Scott Borgerson

Named on the documents as	”Scott Borgerson” in the From line of his own e-mail1 and on the payee line of a wire authorisation2; “Borgerson, Scott” in UBS’s own address-book rendering3; “SCOTT BORGERSON” on a bank statement addressee block4; “SCOTT G. BORGERSON” in a Suspicious Activity Report5; “Dr. Scott Borgerson” at the head of his letter to a federal judge6; “sgb” in his own sign-off7. Three documents in the release misspell him on their own face: “Scott Borgenson”8, an alternation between “MR. BORGENSON” and “MR. BORGERSON” inside one SAR narrative5, and “Scott Bergerson”9
Titles the documents give him	”CEO - CargoMetrics Technologies LLC” and “Scott Borgerson, Ph.D.”, in the signature block of a fund solicitation he wrote7; “CEO/CargoMetrics” in his own typed sign-off to UBS10; “Dr. Scott Borgerson” at the head of the bail letter6; “the CEO of the company I founded and built over the past decade”, in his own words in that letter, which does not name the company11. A bank’s SAR narrative says only that “INTERNAL RECORDS INDICATE THAT HE IS IN EXECUTIVE MANAGEMENT POSITION”, and attributes the rest to research it did itself5
Trust role	One of the three trustees of the Montpelier Trust, on UBS’s client-information sheet. An FBI analyst’s reading of the UBS trust signature page gives his signature date as 12/2/18, against 12/12/18 for the other two trustees. Covered at Angara Trust and Montpelier Trust12
Accounts in his name in these documents	A USAA Federal Savings Bank checking account titled “SCOTT BORGERSON OR GHISLAINE MAXWELL”; an account in his name at Citizens Bank, N.A.; an account at USAA into which a Montpelier Trust distribution was wired. Account numbers on the sheets cited here are not reproduced4213
Institutions that named him in a record	UBS Financial Services Inc.; USAA Federal Savings Bank; the United States Attorney’s Office for the Southern District of New York; the Federal Bureau of Investigation; a firm of accountants filing a joint income-tax return51415816
Documents cited here run from	14 March 2016, the date of a fund solicitation he wrote, quoted inside a forward three days later, to 11 December 2020, the timestamp printed on a draft income schedule. The last document in the set that he himself wrote is the letter of 19 November 20207176

Scott Borgerson is the man the release records as a trustee of one of Ghislaine Maxwell’s trusts, as the joint holder with her of a bank account, as the named beneficiary of a $2,500,000 transfer out of her UBS account, as the subject of two Suspicious Activity Reports, as the person whose card and cheque-account transactions were tabulated in a message about New Hampshire in the year before her arrest, and as the author of a letter to the judge in United States v. Ghislaine Maxwell supporting her application for bail. He is not recorded in these documents as having met Jeffrey Epstein; he wrote to the court that Epstein was “a person I have never met nor had any communication”.¹⁸

Nothing on this page is a finding of wrongdoing, and no document cited here charges him with anything. A Suspicious Activity Report is a report of suspicion filed by a bank, not a finding by anyone; the FBI’s own operation plan records that he “maybe a person of interest but is not an alleged subject”, and the bank that filed the fuller of the two reports also wrote that it “DID NOT IDENTIFY ANY NEGATIVE NEWS OR CRIMINAL HISTORY ON MR. BORGENSON.”¹⁹⁵ Where the record holds his own account of a matter, it is set out beside the record made of him.

Identity numbers, dates of birth, account and routing numbers, telephone and fax numbers, e-mail addresses and residential addresses printed on the sheets cited here are not reproduced on this page.

What this page does not repeat

Angara Trust and Montpelier Trust is the published account of the two trusts, and it names him twenty-one times, thirteen of them in its prose and infobox and eight inside its footnotes. It already carries: his trusteeship of the Montpelier Trust as entered on UBS’s client-information form; the summer-2018 correspondence with the trust’s accountants and its UBS advisers about the Angara Trust’s estimated taxes; his message of 12 September 2018 under the subject “trust renaming”; the March 2019 exchange about 1099s; the July 2019 quarterly distribution of $52,580.63 wired to his USAA account; and the June 2019 wire of $240,000 to a Citizens Bank account in the name of an LLC. None of that is restated here. This page takes the documents that page does not cite.

One of them bears directly on a question that page leaves open. That page records that “No document cited here states what the trust was renamed to”. A message of 20 December 2018 that page does not cite states it: writing to his UBS adviser, Borgerson refers to the money as needing to be “wired into Angara (now Montpelier)”.³ The two statements are consistent, because the earlier one is scoped to the documents that page cites; what that scoping left outstanding is answered by the message quoted in the sentence before this one.

The UBS correspondence: his own voice

Twenty-eight of the twenty-nine documents whose From: line carries his name belong to one body of correspondence, produced under UBSTERRAMAR stamps, between him, Maxwell and the UBS Private Wealth Management team of Scott Stackman and Lyle Casriel.²⁰ Four of those sheets are set out here.

14–17 March 2016. Under the subject “CargoMetrics fund opening”, a message headed “Dear Investor” announces that “CargoMetrics will open the Compass Fund to outside LP’s on Monday, April 4, 2016”, that “The portfolio’s composition of signals and targeted risk will be identical to that of the Blackstone Alternative Asset Management (BAAM) managed account that we have been trading”, and that “Founder’s class fees of 1.5/15 are being offered for the first $150M of AUM.” Its From: line reads “Borgerson, Scott” and its signature block reads “Scott Borgerson, Ph.D. / CEO - CargoMetrics Technologies LLC”.⁷

Above it on the same sheet, addressed “Dear Ghislaine” and signed “sgb”, stands a message that is not given its own header: “You may forward the below email and attached tear sheet to your contacts at UBS. For context, here’s a link to a recent article about CargoMetrics in Institutional Investor magazine. I’m happy to connect with them if they think there might be interest with their clients.” The words “here’s a link” are underlined on the sheet. The attribution of that middle message rests on the sheet itself and not on this page’s judgement: it is addressed to Ghislaine, it is signed with the same three initials that subscribe the message below it, and the message below it carries his name in its From: line.⁷

Maxwell forwarded the pair to Scott Stackman at UBS on 17 March 2016, writing: “Scott – see bellow for infö on the fund I told you about / Signing and returning the paperwork for Millennium today / Thx / G”. The spelling “bellow” and the diaeresis in “infö” are on the face of the sheet at 600 dpi and are not repaired here.⁷

