Epstein Data Wiki

Louis Freeh

Properties2
tagsperson, fbi, foia, dershowitz, giuffre-v-maxwell, little-saint-james, expert-witness
aliasesLouis J. Freeh, Louie Freeh, Freeh, Louis, Judge Louis J. Freeh

26 min read

Named on the documents as”Hon. Louis J. Freeh” in the sender block at the head of his January 22, 2016 letter, and “Louie Freeh” in the typed name beneath his signature on the same sheet; “Louis J. Freeh” in the April 8, 2016 press release; “Louis Freeh” in the pretrial witness list123
Described in the documents as”former FBI director” in a declaration of Maxwell’s counsel; “the former head of the FBI” and “my attorney in New York” in Alan Dershowitz’s sworn deposition testimony; “former federal judge and former FBI Director” in the press release Dershowitz issued452
Acts recorded in this releaseSigned the January 22, 2016 letter to Dershowitz stating a conclusion about former President Bill Clinton and Little St. James; supervised the investigation announced on April 8, 2016; listed as a live witness for the defendant in No. 15 Civ. 7433 (RWS)123
Litigation in which he appearsBradley J. Edwards and Paul G. Cassell v. Alan M. Dershowitz, No. CACE 15-000072 (Fla. Cir. Ct., 17th Jud. Cir., Broward Cnty.); No. 15 Civ. 7433 (RWS) (S.D.N.Y.)5637
The Freeh Group in this releaseThe spaced phrase Freeh Group returns exactly one page of the corpus: the December 23, 2015 e-mail, which names the firm twice. The name also stands unspaced, as the domain of the business e-mail address in the sender block of Freeh’s January 22, 2016 letter; searched in that form it returns five pages, that letter and four further copies of it. The defendant’s witness list gives Freeh two service addresses, with no firm name printed against them8139

Louis J. Freeh, a former Director of the Federal Bureau of Investigation, appears in this release as the author of a signed letter, the supervisor of a named investigation, and a disputed witness. The letter, dated January 22, 2016 and addressed to Professor Alan Dershowitz, reports the United States Secret Service’s response to a Freedom of Information Act request and states Freeh’s own conclusion from it: “I therefore conclude from this response that former President Clinton did not in fact travel to, nor was he present on, Little St. James Island between January 1, 2001 and January 1, 2003.”1 On April 8, 2016 a press release issued through the law firm that a note at its foot says represents Dershowitz announced the result of “the independent investigation conducted by former FBI Director Louis Freeh” into sexual misconduct allegations against Dershowitz.2 In the defamation action against Ghislaine Maxwell in the Southern District of New York, Maxwell’s counsel listed Freeh as a live witness and tendered his report as an exhibit; the plaintiff’s counsel argued that he had been disclosed as a lay witness and was being offered as an expert, and asked that he be excluded.3410

Nothing on this page is a finding of wrongdoing.

The FOIA request and the Secret Service response

The request instrument itself is dated April 6, 2015. It is headed “FOIA REQUEST”, is addressed not to the Secret Service but to a named Deputy Chief FOIA Officer at “The Privacy Office, Department of Homeland Security”, and asks under 5 U.S.C. § 552 for “any and all shift logs, travel records, itineraries, reports, and other records for USSS personnel traveling with former President Bill Clinton to Little St James Island and the US Virgin Islands” for the period 1/1/01 to 1/1/03. The sentence introducing that request runs, on the face of the sheet, “I request access to and copies of For the period 1/1/01 to 1/1/03, any and all shift logs”. It is quoted here as printed: a template filled in without the surrounding words being adjusted. The letter is signed in ink, and the typed name beneath the signature is Patti Bescript, not Louis Freeh. No role, firm or title is printed for that signatory anywhere on the sheet, and none is supplied here.11

