E. Epstein, Supreme Court of the State of New York, Appellate Division: First Department, N.Y. Co. Ind. No. 30129/10, calendar date December 31, 2018, of Karen Friedman Agnifilo, Assistant District Attorney, paragraph 1. https://epstein-data.com/HOUSE_OVERSIGHT_016474 p.1. Quoted as the sheet prints it: “Attomey” for “Attorney”, and “CYRUS R. VANCE, JR,” with a comma standing where the stop after “JR” belongs, are the sheet’s own renderings. ↩ ↩2 ↩3

  9. Letter of January 4, 2019, hand delivered, from Davis Wright Tremaine LLP to the Clerk of Court, Supreme Court of the State of New York, Appellate Division, First Department, withdrawing the December 21, 2018 motion under 22 NYCRR § 1250.2. https://epstein-data.com/EFTA00794227 p.1 ↩ ↩2 ↩3 ↩4

  10. “Memorandum of Law in Support of Motion of NYP Holdings, Inc. to Unseal Appellate Briefs”, December 21, 2018, the page printed 7. https://epstein-data.com/EFTA00805348 p.11; the sentence about the spokesman’s claim runs onto the next sheet, https://epstein-data.com/EFTA00805348 p.12, and is quoted whole across the break. The account of the 2015 request and the referral to the decision is on the preceding sheet, p.10 of the same run. Each of those statements is the memorandum’s recital of the newspaper’s own reporting. The sentence beginning “[s]ome law enforcement sources” is on p.12 of the same run, where the extraction prints the bracketed letter as “[slome”. ↩ ↩2 ↩3

  11. News digest held in the released files, summarising a New York Times report by Jan Ransom of July 2019 on renewed scrutiny of his office’s handling of the registration hearing. https://epstein-data.com/EFTA00043963 p.385; the paragraph begins on the preceding sheet, p.384 of the same run. The rendering of the prosecutor’s name in the sentence immediately before the quoted material is destroyed on the sheet, which prints “Jell! Illef Veil I r ley” where the name belongs; the damage is the sheet’s. The same summary appears a second time in the same run at pp.423-424. ↩ ↩2

  12. Joe Palazzolo, “Documents Show Efforts by Jeffrey Epstein’s Attorneys to Sway Prosecutors,” The Wall Street Journal, August 18, 2019, as reproduced in a Southern District of New York news-clips compilation. https://epstein-data.com/EFTA00092932 p.1. A second copy of the same clip is at https://epstein-data.com/EFTA00077515 p.1. Other passages of the same article are quoted at Ruth Pickholz. ↩ ↩2

  13. Wikipedia, “Cyrus Vance Jr.” https://en.wikipedia.org/wiki/Cyrus_Vance_Jr. Cited for the dates of his tenure only. Every other statement on this page is cited to a document in the released files. ↩

  14. Order, United States v. Jeffrey Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.), Dkt. 14, dated New York, New York, July 15, 2019, signed Richard M. Berman, U.S.D.J. This is sheet 1 of the run and it is the container: the transcript enclosed with it is a different document, in a different court, dated eight years earlier. https://epstein-data.com/EFTA01659328 p.1 ↩

  15. The same brief, the page printed “-62-”, carrying footnote 7. https://epstein-data.com/EFTA00792500 p.66. The first sentence of that footnote uses em-dashes around the two phrases it quotes from Epstein’s brief; the sentence quoted in the blockquote above is the footnote’s second and is reproduced whole. ↩ ↩2

  16. “ORAL ARGUMENT TIME REQUEST”, People of the State of New York against Jeffrey E. Epstein, New York County Clerk’s Index No. 30129/2010, noticed for the September Term, 2011, filed with a covering letter of August 2, 2011 from Kirkland & Ellis LLP to the Clerk of Court copied to Deborah Morse. https://epstein-data.com/EFTA00597954 p.2 (the form) and p.1 (the covering letter). The rule reference prints ”§ 600.11(0” and the respondent’s office prints “New York County District of Attorney’s Office”; both are as the sheet gives them. ↩ ↩2