20 December 2018. Under the subject “[External] Fwd: CargoMetrics Compass Fund - Fund Closing 12/31/18” he wrote to his UBS adviser: “Hi Lyle, good morning from Tokyo. This $1,035,313 needs to be wired into Angara (now Montpelier). Can you or someone in your office kindly call Denis at CargoMetrics to confirm the UBS account number for Angara/Monteplier and then confirm with me once done? Thank you, Scott”. The forwarded message beneath records that on 30 November 2018 “CargoMetrics Technologies LLC (the ‘Firm’) decided to close the CargoMetrics Compass Master Fund LP, CargoMetrics Compass Fund LP and CargoMetrics Compass Fund LTD (the ‘Funds’) effective as of December 31, 2018”, and gives the preliminary unaudited NAV of the investment as “approximately $1,035,313”. The investor being redeemed is named on the sheet as “Temporary Cookware”.³

The top-of-message Sent: field on that sheet, “12/20/2018 7:50:39 PM”, carries no time zone. Two things fix it. The sheet itself prints, immediately beneath, the forwarded message he was passing on, stamped “Date: Fri, Dec 21, 2018 at 4:40 AM”, ten minutes before 04:50 the next morning in Tokyo, and incoherent on any Eastern reading of the field above it. And a second copy of the same message in the release quotes it back as “On Thu, Dec 20, 2018 at 2:50 PM Borgerson, Scott wrote:”, five hours earlier, which is the offset of Eastern Standard Time from UTC in December. The unzoned field is therefore UTC, and 19:50 UTC on 20 December is 04:50 the next morning in Tokyo, which is consistent with the greeting he wrote. No zone is asserted for any other sheet on this page except where stated.³²¹

12 October 2018. Answering a UBS market note addressed “Scott/Ghislaine”, he wrote: “Thanks for the note Lyle and Scott and hello from California, the land of fruits and nuts. Keep calm and carry on.” He continued: “Let us know if you have an idea for our planned portfolio distribution over time if there is a particular opportunity, e.g. when we legged into MLP’s.” and “Otherwise, we’re cool.” The message is signed “sgb” above the line “Sent from iCloud”. The first person plural is his.¹

5 July 2019. Under the subject “[External] Re: Montpelier Trust: Blackrock European L/S” he replied to a message signed “Matt” over a signature block printing “Matthew R. Klein, CFA, CFP”, “UBS Private Wealth Management” and “Stackman | Casriel Group”: “Thanks Matt. Please send subscription documents for $1M to:”, and then, on two lines, “Scott Borgerson / CEO/CargoMetrics”. The To: line of his reply is covered by a bar, so the header as produced names no recipient; the man he was answering is identified here from his own opening words, “Thanks Matt.”, and from the signature block printed beneath the message he quoted, and not from the header.¹⁰

$2,500,000, 3 May 2016

The release holds an instrument and a statement entry that carry the same date, the same amount and the same payee. Neither is cited on the trusts page, and no document cited here states that the second executed the first.

A one-page letter dated May 3, 2016, on Ghislaine Maxwell’s personal letterhead whose address lines are barred, is addressed to Scott Stackman at UBS Financial Services Inc., Private Wealth Management, under the heading “RE: Wire Request”, set in bold italic. It reads: “Please use this letter as authorization to wire $2,500,000.00 from my UBS account ▮ titled Ghislaine Maxwell, to the instructions below.” Beneath it stand four lines: “Bank Name: Citizens Bank”; “Account Name: Scott Borgerson”; “Account Number:” and “Routing Number:”, the values of the last two covered by solid bars.²

The release carries the letter twice and the two copies differ in execution. On the copy at EFTA00238162 the space above the printed name “Ghislaine Maxwell” carries a uniform grey band and no ink stroke crosses it. On the copy at EFTA00238164 a manuscript signature in ink, of varying stroke width, runs across that space. Both were read at 600 dpi.²²²

The UBS Resource Management Account statement for May 2016, account name “GHISLAINE MAXWELL”, friendly account name “Ind:Cash/Saving”, records under “Account activity this month” a single entry in the “Bill payments” block: “May 3 / Withdrawal / ACH TO Scott Borgerson AT CITIZENS BANK, NA / -2,500,000.00”, and a “Total bill payments” of -$2,500,000.00. Total assets on that account on May 31, 2016 were $16,475,002.07. The account-number field on the sheet is barred.²³

His letter to the court four and a half years later says: “we rented a home together in Manchester in 2015, culminating in a more permanent arrangement when purchasing a home in 2016 where we lived peacefully and quietly in until Epstein’s arrest last year.”⁶ No document cited here connects that wire to that purchase, and the two are set out here in sequence and not as a transaction.

Joint accounts, a joint return, and the schedules built from them

The bank account. A USAA Federal Savings Bank statement for the period 01/16/19 – 02/14/19 is addressed to “SCOTT BORGERSON / OR GHISLAINE MAXWELL”, the address block beneath the two names covered by a bar. The account type is “USAA CLASSIC CHECKING”; the balance on the previous statement was 67,155.04 and the balance on that statement 32,797.33. The sheet carries the control number SDNY_GM_00010180. SDNY_GM_00010158 is stamped on a sheet of the Montpelier Trust’s UBS statement run, on sheet 155 of that 160-sheet run, printed “Page 3 of 6” of the June 2020 statement, so this joint personal account is stamped twenty-two numbers later in the same stamp series. Both control numbers were read at the image.⁴²⁴

The tax return. A covering letter from an accounting firm is addressed “SCOTT BORGERSON & GHISLAINE MAXWELL” and opens “DEAR SCOTT & GHISLAINE: ENCLOSED ARE YOUR 2019 INCOME TAX RETURNS, AS FOLLOWS…”, listing a “2019 U.S. INDIVIDUAL INCOME TAX RETURN”, a “2019 FEDERAL REPORT OF FOREIGN BANK AND FINANCIAL ACCOUNTS” and a “2019 MASSACHUSETTS INDIVIDUAL INCOME TAX RETURN”.¹⁶ A carryover schedule in the return run is headed “SCOTT G. BORGERSON & GHISLAINE MAXWELL” and carries a line reading “INCOME LIMITATION - CARGOMETRICS TECHNOLOGIES LLC”.²⁵

The schedule built from the return. An analysis headed “DRAFT - FOR DISCUSSION PURPOSES ONLY”, “Year: 2019”, breaks the Form 1040 income down by source. Four of its rows attribute an entity to a person: “Alphakeys Millennium Fund, LLC - Partnership - G. Maxwell”; “Angara Trust - G. Maxwell”; “Montpelier Trust - S. Borgerson”; and “Cargometrics Technologies LLC - Partnership - S. Borgerson (A)”, the last carrying $389,357 in the “Income (Loss) Trusts / Partnerships / LLC” column against the legend “(A) Guaranteed payment”. That figure and the legend are filled green on the sheet; seven cells of the TOTAL row in the left-hand block and the Other Income Subtotal cell of the right-hand block are filled yellow, and the other five cells of the right-hand block are unfilled. A fifth row reads “Cargometrics Technologies LLC - Partnership -” and stops there: on the sheet the printed label ends at the dash, with no name after it, no bar over it and no rule beneath it. The total taxable income for 2019 is given as 854,230. The company’s name is set on this sheet as “Cargometrics”, where the company’s own correspondence sets it “CargoMetrics”. The identifier is a run of three sheets and not one: the two sheets after it are the 2018 and the 2017 schedules in the same design, read at the image and not set out here.²⁶