The Secret Service’s reply is on United States Secret Service letterhead, is addressed to Patti Bescript, opens “Dear Requester:”, and carries the file number 20150826. It records the request as “originally received by the United States Secret Service (USSS) on April 16, 2015”, ten days after the request letter’s own date, and states: “In response to your request, the USSS has conducted a reasonable search for responsive records. It appears, from a review of USSS main indices, that there are no records pertaining to your request that are referenced in these indices. Enclosed is a copy of your original request.” It offers appeal rights. The signature over the printed block for Kim E. Campbell, Special Agent In Charge, Freedom of Information Act & Privacy Act Officer is ink.12

The date on that reply is a rubber stamp applied upside down. Read at the native raster of the released page image (816 × 1056 at 96 ppi), rotated 180°, the Date field reads JAN 15 2016. The day is a 5, not a 6: it carries a flat horizontal top bar with an open right shoulder and a bowl confined to the lower half, where the 6 at the end of the same stamp’s “2016” has a curved top-right shoulder, no top bar, and a closed lower loop. The text layer emits the whole stamp as 9ilic.129 Freeh’s letter of January 22, 2016 describes the same instrument as “a January 16, 2016 letter from Kim E. Campbell”.1

The engagement, December 2015

An e-mail of December 23, 2015 is the earliest document opened for this page that describes the investigation being set up. It reached Jeffrey Epstein as a forward: Martin Weinberg forwarded it to Epstein at Wed, 23 Dec 2015 12:46:32 +0000, and the message he forwarded carries its own header, December 23, 2015, 7:25:09 AM EST. Both zone markers are printed on the one sheet and they reconcile: 7:25:09 Eastern is 12:25:09 UTC, so, reduced to one clock, the forward followed the original by twenty-one minutes.8

The forwarded message is from Nicholas Maisel, whose signature block reads “Research Assistant for Alan Dershowitz”. It is addressed to Weinberg and copies Dershowitz. It reads, in part:

Alan has asked the Freeh group to conduct an independent investigation of ▮ credibility, and her allegations in his regard. They are now beginning the process of conducting interviews with individuals who they think might provide relevant information. To that effect, they wanted to get in touch with ▮, ▮, Ghislaine Maxwell, and Juan Alessi.

Alan wanted to make sure that there was no problem on your end with the Freeh Group investigators contacting them. We have email addresses for ▮, ▮, and Ms. Maxwell; we don’t have anything for Mr. Alessi so if you have an email for him, we would really appreciate it.

The bars are the producing party’s. The person whose credibility was to be investigated is withheld on this sheet, and this page does not complete that field. The interview sentence names four people, and two of the four are barred. The signature block on this sheet is printed type with no rule and no ink.8

The extraction of this sheet closes or corrupts every bar in the passage quoted above. The text layer renders the first sentence as “an independent investigation of credibility, and her allegations in his regard”, turning a sentence about a person into a sentence about an abstraction; it renders the four-name list as a two-name list, so that a reader working from the text layer would state a complete list that the sheet bars half of; and in the last sentence it closes one of the two bars entirely and emits the other as the stray characters MM,.9

Use in the Florida litigation, early 2016

Earlier still, on Friday, October 16, 2015, Dershowitz gave the second volume of his videotaped deposition in Bradley J. Edwards and Paul G. Cassell v. Alan M. Dershowitz in the Seventeenth Judicial Circuit in and for Broward County. Asked whether he had made a public records request about former President Clinton’s private air travel, he answered: “Well, we have made a Freedom of Information request. My — my attorney in New York, Louis Freeh, the former head of the FBI, has made a FOIA request for all information that would conclusively prove that Bill Clinton was never on Jeffrey Epstein’s island, yes.” Pressed on whether the records had been denied, he added: “As any lawyer knows, FOIA requests take a long, long period of time. So they were neither denied nor were they given to us. They are very much in process.”5 That description of Freeh is Dershowitz’s own sworn word for the relationship; it is quoted here, not adopted, and no retainer, engagement letter or firm relationship for Freeh appears in any document opened for this page.