  17. Internal email, Office of the United States Attorney, Southern District of Florida, subject “Inquiry from Manhattan DA’s Office re Epstein”, May 12, 2011, 22:27 UTC, signed “Assistant U.S. Attorney”. Sender and recipients are redacted. https://epstein-data.com/EFTA00207963 p.1 ↩ ↩2

  18. The same letter as the second sheet of a two-sheet fax from the office’s Appeals Bureau, behind the office’s own “FAX DOCUMENT COVERSHEET”. https://epstein-data.com/EFTA00205952 pp.1-2. The salutation on this copy prints “Dear Ms. Villafalia,”. The fax banner’s meridian differs between the two sheets of the same transmission, printing “Jul 17 2011 10:15pm” on the coversheet and “Jul 17 2011 10:15am” on the letter, and the copy of the same transmission in a defence file prints the coversheet’s banner as “10:15pm” (https://epstein-data.com/EFTA00181217 p.13) and the letter’s as “10:15pa” (p.14 of the same run); this page therefore states no time of day for the fax. ↩

  19. Letter of July 19, 2011 from the United States Attorney, Southern District of Florida, to Roy Black, Esq., Black Srebnick Kornspan & Stumpf P.A., “Re: Jeffrey Epstein”, subscribed Wifredo A. Ferrer, United States Attorney, and copied to Deborah L. Morse. https://epstein-data.com/EFTA00205958 p.1. The statutory citation prints across a line break as “5 U.S.C. § 552a(b) (7)” and is reproduced as printed. ↩ ↩2 ↩3 ↩4

  20. A second letter, also dated July 19, 2011 and otherwise in the same terms, which gives the time of the intended disclosure as “5:00 p.m. on Thursday, July 21, 2011” rather than the close of business, and which carries no addressee block or copy line on the copy in the release. https://epstein-data.com/EFTA00205954 p.1 ↩ ↩2

  21. Internal email, Office of the United States Attorney, Southern District of Florida, subject “FOIA Request”, July 20, 2011, 01:30 UTC, attaching a scan of the District Attorney’s letter and a draft of the letter to Epstein’s counsel. Sender and recipient are redacted. https://epstein-data.com/EFTA00205951 p.1 ↩ ↩2

  22. Letter of July 21, 2011 from the United States Attorney, Southern District of Florida, to Roy Black, “Re: Jeffrey Epstein”, as held in a defence file, which prints the assistant district attorney’s name where other copies redact it. https://epstein-data.com/EFTA00181217 p.15. A separately produced copy, with the name redacted, is at https://epstein-data.com/EFTA00613998 p.1. ↩ ↩2

  23. Internal email, Office of the United States Attorney, Southern District of Florida, subject “Emailing: 20110721 Ltr to Black.wpd”, July 21, 2011, 18:05 UTC, transmitting a revised draft. https://epstein-data.com/EFTA00205942 p.1. Quoted from the document’s text layer, which prints the message’s four short lines out of order and does not legibly render the name of the person who made the recommendation; the quoted clause is a fragment of one of those lines and no sentence is closed for it here. The substance of the change is independently visible on the face of the two letters, which cite different authority. ↩ ↩2

  24. Letter of July 22, 2011 from Martin G. Weinberg, Attorney at Law, Boston, to “A. Marie Villaftula, Assistant United States Attorney”, “Re: Jeffrey Epstein”, copied to Roy Black. https://epstein-data.com/EFTA00611512 p.1. The addressee’s surname is mangled in the address block and printed correctly in the salutation on the same sheet; the mangling is in the extraction. Separately produced copies, with the name redacted, are at https://epstein-data.com/EFTA00205223 p.1 and https://epstein-data.com/EFTA00181217 p.1. ↩ ↩2

  25. Letter of July 27, 2011 from the United States Attorney, Southern District of Florida, to Martin G. Weinberg, “Re: Jeffrey Epstein”, first sheet. https://epstein-data.com/EFTA00205945 p.1. The single quotation marks inside the blockquoted sentence and in the sentence preceding it stand for the letter’s own double quotation marks around the defined term “Agreement”. ↩ ↩2 ↩3