The release holds a second draft of the same schedule, timestamped on its own face “12/11/2020 4:45 PM”. Four of its entity rows carry the first draft’s four attributions; a fifth attributes the second Cargometrics partnership row to S. Borgerson, where the first draft’s printed label leaves that name off altogether. That difference is UNVERIFIED, from the extraction of the second draft, which was not rendered; the first draft’s blank label was read at the image. The two drafts’ subtotal columns also differ, in the TOTAL row of the right-hand block. Neither draft is a return and both say on their face that they are drafts.¹⁷

The account summary. A three-sheet analyst’s schedule headed “SUMMARY OF GHISLAINE MAXWELL’S RELATED ACCOUNTS AS OF 6/30/2020 - DRAFT” lists as its first row “USAA FEDERAL SAVINGS BANK / SCOTT BORGERSON OR GHISLAINE MAXWELL”, balance $5,259.80, with the comment “(A) The balance stated for this account is as of 6/16/2020.” The account-holder’s statement address and account-number columns are barred across the whole sheet.¹³ Its second sheet records that “On 3/17/2020, $3,560.59 was transferred from the Montpelier Trust’s UBS account ▮ to the USAA Federal Savings Bank account titled Scott Borgerson Or Ghislaine Maxwell ▮”, and that “On 12/13/2019, Granite Reality LLC purchased that property in an all cash transaction for $1,070,800”, the property being the New Hampshire residence at which Maxwell was arrested; the schedule notes that “The address listed for Granite Reality LLC is 155 Seaport Blvd, Boston MA 02210-2698. The address, excluding the ZIP code, is identical to Montpelier Trust’s address.”²⁷ The same schedule states, of the trust of which he was a trustee, that “The relationship between Ghislaine Maxwell and the Montpelier Trust is unknown at this time.” The sentence printed immediately after it goes the other way: “It can be inferred that there is a relationship between Ghislaine Maxwell and the Montpelier Trust due to the following:”, and numbered grounds follow: two in the comment on the first sheet, three in the comment against a second Montpelier Trust account on the second, the 3/17/2020 transfer quoted above being one of the three and the Granite Reality purchase the last of both.¹³²⁷

What USAA reported, March 2020

A Suspicious Activity Report record in the release, an initial and joint report with a filing date of 03/11/2020, enters him as a subject: “Last(or Entity) Name BORGERSON / First Name SCOTT / Middle Name G”, role “Subject”, subject type “Both Purchaser and Payee”, and occupation “CEO of Cargo Metrics”. Ghislaine Maxwell is entered as the second subject on the same terms, occupation “Executive Management”. The structured Suspicious Activity block gives “Amount Involved $1,906,662” and “Date or Date Range of Activity 02/18/2015 - 10/17/2019”. Against the row labelled “Money laundering” it lists five values, “Other: Suspicion concerning the use of funds:”, “Suspicious EFT/wire transfers”, “Suspicious concerning the source of funds”, “Suspicious use of third-party transactors (straw-man)” and “Transaction out of pattern for customer(s)”; and against “Other suspicious activities”, “Human trafficking”. These are values printed in table rows on the sheet and not ticked boxes.²⁸

A later sheet of the same report carries the Law Enforcement Information block, which names “FBI New York Office” against a contact date of 03/02/2020.²⁹

The narrative sheets carry the filer’s name barred in places and printed in the clear in others as “USAA AMLI”. They open with the case identifier: “CASE ID: C2002421770 DISCOVERY DATE: 02/11/20 ADVISORY HUMAN TRAFFICKING”, and give the period of the activity as “BETWEEN 02/18/15 AND 10/17/19”, which is the period the structured field gives.²⁹²⁸

What the narrative says about him:

MR. BORGENSON IS 44 YEARS OLD, A 23-YEAR ▮ CUSTOMER AND CURRENTLY RESIDES IN MANCHESTER, MASSACHUSETTS. INTERNAL RECORDS INDICATE THAT HE IS IN EXECUTIVE MANAGEMENT POSITION, AND A SOCIAL MEDIA PRESENCE INDICATED HE IS THE CEO OF CARGO METRICS TECHNOLOGIES, A DATA SCIENCES COMPANY WORTH OVER $100M WHICH WAS CORROBORATED BY EXTERNAL RESEARCH.⁵

and, on the same sheet, ”▮ DID NOT IDENTIFY ANY NEGATIVE NEWS OR CRIMINAL HISTORY ON MR. BORGENSON.” The actor of that sentence is behind a bar on that sheet; it is named in the clear as USAA AMLI on a later sheet of the same document, which says of other parties “USAA AMLI DID NOT IDENTIFY NEGATIVE NEWS OR CRIMINAL HISTORY FOR ANGARA TRUST, MONTPELIER TRUST OR NUTTER MCCLENNEN & FISH LLP”.⁵³⁰

That last narrative sheet also records that “ADDITIONAL ACTIVITY WITHIN THE CUSTOMERS’ ACCOUNT CONSIST OF BILL PAYMENTS, PHONE PAYMENTS, AND AMERICAN EXPRESS CREDIT CARD PAYMENTS WHICH APPEARS TO BE NORMAL CONSUMER RELATED BEHAVIOR” and that “USAA AMLI DID NOT IDENTIFY SUSPICIOUS ACTIVITY WITHIN THE CUSTOMER’S OTHER USAA ACCOUNTS.”³⁰

The transactional account: “ON 02/11/20, ▮ CONDUCTED A REVIEW OF ALL ▮ ACCOUNTS HELD BY MR. BORGENSON AND MRS. MAXWELL, FOR THE PERIOD OF 02/04/15 TO 02/04/20.” Then: “ON 04/15/12, ▮ CREDIT CARD ACCOUNT ▮ HELD BY MR. BORGENSON AND MRS. MAXWELL WAS ESTABLISHED. ON 04/16/12, ▮ CHECKING ACCOUNT ▮ HELD BY MR. BORGENSON AND MRS. MAXWELL WAS ESTABLISHED.” And: “BETWEEN 02/18/15 AND 10/12/19, 95 ACH FUNDS TRANSFERS TOTALING $602,000.00 CREDITED ▮ CHECKING ACCOUNT ▮, RANGING FROM $1,000.00 TO $20,000.00. THE ORIGINATOR, SCOTT G. BORGERSON, UTILIZED EXTERNAL ACCOUNT ▮ AT CITIZENS BANK N.A., AS THE DEBITED”. The sentence continues on the sheet after the quoted words.⁵