Seven days after the letter’s date, Freeh’s conclusion was in use in that same Florida action. Dershowitz moved on January 29, 2016 for clarification of, or relief from, the confidentiality order, and a later redacted motion in the same case argues: “Indeed, former FBI Director Louis Freeh determined based on the response of the federal government to a FOIA request that the absence of records responsive to the request ‘strongly establishes that former President Clinton was not present on Little St. James Island during the period at issue.’”6

The letter of January 22, 2016

The letter is addressed to Professor Alan Dershowitz at Harvard Law School and is headed “RE: FOIA Request”. The sender block above the date carries, beneath the name, a telephone line and a business e-mail address; neither value is reproduced here. The domain of that address is the firm’s own, and a search for the spaced phrase Freeh Group does not return this sheet: searched as the unspaced token the name stands here and on four further copies of the same letter.19

One sentence in it carries a redaction bar: “The basis of the above-described FOIA request was a claim by ▮ in court papers filed in early 2015 in Florida federal court, that she and former President Clinton were on Little St. James Island at the same time during the 1/01/01 to 1/1/03 period.” The bar is a redaction, not an absence, and the name behind it is not supplied here.1

Three things about the letter’s own language are on the face of it. It describes the request in the passive voice and names no requester: “As you know, on April 6, 2015, a request was made to the United States Secret Service”, where the instrument itself bears another person’s signature.111 It states its conclusion in the first person: “I therefore conclude from this response…”. And it labels that conclusion an opinion: “The total absence of any such records and documentation, in my opinion, strongly establishes that former President Clinton was not present on Little St. James Island during the period at issue.”1 The intervening paragraph rests on the writer’s own experience rather than on any record produced: “Based upon my experience and knowledge of the duties, protocols and operations of USSS Protective Details, the Special Agents accompany and escort former President Clinton 24 hours per day, and would have certainly went with him to Little St. James Island during the period at issue”. The grammatical slips in that sentence and the next (“would had been required”) are on the sheet.1

The letter is signed in ink: the stroke width varies, the mark sits off the baseline and runs past the typed name below it. That typed name reads “Louie Freeh”, where the sender block at the head of the same sheet reads “Hon. Louis J. Freeh”.1

Publication, April 8, 2016

On April 8, 2016 a press release headed “FOR IMMEDIATE RELEASE” and naming Richard A. Simpson as its contact announced: “INVESTIGATION BY FORMER FBI DIRECTOR LOUIS FREEH CONCLUDES THAT THE TOTALITY OF THE EVIDENCE REFUTES ALLEGATIONS MADE AGAINST PROFESSOR DERSHOWITZ”. Under the heading “STATEMENT OF LOUIS J. FREEH” it prints: “Over the past several months, an independent investigation was conducted, under my supervision, by former senior federal law enforcement officials. We interviewed many witnesses and reviewed thousands of pages of documentary evidence. Our investigation found no evidence to support the accusations of sexual misconduct against Professor Dershowitz. In fact, in several instances, the evidence directly contradicted the accusations made against him.” A further paragraph follows, and it labels the conclusion an opinion as the January letter does: “In my opinion, the totality of the evidence found during the investigation refutes the allegations made against Professor Dershowitz.” Dershowitz’s own statement above it calls the same work “his independent investigation” and attributes the conclusion to “Judge Freeh’s professional opinion”. At the foot of the sheet, in italic type, stands: “Editor’s note: Wiley Rein LLP represents Alan M. Dershowitz.” The contact line at the head of the same sheet gives that contact a business e-mail address in that firm’s own internet domain, which is what supports describing the release as issued through the firm; the address itself is not reproduced here.2

That release is the third sheet of a six-sheet package. The first two sheets are a separate press release of the same date, “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz”, announcing the resolution of the Broward County action; the last three are the Freeh letter and its two attachments, the Secret Service reply and the April 2015 FOIA request.131211

The day after that, Epstein circulated the package. On Sat, 09 Apr 2016 15:51:27 +0000 an e-mail from “jeffrey E.” to David Stern, with the attachment AD_Statement_Package.pdf, carries a message body above a standing confidentiality trailer. That body reads: “PA might want to use this, ▮ is proved to have made up the dersh story, louis freeh former fbi head , also did indpemetn investigation , said no facts to support her dersh claim at all.” The misspelling of “independent” is on the sheet; the name is barred; the Subject field on this sheet is empty rather than redacted, while the recipient’s address field carries a bar.14