  26. The same letter, second sheet, carrying the Rule 6(e) holding, the invitation to supply further authority by 5:00 p.m. on July 29, 2011 and the new disclosure deadline. https://epstein-data.com/EFTA00205945 p.2. The running head on this sheet prints the addressee’s surname as “WENDER°”; other copies of the same sheet print it “WEINBERG” and “WEINBRO”. https://epstein-data.com/EFTA00598044 p.2 ↩ ↩2

  27. Letter of August 15, 2011 on the letterhead of the District Attorney of the County of New York, signed “Deborah L. Morse / Assistant District Attorney”, to the same Assistant United States Attorney, enclosing the appellant’s brief and appendix and the People’s brief. https://epstein-data.com/EFTA00181217 p.17. Separately produced copies are at https://epstein-data.com/EFTA00231917 p.646 and https://epstein-data.com/EFTA00230786 p.657. ↩ ↩2

  28. The same supplemental affirmation, the sheet carrying paragraphs 11 and 12 and the date line of March 12, 2019. https://epstein-data.com/EFTA00798561 p.4 ↩ ↩2 ↩3

  29. The cover sheet of the same affirmation, carrying the office block and the assistant district attorney’s name “Of Counsel”. https://epstein-data.com/HOUSE_OVERSIGHT_016477 p.1. It too prints “Attomey”. Its own title is “AFFIRMATION IN RESPONSE TO NON-PARTY MOTION”, where the affirmation’s first sheet is headed “AFFIRMATION IN RESPONSE TO MOTION”. ↩ ↩2

  30. The signature page of the same affirmation, dated New York, New York, December 28, 2018, signed above the typed name and copied to the movant’s counsel. https://epstein-data.com/HOUSE_OVERSIGHT_016476 p.1. The telephone line beneath the signature is not reproduced. ↩ ↩2

  31. The same affirmation, paragraphs 2 and 3, which set out the two grounds. https://epstein-data.com/HOUSE_OVERSIGHT_016475 p.1. Its words are quoted in full at NYP Holdings, Inc. and are summarised rather than requoted here. ↩

  32. “Supplemental Affirmation of John M. Browning in Further Support of Motion to Unseal”, March 12, 2019, paragraphs 2 and 3, which identify and quote the second affirmation filed by the office, dated January 18, 2019. That affirmation is not itself among the documents in the release, and this page carries only the movant’s account of it. https://epstein-data.com/EFTA00798561 pp.1-2 ↩ ↩2

  33. The same memorandum, the page printed 8, on the December 4, 2018 request to the office’s Director of Communications and its refusal. https://epstein-data.com/EFTA00805348 p.12. The office’s later explanation of the discrepancy between that answer and the affirmation is set out at NYP Holdings, Inc.. ↩ ↩2

  34. Decision and Order Remanding Defendant, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.), filed July 18, 2019, the page printed 20. https://epstein-data.com/EFTA00039383 p.20. Quoted from the document’s text layer. The full stop after “as noted” in the first quotation is printed on the sheet in place of a comma. ↩

  35. The same decision, the page printed 19. https://epstein-data.com/EFTA00039383 p.19. The bracketed capital in “[a]t the hearing” is this page’s; the sentence begins “At” on the sheet. The same sheet prints the hearing date as “January 11, 2018” in the text of the paragraph preceding the one quoted, and cites the transcript as “dated Jan. 18, 2011” in the citation that closes that same paragraph. ↩ ↩2

  36. The same transcript, transcript p.8, the sheet on which Epstein’s counsel joins the People’s application, followed immediately by the court’s reply. https://epstein-data.com/EFTA01659328 p.9. Both sentences close with a full stop on the sheet. ↩

  37. Letter of August 6, 2019 from the United States Attorney’s Office for the Southern District of New York to Martin G. Weinberg, Reid Weingarten and Michael Miller, “Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)”, answering defence letters of July 26 and August 1, 2019. The list of bodies, which names the Manhattan District Attorney’s Office, is in footnote 1 on the same sheet. https://epstein-data.com/EFTA00016596 p.1. Separately produced copies are at https://epstein-data.com/EFTA00100775 p.2 and https://epstein-data.com/EFTA00085284 p.2. ↩ ↩2