Those two April 2012 dates sit awkwardly beside his own account. His letter to the court opens “I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend.”⁶ The narrative sentence is capable of two readings: that an account jointly titled from the outset was opened in April 2012, or that an account opened in April 2012 was, by the time of the review, held in both names. The same narrative sheet bears on which of the two is right. Of him it says “MR. BORGENSON IS 44 YEARS OLD, A 23-YEAR ▮ CUSTOMER”; of her, in the same paragraph, “MRS. MAXWELL IS 58 YEARS OLD, IS A THREE-YEAR ▮ CUSTOMER AND CURRENTLY RESIDES IN MANCHESTER, MASSACHUSETTS.” The same sheet dates the review to 02/11/20 and gives its period as “02/04/15 TO 02/04/20”; three years back from that is about 2017, which is after April 2012 and after the 2013 meeting he describes. Customer tenure and account titling are different facts, and no document cited here states when a second name was added to either account; but on the bank’s own figure she was not its customer in April 2012, and it is the second reading that fits what the sheet says.⁵

The bank’s conclusion, printed on the last narrative sheet, keeps the two questions apart:

ALTHOUGH MR. BORGERSON IS THE CEO OF A TECH COMPANY WORTH MILLIONS OF DOLLARS AND MRS. MAXWELL’S ANNUAL INCOME OF $250,000.00 TO $499,999.00 WITH A NET WORTH OF $1,000,000.00 IS ENOUGH TO SUBSTANTIATE THE FUNDS TRANSFERS, THE OVERALL ACTIVITY IS DEEMED SUSPICIOUS DUE TO THE UNKNOWN PURPOSE OF THE RENTAL PROPERTIES, THE ASSOCIATION AND ALLEGATIONS FOUND FOR MRS. MAXWELL TOWARDS HER POTENTIALINVOLVEMENT TO PROCURE SEX TRAFFICKING VICTIMS AND THE SCOPE OF JEFFREY EPSTEIN’S WEALTH, INFLUENCE AND EPSTEIN’S ABILITY TO SOURCE AND MOVE FUNDS TO SUPPORT HIS ALLEGED SEX TRAFFICKING APPARATUS.³⁰

“POTENTIALINVOLVEMENT” is set as one word on the sheet. The same sheet records that “ONLINE RESEARCH SHOWS ANGARA LLC WAS FORMED BY MRS. MAXWELL’S SISTER, CHRISTINE MAXWELL AND MR. BORGENSON. NO CONCLUSIVE INFORMATION WAS LOCATED FOR THE MONTPELIER TRUST.” That sentence is the bank’s own online research and is about an “LLC” and not about the Angara Trust.³⁰ The report gives its basis on the sheet before, and the basis is not what the closing sentence says it is. There the bank keeps its own research and the press apart: “ONLINE RESEARCH SHOWS ANGARA LLC TO BE A DOMESTIC LIMITED LIABILITY COMPANY FORMED IN 2016 IN WHICH RECORDS WERE MAINTAINED C/O NUTTER MCCLENNEN & FISH LLP. ADDITIONALLY, THERE IS A PUBLISHED ARTICLE THAT IDENTIFIES ANGARA LLC AS A TRUST FORMED IN 2016 BY MRS. MAXWELL’S SISTER, CHRISTINE MAXWELL AND MR. BORGENSON. THE COMPANY WAS DISSOLVED ON 01/02/18.” The bank’s own research reaches the company’s registration and the address at which its records were kept, and names nobody as having formed it; both names come from the published article, which the report does not identify. By the closing sheet that distinction is gone, and what the article is said to say is restated as what online research shows.³¹

Nine days before the filing, the Government had asked the bank not to close the accounts. A letter of the United States Attorney for the Southern District of New York dated March 2, 2020, headed “Re: Keep Accounts Open Request, CASE NUMBER C2002421770”, the same case number the SAR narrative carries, is addressed to “USAA – AML FIU” in Tampa and reads: “As discussed with Federal Bureau of Investigation Special Agent ▮, with respect to case number C2002421770, the Government respectfully requests that USAA Bank keep open until further notice bank accounts associated with the following individuals and account numbers, in connection to the prior grand jury subpoena served upon USAA Bank”. Two individuals are listed, “Ghislaine Maxwell, a/k/a Ghislaine Borgerson” and “Scott Borgerson”, each with a date-of-birth line and an identity-number line. No date of birth and no identity number printed on this sheet is reproduced here. The single account-number entry beneath is barred. The letter closes: “While we are aware that USAA Bank has the ultimate decision to keep open or close these accounts, we advise that closing the accounts would impact the progress of a criminal grand jury investigation.”¹⁵

A recorded voicemail transcribed in the release, from a caller identifying themselves as being “with USAA’s Compliance Department”, asks about “a case that we had some time ago where we apparently had Ghislaine Maxwell and Scott Borgenson had a Keep Account Open letter for those customers”, the previous letter having expired.³²

What UBS reported

A separate compilation in the release sets out the narratives of several Suspicious Activity Reports, one to a heading. Under the heading “SAR - 31000174054068” the narrative reads in full:

UBS Financial Services Inc. (UBS FS) is filing this Suspicious Activity Report (SAR) under the suspicion that Ghislaine ▮ may have attempted to hide her assets from federal courts, via various UBS accounts funded by Ghislaine ▮, by issuing wires to external accounts held or controlled by Scott Borgerson. According to recent media reports, Borgerson, who is the trustee on several of Maxwells UBS FS trust accounts, may be married to ▮ but she has refused to identify her spouse to court officials. In total, UBS FS is reporting twenty-nine (29) payments, which includes three (3) credit and twenty-six (26) debit payments, totaling $18,289,739.65, which occurred from December 18, 2014 to July 10, 2020, involving Maxwells UBS FS accounts and external bank accounts associated with Scott Borgerson.¹⁴

The paragraph beginning “Conclusion:” that stands immediately above that heading on the same sheet belongs to the preceding SAR and not to this one; it is separated from the Borgerson narrative by the heading. Nothing in it is attributed here to the UBS report.¹⁴

Two things in the UBS narrative are the bank’s own hedges and are carried here as such: the marital statement is prefaced “According to recent media reports”, and the whole is a statement of suspicion. The bank’s own note that Maxwell “has refused to identify her spouse to court officials” is what the sheet says; this page identifies nobody the sheet does not.

The record law enforcement built, 2019–2020

17 September 2019. Under the subject “Epstein update”, timed Tue, 17 Sep 2019 20:29:17 +0000, a message subscribed with the block “Crimes Against Children/Human Trafficking / FBI New York”, the name and telephone lines of which are barred, reads in full:

Maxwell’s boyfriend, Scott Borgenson, lives in Manchester By the Sea, MA, we spoke with the PD and they were in contact with him earlier in August. Maxwell was with him but left after all the media scrutiny. The PD has a good relationship with him. We are tracking a cell phone we believe belongs to Maxwell, we just subpoena’d for subscriber info., I will keep you posted.