A New York Times account of the settlement, filed in this release as a database printout, reported: “On Friday, he released a statement by Louis J. Freeh, the former director of the Federal Bureau of Investigation, whom Mr. Dershowitz hired to investigate the matter.” That is the newspaper’s characterisation, and it is set out here as such.15

Witness in No. 15 Civ. 7433 (RWS)

Freeh was disclosed on February 24, 2016 in “DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES”, signed with a conformed “s/ Laura A. Menninger” in type over a rule. Item 9 of that disclosure reads, in its entirety: “Louis Freeh / Address unknown at this time / ▮ / ▮ / Mr. Freeh may have knowledge concerning travel of Bill Clinton.” Two lines beneath “Address unknown at this time” are barred, and the extraction closes them so that the entry reads as continuous. The disclosure attributes to him knowledge of one subject, Clinton’s travel, and mentions no report and no opinion.16

By June 20, 2016 the report itself was an exhibit: a declaration of Maxwell’s counsel filed that day states, at its item 4, “Attached as Exhibit C is a report by former FBI director, Louis Freeh.”4 Maxwell’s opposition to the plaintiff’s omnibus motion in limine devoted a numbered section to him: item 4 of its table of contents reads “Louis Freeh’s testimony and report are admissible evidence (Motion in Limine 4)”.17 The joint pretrial statement lists him at item 18 of the defendant’s witness list, “18. Louis Freeh (live)”, with two service addresses beneath.3

At oral argument on March 31, 2017 before Judge Robert W. Sweet, the dispute was joined. For the plaintiff, Sigrid S. McCawley said: “they have Louie Freeh who they’ve identified. This is a former FBI director. … So they’ve put him in without giving us a Rule 26 expert report. He was never disclosed during the time period. His report or what he’s going to say, as we understand it, is that he’s reviewed the FOIA response and that there’s no evidence in his view that Clinton was on this island”.7 She argued the records question directly: “that the government only typically retains records for a few years when they were requesting records from 15 years ago, so it doesn’t have the indicia of trustworthiness to be able to say that this is actually the fact because, of course, as we know, the government regularly has to get rid of records”, and asked that “Mr. Freeh should be excluded, the FOIA letter should not come into evidence”.18

For the defendant, counsel answered: “With regard to Louie Freeh, your Honor, we disclosed him as a witness in our Rule 26 disclosures last March — excuse me — February of 2016. Plaintiff made no effort to try to depose him, made no effort to find out his basis of knowledge. We produced in discovery his report in which he submitted a FOIA request.”19 McCawley returned to it later the same day, reading from the letter aloud and putting the objection in one sentence: “They disclosed him as a lay witness in this case, not an as an expert witness.” She added: “If we had known, of course, that Mr. Freeh was going to be put on the stand as an expert in this case, we, of course, would have sought his deposition through the expert process.”10 Earlier in the same argument she had put the objection in terms of what the court had already refused her: “in your Honor’s order in 264-1, which is one of the sealed orders, you did not allow us to depose him because you said it was irrelevant. So we’re now in a position where at trial they want to put forth that information against my client, and I don’t have an under-oath statement from that individual saying whether or not he actually was.” On the same sheet she called Freeh “clearly an expert that was undisclosed.”20

The sequence, and a question the documents do not answer

Set in the order the documents were made:

DateDocumentWhat it records
Oct 16, 2015Deposition, Edwards and Cassell v. Dershowitz5Dershowitz, under oath: “my attorney in New York, Louis Freeh … has made a FOIA request”
Dec 23, 2015E-mail, Maisel to Weinberg, forwarded to Epstein8”Alan has asked the Freeh group to conduct an independent investigation”; Dershowitz’s research assistant asks whether “there was no problem on your end with the Freeh Group investigators contacting” four people, two of them Ghislaine Maxwell and Juan Alessi
Jan 15, 2016Secret Service reply12”no records pertaining to your request that are referenced in these indices”
Jan 22, 2016Freeh to Dershowitz1”I therefore conclude …”, “in my opinion, strongly establishes …”
Jan 29, 2016 onwardMotions, Broward County6Dershowitz’s filings in the Florida action deploy the conclusion
Feb 24, 2016Maxwell’s Rule 26 disclosures16”Mr. Freeh may have knowledge concerning travel of Bill Clinton”
Apr 8, 2016Press release2”the independent investigation conducted by former FBI Director Louis Freeh”; “Wiley Rein LLP represents Alan M. Dershowitz”
Apr 9, 2016Epstein forwards the package14”PA might want to use this”
Mar 31, 2017Oral argument10”They disclosed him as a lay witness in this case, not an as an expert witness”

The first of those entries is dated October 16, 2015 and the seventh April 8, 2016. What relation, if any, the sworn description in October bears to the word used in April is not settled by any document opened for this page. No retainer, engagement letter or scope of work for Freeh appears among them; the request instrument bears a different signature and Freeh’s own letter describes it in the passive; the assistant who wrote in December wrote on Dershowitz’s behalf, told Martin Weinberg that Dershowitz “wanted to make sure that there was no problem on your end with the Freeh Group investigators contacting them”, and added that “we don’t have anything for Mr. Alessi so if you have an email for him, we would really appreciate it”; and the announcement in April came out through the firm the same sheet identifies as Dershowitz’s counsel. Those are the dates and the words. What they establish, and what they do not, is a question this page leaves open, and the inference is the reader’s to draw or to refuse.

Note on the documents

Every quotation above was read at the image at the resolutions given in the footnotes; the corpus text layer was used only to locate sheets. Three faults in that text layer destroy something these sheets show, and matter to anyone re-deriving this page. On the December 23, 2015 e-mail the extraction closes four redaction bars, turning a four-name list into a two-name list and a sentence about a person into a sentence about an abstraction.8 On the Rule 26 disclosure it closes two more, so that Freeh’s entry reads as continuous.16 On the Secret Service reply it renders the upside-down date stamp as 9ilic.12 A page written from the extraction of any of the three would state something the sheet does not.

Signature states, since a signature block is not a signature: the Freeh letter, the Secret Service reply and the April 2015 request are each signed in ink; the Maisel e-mail carries printed type with no rule; the Rule 26 disclosure carries a conformed “s/” signature in type over a rule.11211816

Telephone numbers, fax numbers and e-mail addresses on these sheets are not reproduced here. The defendant’s witness list gives Louis Freeh two service addresses; one of the two is the street address that also stands in the sender block of the April 6, 2015 request. No address value is printed here.113

Footnotes

  1. Letter, Hon. Louis J. Freeh to Professor Alan Dershowitz, January 22, 2016, “RE: FOIA Request,” the fourth sheet of a six-sheet package. Read at the image at 400 dpi: one field on the sheet is withheld behind a redaction bar, the name of the person whose claim the request concerned; the signature is ink and the typed name beneath it reads “Louie Freeh.” The sender block prints the name, a telephone line and a business e-mail address whose domain is the Freeh Group’s own; no contact value from it is reproduced here. The four further copies of this letter that carry the same domain in their text layer were not opened at the image. https://epstein-data.com/EFTA01186699 p.4. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13