  38. Email, Assistant U.S. Attorney, Southern District of New York, subject “RE: tip to the Manhattan DA’s office”, July 12, 2020, 20:15 UTC, to a Federal Bureau of Investigation and New York Police Department recipient and copying two colleagues. Sender and recipients are redacted. https://epstein-data.com/EFTA00038019 p.1. The sentence describing the tip is interrupted by a redaction at the point where it would name a person, and neither the name nor the substance following it is reproduced here. ↩ ↩2

  39. Criminal Investigative Division, Federal Bureau of Investigation, briefing document marked “Approved by CID A/AD on 7/17/2024”, the sheet carrying the chronology headed “Post Epstein’s suicide”. https://epstein-data.com/EFTA01649149 p.3. The bullet quoted is complete as it stands on the sheet and carries no date. A second version of the same chronology, with slightly different wording of the same bullet, is at https://epstein-data.com/EFTA01649143 p.5. ↩

  40. Expert Report of Dr. Kimberly Mehlman-Orozco, CEO of Break the Chain LLC, June 23, 2023, served in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 22-cv-10904-JSR (S.D.N.Y.), and filed as Exhibit 1 to Dkt. 290-1 on August 18, 2023; the page printed 50. https://epstein-data.com/EFTA02816521 p.51. Its footnote 143 gives the underlying source as Following the Money: How Human Traffickers Exploit U.S. Financial Markets, Hearing Before the Subcommittee on Oversight and Investigations of the House Committee on Financial Services, 115th Congress, January 30, 2018. The hearing transcript is not among the documents cited here. The report’s own text prints “according Mr. Vance” and the author’s surname as “Mehlman-O rano” on its title sheet; both are as the sheets give them. The superscript footnote numerals 143 and 144 that the sheet prints inside the quoted passage are not reproduced in the blockquote. ↩ ↩2

  41. Email forwarding the invitation to Epstein, subject “FW: September 9th Evening with Cy Vance”, August 28, 2009, 15:09 UTC, from an address the production gives as “gmax”, quoting in full the message of Gerald B. Lefcourt of Gerald B. Lefcourt, P.C., 148 E. 78th Street, New York, dated August 26, 2009, 11:30 Eastern. https://epstein-data.com/EFTA00769520 p.1. The web address of the campaign’s RSVP page and the two staff contacts’ details are printed on the sheet and are not reproduced here. The New York Times endorsement circulated with it is the next sheet of the same run, https://epstein-data.com/EFTA00769522 p.1. ↩ ↩2 ↩3

  42. Jeffrey Epstein to “gmax”, subject “Re: FW: September 9th Evening with Cy Vance”, August 28, 2009, 15:10 UTC. The body is the single word “no”, above the quoted forward. https://epstein-data.com/EFTA00739073 p.1 ↩ ↩2

  43. Email chain, Sunday April 3, 2011, subject “raw text”: Scott Denett to Lesley Groff at 10:04 Eastern; Groff to Jeffrey Epstein and Darren Indyke; Indyke’s reply at 12:54 Eastern as the sheet’s own header gives it. https://epstein-data.com/EFTA00436103 p.1. The last word of Indyke’s message prints “does” for “docs” and the date lines are damaged on the sheet. ⚠ The copy cited for the text of the messages names none of the correspondents: every “From” and “To” line on it is redacted. The attributions above are taken from a separately produced copy of the same forward which carries the header whole, “From: Lesley Groff” and “To: Jeffrey Epstein” and “Darren Indyke”, above the same text and above the same forwarded message from Scott Denett: https://epstein-data.com/HOUSE_OVERSIGHT_009408 p.1. The two copies do not agree on when Groff sent it. The quotation line inside Indyke’s reply gives 10:08 AM, which is before the 12:54 reply; the header of the second copy gives 02.08 PM, which is after it. This page therefore gives no time for that message. ↩ ↩2

  44. The text of the article as forwarded by Jeffrey Epstein on Sunday, April 3, 2011 at 16:41 Eastern. https://epstein-data.com/EFTA01777973 p.1. The two sentences quoted here are on that sheet and are quoted whole; nothing is taken from the later sheets of the run, which carry material about identified and unidentified complainants that this page does not reproduce. The author is not named on the sheet. A separately produced copy of the same text, sent under the same subject earlier the same day, is at https://epstein-data.com/EFTA00436099 p.1. ↩ ↩2 ↩3

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