The misspelling “Borgenson” and the contraction “subpoena’d” are on the face of the sheet at 600 dpi. The text of the message stands under three identifiers in the release, once on its own and once inside a reply, and no correct spelling of his surname returns any of the three.⁸³³

A list of his New Hampshire transactions. A screenshot of a sent message, headed “New Hampshire”, reads “Borgerson’s New Hampshire transactions from USAA checking and credit card.” and lists sixteen dated entries running from 3/10/19 to 9/29/19. Among them are a pub and a ski shop in Newbury on 3/10/19, an ATM withdrawal in Exeter and two pet shops on 5/20/19, and five entries for the same Hooksett restaurant, printed on the sheet as “COMMON MAN HOOKSET”, on 3/10/19, 4/6/19, 9/15/19, 9/27/19 and 9/29/19. Below the list the message begins “For your reference distance between Sutton and the cities mentioned above” and the screenshot is cut off part way through the first distance line; the truncation is on the face of the image and is not repaired here. One value at the head of the message is barred.³⁴

29–30 June 2020. An Amended Agent Affidavit filed under docket number 20 Mag. 6770 records that on 29 June 2020 United States Magistrate Judge Katharine H. Parker signed a warrant and order for a target cellphone, and that on the afternoon of 30 June the affiant realised the original affidavit “contained two inadvertent errors”. The second concerned him:

Second, the Agent Affidavit incorrectly stated that the Target Cellphone had been in contact with a phone identified as the Scott Borgerson Phone within the last 30 days. In fact, the Target Cellphone was most recently in contact with the Scott Borgerson Phone in or about March 2020. The errors resulted from my misreading of certain phone records for the Target Cellphone.

The explanation continues onto the next sheet: “while one column in those records indicated that the Isabel Maxwell Phone and Scott Borgerson Phone had themselves been active within the last 30 days, I mistook those dates to be the dates of those phones’ most recent contact with the Target Cellphone.”³⁵³⁶

The Amended Affidavit itself carries, on a later sheet of the same run, its own restatement of the description on which the corrected figure hangs: “The Target Cellular Device has also been in contact with a phone subscribed to in the name of ‘Scott Borgerson,’ which I know from my review of bank records and Amazon records is the name of an individual with whom GHISLAINE MAXWELL shares a joint bank account and to whom MAXWELL’s Amazon account has sent multiple packages within approximately the last year (the ‘Scott Borgerson Phone’). The most recent contact between The Target Cellular Device and the Scott Borgerson Phone occurred in or about March 2020.”³⁷

The same descriptive clause stands in other affidavits in the release, and the figure after it is not the same in all of them. Where the device is called “The Target Cellular Device” the clause is followed by “in or about March 2020”; where it is called “Target Cellphone-1” it is followed by “in or about August 2019”, and footnote 1 of the Amended Affidavit says of that second phone that “there were no errors in my affidavit with respect to Target Cellphone-1”.³⁵ No sheet returned by the searches set out below carries the erroneous “within the last 30 days” form of the clause; the original’s error stands on this record only in the amendment’s own account of it.³⁸

1 July 2020. An FBI Tactical Operation Plan, operation date 07/01/2020, case name “GHISLAINE MAXWELL”, briefing location the Sutton Police Department, records under Type of Operation two ticked boxes, “Arrest Warrant” and “Surveillance”, and under target-location assessment one ticked box, “Children Present”. The Case Number cell is a blank printed field with nothing entered in it; the case agent, assisting agent and supervisor names are covered by bars. The narrative reads in full:

The FBI’s New Hampshire Safe Streets Gang Task Force (NHSSGTF) is in direct support of the New York Field Office (NYFO) in order to locate and arrest GHISLAINE MAXWELL. MAXWELL is known to have three separate citizenships and is considered a flight risk.

On June 30, 2020, NH-2 and the NHSSGTF received information that MAXWELL maybe located in the Sutton, New Hampshire / Lake Sunapee region. MAXWELL is known to be the associate of (girlfriend of) Scott Borgerson. At time of writing Borgerson maybe a person of interest but is not an alleged subject.

The objective printed beneath is “To locate and safely arrest via federal arrest warrant GHISLAINE MAXWELL.”¹⁹

13 July 2020. Eleven days after the arrest, a message ran from an address whose only uncovered part reads “(NY) (FBI)” to an address whose only uncovered part reads “(USANYS)”, under the subject “Analysis of Recent UBS Production”, attaching a rollforward of the Montpelier Trust account. The memo lists the three sources from which the account was funded and states “There have no major transfers or disbursements from this account.”, as printed, before qualifying itself twice: “The attached analysis is a draft to be used for discussion purposes only and is subject to change” and “Once I have received a full set to Montpelier Trust Account statements, I will prepare a comprehensive analysis.” Its list of what the account-opening documents show gives the trustees’ signature dates: “Jeffery Roberts (signature date 12/12/18), Scott Borgerson (signature date 12/2/18) and Christine Yvonne Malina-Maxwell (signature date 12/12/18)”. The last of the three numbered lists on that sheet runs 1, 2, 3, 4, 5, 4, 5.¹²

The letter to the court, 19 November 2020

The release holds, as “Exhibit A” to a filing, a three-sheet letter headed “CONFIDENTIAL/PRIVILEGED/SEALED” and dated November 19, 2020. Beneath the date stands the line “Dr. Scott Borgerson”, and beneath that a solid bar. The letter opens “Dear Judge Nathan,” and “I respectfully submit this letter in support of Ghislaine Maxwell’s bail application.” It carries five bold headings, History, Home, Privacy, Separation, and “My support for her bail application”. Its numbered paragraphs run 1 to 13, with two consecutive paragraphs both numbered 13; ten further paragraphs carry no number at all, counted at the image over the three sheets and excluding the salutation and the five headings. It ends “With humility and deep compassion, I am also praying for Epstein’s victims.” There is no signature and no printed name at the foot of the letter; the name appears only at its head.⁶¹⁸¹¹

On how they met, and on Epstein:

1. I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend.

2. Ghislaine and I developed a friendship through a shared passion for ocean conservation which over time grew into a close personal relationship. As the years passed, we travelled extensively together, initially to ocean conferences, and then for leisure and she accompanied me on business travel. Her trips to Japan, the UK, and other countries over the last few years were for my legitimate business meetings. […]⁶

7. I was, of course, aware of Ghislaine’s previous relationship with Epstein, a person I have never met nor had any communication. The media coverage of Epstein is very different today than it was seven years ago when Ghislaine and I first met. To be clear, I met Ghislaine nearly two decades after the alleged crimes.¹⁸