  2. “INVESTIGATION BY FORMER FBI DIRECTOR LOUIS FREEH CONCLUDES THAT THE TOTALITY OF THE EVIDENCE REFUTES ALLEGATIONS MADE AGAINST PROFESSOR DERSHOWITZ,” press release of April 8, 2016 carrying the Statement of Professor Alan M. Dershowitz and the Statement of Louis J. Freeh, with an editor’s note at its foot. Read at the image at 300 dpi: the Statement of Louis J. Freeh runs to two paragraphs, the second of them the “In my opinion” sentence quoted above; the contact line at the head of the sheet carries a business e-mail address in the law firm’s own internet domain, and no contact value from it is reproduced here. https://epstein-data.com/EFTA01186699 p.3. Further copies of the same release sit at https://epstein-data.com/EFTA01084160 p.3, https://epstein-data.com/EFTA01105096 p.1 and https://epstein-data.com/EFTA01186541 p.1; those three are cited here from the text layer only and were not opened at the image. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  3. Joint Pretrial Statement, No. 15-cv-07433-RWS, defendant’s witness list, item 18. Read at the image at 300 dpi. https://epstein-data.com/EFTA00792756 p.15. A second copy of the same instrument, also read at the image at 300 dpi, is at https://epstein-data.com/EFTA00617396 p.15. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  4. Declaration of Laura A. Menninger in Support of Defendant’s Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45, No. 1:15-cv-07433-RWS, Document 229, filed 06/20/16, item 4. Read at the image at 300 dpi. https://epstein-data.com/EFTA00605141 p.2. A second copy of the same declaration, filed as Document 1090-25 on 07/30/20, is at https://epstein-data.com/EFTA02782527 p.2. ↩ ↩2 ↩3

  5. Continued videotape deposition of Alan M. Dershowitz, Volume 2, pages 180 through 333, Friday, October 16, 2015, in Bradley J. Edwards and Paul G. Cassell v. Alan M. Dershowitz, Case No. CACE 15-000072, Circuit Court of the Seventeenth Judicial Circuit in and for Broward County, Florida. Read at the image at 300 dpi. The quoted answer begins at transcript p.215 line 22 and the answer about the requests being “very much in process” is at transcript p.216 lines 9–12. https://epstein-data.com/EFTA02726484 pp.36–37. ↩ ↩2 ↩3 ↩4

  6. Defendant/Counterclaim Plaintiff Alan M. Dershowitz’s Redacted Motion to Modify Confidentiality Order of January 12, 2016, Case No. CACE 15-000072, referring at p.4 to his earlier Motion for Clarification of Confidentiality Order or Relief from that Order filed January 29, 2016. Read at the image at 300 dpi: the sheet is heavily redacted around the passage quoted here. https://epstein-data.com/EFTA01079203 p.4. The January 29, 2016 motion itself is at https://epstein-data.com/EFTA01112265, cited here from the text layer only and not opened at the image. ↩ ↩2 ↩3

  7. Same argument, transcript p.13, Ms. McCawley. Read at the image at 300 dpi. https://epstein-data.com/EFTA00794556 p.13. The plaintiff’s name is redacted in the caption of this transcript at p.1, also read at the image at 300 dpi. ↩ ↩2

  8. E-mail, Nicholas Maisel to Martin Weinberg, copy to Alan Dershowitz, December 23, 2015, 7:25:09 AM EST, forwarded by Weinberg to Jeffrey Epstein at 12:46:32 +0000 the same day. Both zone markers are printed on the one sheet. Read at the image at 400 dpi: the firm is named twice on this sheet, once lower-case and once capitalised; four persons are named in the interview sentence and two of the four are barred; the subject of the investigation is behind a further bar; two further bars stand in the sentence about e-mail addresses; the signature block is printed type with no rule and no ink. The extraction of this sheet closes or corrupts every one of those bars. https://epstein-data.com/EFTA00704078 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  9. Searches were run against the corpus FTS5 index, never with LIKE. Counts on 2026-09-10: Freeh 125 pages across 85 documents; "Louis Freeh" 65; "Louis J. Freeh" 26; "Louie Freeh" 24; "Freeh Group" 1; the unspaced FreehGroup 5, of which only the sheet cited at 1 was opened at the image. FTS5 folds case, so those are upper bounds on proper-noun matching and lower bounds where OCR has damaged the name. Documents in which Freeh is written about rather than acting — a press report about a subpoena to a consulting firm, a 1993 FBI service citation on a curriculum vitae, an unrelated Florida police matter, a governance-panel roster and a passage about the Wen Ho Lee investigation — are outside the scope of this page and are not cited. ↩ ↩2 ↩3 ↩4