On the allegations made against him online, in his own words: “Some of the outlandish conspiracy allegations on the internet have insinuated that I am somehow involved in trafficking, in cahoots with Ghislaine for nefarious activities, or shielding her criminal activity. These ridiculous comments on the internet could not be further from the truth. I (we) lived a law abiding and innocent life.” He described one Twitter comment “speculating that I am a spy (not true)”, and wrote “I have zero knowledge of any videos or other outlandish conspiracy theories.”¹⁸

On the New Hampshire property, in the paragraph that the account schedules and the operation plan run alongside:

I assisted in the purchase of the New Hampshire property not for the purposes of evading law enforcement – there was never a warrant out for her arrest and her lawyers reported being in regular contact with the prosecution offering Ghislaine’s assistance – but for the sole reason of protecting her and my family from the media.¹⁸

On his own position: “This summer I resigned as the CEO of the company I founded and built over the past decade because my presence was becoming a distraction to an otherwise fantastic business.” He gave as his ground for vouching for her: “As a military veteran and a patriot of deep conviction and character, I believe wholeheartedly in Ghislaine’s commitment to stand trial and not to seek to leave the jurisdiction should her bail application be successful.”¹¹

The letter is also the record of what he says the coverage cost his household. He wrote that he is “the father of two minor children” and that he and their mother share custody; nothing further about them is set out here.⁶ He described “constant, 24/7 media intrusion from helicopters and drones hovering overhead, to long range photographers stationed in boats, cars and on foot”, that “The local police department has nobly tried to protect my family, at one point parking a marked car in my driveway”, and that “I have filed multiple harassment reports with the police, including against ‘journalists’ trying to physically enter my house.”¹⁸

The letter was checked. A law-enforcement document headed “Review of individuals who submitted letters for Maxwell”, the heading bold and underlined, lists him first on its first sheet: “1. Scott Borgerson”, a barred line beneath the name, then a database entry of five items of which four are barred and the third is labelled “SSN:”, and then “b. NYPD Checks: Negative”. Isabel Maxwell and Christine Maxwell follow on the same terms. The entry against Christine Maxwell reads “b. NYPD Checks:” with nothing after it, an empty printed field and not a bar. The document is a run of six sheets and the review continues on the five after this one, reviewing further letter-writers on the same form; nothing from those sheets is used here.³⁹

His denial is in the record too, at one remove. An internal message of 6 December 2019 under the subject “Borgerson article”, subscribed with the block “Detective / NYPD / FBI / Child Exploitation Human Trafficking Task Force”, carries a link and a headline: “Scott Borgerson denies he’s dating Jeffrey Epstein pal Ghislaine Maxwell - New York Post”, with the preview text “The man rumored to be dating Jeffrey Epstein’s former lover and alleged madam Ghislaine Maxwell has completely denied any romance between the pair”. This page reports the message and its preview text, which is what the release holds; the article itself is not among the documents cited here.⁴⁰ A second press text in the release, from a different outlet, reports a refusal rather than a denial: “Borgerson declined to comment on his relationship with Maxwell when contacted by the Daily Mail.”⁴¹

And the resignation reached the FBI from outside. An e-mail of 3 October 2020 from a correspondent outside the bureau, forwarded two days later by a Special Agent of the FBI in Boston, reads: “You may have seen that Scott Bergerson (Ghislaine Maxwell’s reputed husband) resigned from his tech startup. That leads me to believe the Maxwell deposition is likely to be unsealed.” The misspelling is on the face of the sheet at 400 dpi, not an artefact of the extraction, and it is the only reason that document is reachable by any search on his surname.⁹

What the search returned

The corpus of released files was searched with the FTS5 index on 2026-09-10 in the forms below. Counts are pages and documents as stated.

• "Scott Borgerson": 314 pages in 149 documents
• "Borgerson": 590 pages in 215 documents
• Borgerson* (prefix): 592 pages in 216 documents
• "Borgerson, Scott": 22 pages in 15 documents
• "S. Borgerson": 8 pages in 5 documents
• "Scott G Borgerson": 192 pages in 24 documents
• "BORGERSON/SCOTT": 22 pages in 15 documents
• "Ghislaine Borgerson": 76 pages in 51 documents
• "Dr. Scott Borgerson": 1 page in 1 document

The surname alone reaches 66 documents that the full name does not, so the full-name figure is not the record. "Dr. Scott Borgerson" returns one document because the second copy of that same letter is damaged, as set out below.²⁰

Damaged and mistyped forms. Twenty forms were probed. Four reached documents that no correct spelling reaches, and the damage is of two different kinds:

form	pages / docs	outside the surname set	this subject
"Borgenson"	8 / 5	4	4 — three copies of the 17 September 2019 FBI message and one USAA voicemail transcript
"Bergerson"	2 / 2	2	1 — the 3 October 2020 message; the other is a different person’s surname in an HSBC fund table
"Burgerson"	1 / 1	1	1 — one law-enforcement record
"Scott Bor" (two tokens)	6 / 6	4	3 — the second copy of the bail letter and the two copies of the May 2016 wire authorisation; the fourth is a homograph

Nine documents are therefore reachable only through a damaged or broken form, and every one of the nine is this subject, being 4 + 1 + 1 + 3 across the four rows above, counted from the rows and not from the total. Two of the four productive forms are misspellings on the face of the document: “Borgenson” in the FBI message and in the SAR narrative, and “Bergerson” in the outside correspondent’s message. Both were confirmed at the image rather than inferred from the extraction. The "Burgerson" document was not rendered and whether that spelling is the writer’s or the extraction’s is not established here. The third kind is extraction damage: the second copy of the bail letter extracts as “Dr. Scott Bor erson” with the g lost, and both copies of the wire authorisation extract as “Scott Bor erson” and “Scott Bor son” where the sheets print “Scott Borgerson” at 600 dpi. A copy of his own letter to a federal judge is invisible to every correct spelling of his name.^2042222

These forms returned nothing: "Borgersen", "Borgersou", "Borgerscn", "Borqerson", "Borgeson", "Borgersoa", "Borgerrson", "Borgerton", "Borgersoo", "Borgeron", "Borgersn", "Borgarson", "Borgersson", "Bogerson", "Borqersen", "Borgersor", "Bcrgerson", "Borgeraon", "Borgersori", "Borgersonn", "Borgersan", "Dorgerson", "Borgerbon". "Borgcrson", "Borgerso", "orgerson", "B0rgerson" and "Sorgerson" returned only documents already inside the surname set.²⁰

Homographs, sampled before use. "Borgers" returns 34 pages in 33 documents, of which 32 are outside the surname set and none is this subject: the bulk are copies of one complaint text naming an accounting firm, plus a Swedish networking list. "Bergerson" carries one further person of that surname in a fund performance table. "Scott Bor" returns one 1,000-sheet DOJ-OGR- document in which no literal “Scott Bor” occurs in the extraction; the index match is an adjacency between a hyphenated surname ending “-Scott” and an unrelated capitalised fragment, and that document is excluded. Its PDF path answers HTTP 403 and it could not be read at the image; the exclusion rests on the extraction.²⁰

Act against mention. Every one of the 590 pages returned by the surname was classified mechanically, and each of the 215 documents was assigned its strongest page class. A document was counted as authored only where his name stands in the From: field of an e-mail header block, parsed label by label:

class	documents	share
a sheet whose From: line names him — he is the author	29	13.5%
addressed to him on a To: or Cc: line	11	5.1%
a bank statement, credit file, subscriber record, tax schedule or account form	41	19.1%
a calendar entry, appointment or reminder	37	17.2%
a court filing, affidavit, subpoena, SAR or other law-enforcement record	53	24.7%
something else	44	20.5%

Thirty of the forty-four documents in the last row were read in the extraction and hand-classified. Not one is authored by him. Five are news or report texts about him, one of them circulated inside the FBI; fourteen are law-enforcement or prosecution records the mechanical rule missed (an operation plan, three interview records, four analysts’ schedules, three internal e-mails, a Suspicious Activity Report, a compilation of SAR narratives, a review of the letter-writers); five are copies of the UBS client-information form that names him a trustee; two are bank statements of an account of Maxwell’s carrying a transfer to him; two are affidavits; one is a consumer-reporting record; and one is a fund tear sheet attached to a message of his. The parts of that decomposition were counted separately from the total, and they sum to thirty.

The bail letter is his own composition and the mechanical rule classes it with the court filings. Counting it, 30 of 215 documents, 14.0%, or about one document in seven, carry something he wrote. The remaining six in seven list, address, schedule, analyse or report him. And the authored seventh is narrower than it looks: twenty-eight of the twenty-nine belong to a single body of correspondence with one bank. One further document in the authored class, a 2,266-sheet card-expense run, is a false positive of the header rule and is not his correspondence. Duplication across the whole set is heavy: three copies of one FBI message, two of the bail letter, two of the wire authorisation, and at least five of one UBS client-information form all appear as separate documents.²⁰

Two absence statements, and what would falsify each. The 2023 FinCEN deconfliction correspondence in the release, in which the FBI was asked whether it objected to the release of information about named people, is not reached by "Deconfliction request" AND "Borgerson" (0 pages) or by "deconflict" AND "Borgerson" (0 pages). That is a statement about those two searches only: rows on those lists are barred, and a name behind a bar cannot be returned by any query. Separately, no document cited on this page records a response by him to either Suspicious Activity Report, to the keep-open letter or to the account schedules. The searches run to test that, and what each returned, are: "Borgerson" AND "denies" returns 1 page, the New York Post item above; "Borgerson" AND "declined to comment" returns 3 pages in 3 documents, which is where the Daily Mail refusal quoted above was found; "Borgerson" AND "responded" returns 5 pages in 4 documents, being the same press texts and one interview record; "Borgerson" AND "attorney for" returns 1 page, the same press text; and "Borgerson" AND "statement" returns 187 pages in 30 documents, inspected as a set and containing no response of his. The subject line and header block of every one of the 29 authored documents were also inspected in order, since a response need carry none of those words. The first two of those searches did return something, and it is on the page. None of them reaches a response to the bank filings, which is the narrower statement made here.²⁰

Note on the documents

Sheets read at the image. Thirty-nine sheets across twenty-four documents were rendered locally and read at the image: thirty-six at 400 dpi and three at 600 dpi, the latter where a spelling or the presence of ink decided the finding. Four of the 400 dpi sheets were re-read in part at 600 dpi: one whole field, cropped, to settle a single character; one line to settle a diaeresis; one two-line heading to settle which of its lines carries a rule; and one paragraph to settle the wording of a sentence quoted above. Every quotation on this page other than those in footnotes marked otherwise is taken from a page image. Ten of the forty-two footnotes below are marked UNVERIFIED, from a search hit, each saying so in those words and saying what verifying it would cost. Where a footnote lists further copies of a document that were resolved by search rather than opened, it says which of them were read at the image and which were not.

Field states. The line beneath “Dr. Scott Borgerson” at the head of the bail letter is barred; the letter’s foot carries no signature and no printed name at all. The Case Number cell of the operation plan is an empty printed field. “b. NYPD Checks:” against the third name on the letter-writers review is an empty printed field, where the same line against the first two names carries the word “Negative”. The signature space on the wire authorisation at [^loa] carries a uniform grey band with no ink; the second copy at [^loasigned] carries an ink signature of varying stroke width crossing the same space. The account-number, routing-number, identity-number and address values on the sheets cited here are barred except where the footnote says otherwise, and no such value is reproduced on this page in either case.

Faults in the text layer that matter to anyone re-deriving this page. The extraction of the bail letter’s header reads “CONFIDENTIAUPRIVILEGED/SEALED” where the sheet prints “CONFIDENTIAL/PRIVILEGED/SEALED”, and reads “intemet” where the sheet prints “internet”. The extraction of the second copy of that letter reads “Dr. Scott Bor erson”. The extraction of both copies of the wire authorisation breaks the surname the same way. On one UBS statement the extraction reads “ACH TO Scott Borgerson AT OWENS BANK, NA” where a second copy and the image read “CITIZENS BANK, NA”. On the Suspicious Activity Report the extraction of the structured date field reads “02/18/2016” where the sheet prints 02/18/2015, a one-character substitution that would, if taken as the sheet, manufacture a disagreement with the narrative’s “BETWEEN 02/18/15 AND 10/17/19” that does not exist. On two UBS subject lines the extraction reads “[External’” and “‘External]” where both sheets print [External], and on one of them it ends the subject “European LA” where the sheet prints European L/S. On the income schedule the extraction reads “Aiphakeys” where the sheet prints Alphakeys, reads 2,318 and (19413) where the sheet prints 2,338 and (19,513), and reads “EEC” in both Cargometrics row labels where the sheet prints LLC. In each of these the sheet was read at the image and the pin is to the sheet; a string search run against the extraction will land elsewhere or nowhere, and the pins should not be moved on that account. A pin checker run against the extraction reports eleven rows on this page, in three groups, and none of them is a wrong pin. The row count is not itself meaningful, because it rises and falls with the number of quotations sharing a line, so the groups are what to read. Nine rows are one group: the July 2019 subject line, whose printed form the extraction of the sheet it is pinned to does not carry while a later copy in the same run does. One is the phrase “The Target Cellular Device”: that is the name used on the later sheets of the affidavit run and in the other affidavits listed here, and the sheet pinned beside it is the sheet of the paragraph discussing them rather than a sheet that prints the phrase. One is the heading “SAR - 31000171404867”, which stands on the first sheet of that two-sheet compilation while the pin is to the second sheet, which carries the close of that report’s narrative and the whole of the report quoted here. The checker’s own report calls the last two not locatable and no evidence either way, which is exactly what they are, and both pinned sheets were read at the image for this page. A fourth row of the same kind is no longer reported at all, and only because the income schedule’s footnote now cites all three sheets of its run: the row label quoted from the 2019 sheet stands cleanly in the extractions of the 2018 and 2017 sheets and is damaged in the 2019 sheet’s own. None of the four is a reason to move a pin. Against those, three of the misspellings on this page are on the sheets themselves and not extraction faults: “Borgenson”, “Bergerson”, and, inside one narrative, an alternation between “BORGENSON” and “BORGERSON”. Each was settled by opening the image rather than by trusting the index.