  10. Same argument, transcript p.76, Ms. McCawley. Read at the image at 300 dpi. The passage she reads aloud from the letter is the court reporter’s transcription of counsel reading, and differs in wording from the letter itself as printed at EFTA01186699 p.4. https://epstein-data.com/EFTA00794556 p.76. ↩ ↩2 ↩3

  11. FOIA request letter, April 6, 2015, addressed to the Deputy Chief FOIA Officer, The Privacy Office, Department of Homeland Security, signed in ink over the typed name Patti Bescript; the sixth sheet of the same package. Read at the image at 400 dpi. The sentence “I request access to and copies of For the period 1/1/01 to 1/1/03” is quoted as printed. https://epstein-data.com/EFTA01186699 p.6. ↩ ↩2 ↩3 ↩4 ↩5

  12. United States Secret Service, Freedom of Information Act and Privacy Act Branch, final response to FOIA/PA request, file number 20150826, over the ink signature of Kim E. Campbell, Special Agent In Charge, FOIA & Privacy Act Officer; the fifth sheet of the same package. Read at the image at 600 dpi and again at the native raster of the released page image (816 × 1056, 96 ppi): the Date field is a rubber stamp applied upside down and reads JAN 15 2016 when rotated 180°. https://epstein-data.com/EFTA01186699 p.5. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  13. “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz,” press release of April 8, 2016, the first two sheets of the same six-sheet package. Cited here only for the composition and order of the package. https://epstein-data.com/EFTA01186699 pp.1–2. ↩

  14. E-mail from “jeffrey E.” to David Stern, Sat, 09 Apr 2016 15:51:27 +0000, attaching AD_Statement_Package.pdf. Read at the image at 400 dpi: the message body stands above a standing confidentiality trailer, which is not quoted here; the Subject field is empty rather than redacted, the recipient’s address field carries a bar, and one name in the body is barred. “indpemetn” is on the face of the sheet. https://epstein-data.com/EFTA01186698 p.1. ↩ ↩2

  15. The New York Times, report of the settlement of Edwards and Cassell v. Dershowitz, copyright 2016 The New York Times Company, preserved in this release as a LexisNexis printout dated 4/30/2018 and stamped confidential under Fed. R. Crim. P. 6(e). Read at the image at 300 dpi; the text layer of this sheet renders “Dershowitz” as “Dershowtz” in the sentence quoted, and the image is followed here. Two names in the article are behind redaction bars on this copy. https://epstein-data.com/EFTA01368204 p.1. A second copy is at https://epstein-data.com/EFTA01412453 p.60, not opened at the image. ↩

  16. “DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES,” No. 15-cv-07433-RWS, dated February 24, 2016. Read at the image at 300 dpi: item 9 carries two redaction bars beneath the line “Address unknown at this time,” which the extraction closes; the signature is a conformed “s/ Laura A. Menninger” in italic type over a rule. https://epstein-data.com/EFTA01079536 p.3 (entry) and p.7 (date and signature). ↩ ↩2 ↩3 ↩4

  17. Defendant’s Response in Opposition to Plaintiff’s Omnibus Motion In Limine, No. 15-cv-07433-RWS, table of contents item 4. Read at the image at 300 dpi. https://epstein-data.com/EFTA00593364 p.2. ↩

  18. Same argument, transcript p.15, Ms. McCawley. Read at the image at 300 dpi. https://epstein-data.com/EFTA00794556 p.15. ↩

  19. Same argument, transcript p.49, counsel for the defendant. Read at the image at 300 dpi. https://epstein-data.com/EFTA00794556 p.49. ↩

  20. Oral argument before Hon. Robert W. Sweet, No. 15 Civ. 7433 (RWS), New York, March 31, 2017, transcript p.8, Ms. McCawley. Read at the image at 300 dpi. https://epstein-data.com/EFTA00794556 p.8. ↩

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