Typography stated on this page, and how it was settled. Enumerated by reading the page through rather than by searching it for markup, there are ten of them, in prose and in the footnotes: five headings in the bail letter are bold; “RE: Wire Request” on the wire authorisation is bold italic; “here’s a link” in the March 2016 message is underlined; on that same sheet the forwarded sender name “Borgerson, Scott” is bold while the From: label is regular; on the December 2018 sheet the sender name “Dietz, Denis” is bold on each of the two forwarded blocks while the From: labels are regular; on the July 2019 sheet the signature block’s name, “UBS Private Wealth Management” and “Stackman | Casriel Group” are bold; the heading and the three names on the first sheet of the letter-writers review are bold and underlined; the heading of the March 2020 keep-open letter is set over two lines, both bold, with the rule under the second line only; the figure 389,357 and the “(A) Guaranteed payment” legend on the income schedule are filled green; and seven cells of the income schedule’s TOTAL row in its left-hand block, with the right-hand block’s Other Income Subtotal cell, are filled yellow while the other five cells of that block are unfilled. Each was checked at the image, and no emphasis is asserted inside any quotation on this page. Two things deliberately fall outside that set and should not be counted back into it by a later pass: the grey band and the ink signature on the two copies of the wire authorisation, which are field states and are set out under “Field states” above; and the setting of any value covered by a bar, which cannot be observed and is nowhere asserted here. The paragraph numbering of the bail letter (1 to 13 with 13 used twice, and ten further paragraphs unnumbered) is a count and not a typographic claim, and was made at the image on the three sheets.

Times. Only one clock claim is made: the unzoned top-of-message field on the 20 December 2018 sheet is UTC, established from the forwarded stamp printed on that sheet itself and from a second copy that quotes it back in Eastern Standard Time. Every other date on this page is taken from a printed calendar date, an RFC Date: header carrying +0000, or a form field, and no interval is computed across two unzoned clocks.

Related

• People: Ghislaine Maxwell; Jeffrey Epstein; Isabel Maxwell
• Entities: Angara Trust and Montpelier Trust; UBS Private Wealth Management; The TerraMar Project; Southern District of New York
• Topics: Offshore financial structures

Sources

Footnotes

1. E-mail, Scott Borgerson, Sent 10/12/2018 1:30:14 PM, subject “Re: Volatile Markets”, carrying beneath it a UBS market note of “On Oct 11, 2018, at 09:16 PM” addressed “Scott/Ghislaine,”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00239159 p.1. Stamped UBSTERRAMAR00003827 and marked CONFIDENTIAL. The To: and CC: lines, and the sender line of the quoted note, are covered by bars; no address on the sheet is reproduced here. The top-of-message Sent field carries no time zone and no clock time from this sheet is printed on this page. ↩ ↩²

2. Letter of authorisation, Ghislaine Maxwell to Scott Stackman, UBS Financial Services Inc., Private Wealth Management, dated May 3, 2016, headed “RE: Wire Request” in bold italic. Read at the image at 600 dpi. https://epstein-data.com/EFTA00238162 p.1. Stamped UBSTERRAMAR00002610 and marked CONFIDENTIAL. Two address blocks — the letterhead’s own and the addressee’s — are covered by bars, as are the account reference in the operative sentence and the values against “Account Number:” and “Routing Number:”; none is reproduced here. The sheet prints “Account Name: Scott Borgerson”; the extraction reads “Scott Bor erson”. Above the printed name “Ghislaine Maxwell” the sheet carries a uniform grey band and no ink stroke. ↩ ↩² ↩³ ↩⁴ ↩⁵

3. E-mail, Borgerson, Scott to Lyle C, Sent 12/20/2018 7:50:39 PM, copied to Denis Dietz and Ghislaine Maxwell, subject “[External] Fwd: CargoMetrics Compass Fund - Fund Closing 12/31/18”, carrying two forwarded messages from Dietz, Denis, the outer stamped “Date: Fri, Dec 21, 2018 at 4:40 AM” and the inner “Mon, Dec 17, 2018 at 10:05 AM”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00239488 p.1. Stamped UBSTERRAMAR00004160 and marked CONFIDENTIAL. Every e-mail address on the sheet is barred, as is the account reference after “FFC: Cookware a/c”; none is reproduced here. On each of the two forwarded From: lines the sender name “Dietz, Denis” is bold and the From: label is regular; the address between the angle brackets is covered by a bar, so nothing is asserted here about how it is set. The subject line prints a square bracket: the apostrophe in “[External’” exists only in the extraction and is not on the sheet. ↩ ↩² ↩³ ↩⁴

4. USAA Federal Savings Bank statement, account type “USAA CLASSIC CHECKING”, statement period 01/16/19 – 02/14/19, addressed “SCOTT BORGERSON / OR GHISLAINE MAXWELL”. Read at the image at 400 dpi. https://epstein-data.com/EFTA01266498 p.16. Stamped SDNY_GM_00010180 and EFTA_00120834. The addressee’s address block, the account-number field, one cheque number and a wide column of transaction detail are covered by bars, and no value from any of them is reproduced here. The run at this identifier is 103 sheets and holds USAA checking statements and credit-card statements. The comparison with SDNY_GM_00010158 is arithmetic on two printed control numbers, each read at the image for this page: 10180 − 10158 = 22. ↩ ↩² ↩³

5. The same report, narrative sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA01654856 p.6. Carries the page stamp EFTA01654861. SUPPRESSED; citation permitted. The filer’s name, several account references and several figures on this sheet are covered by bars, marked ▮ in the quotations above, and no barred value is reproduced here. The sheet prints “MR. BORGENSON” and “MR. BORGERSON” in alternation within the same paragraph; both forms are reproduced as printed. No address, account number or identity number from this sheet is reproduced here. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

6. Letter, “Dr. Scott Borgerson” to “Judge Nathan”, November 19, 2020, headed CONFIDENTIAL/PRIVILEGED/SEALED, first sheet of three, produced as “Exhibit A”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00154393 p.2. Carries the page stamp EFTA00154394 and footed “1 | P a g e”. The line beneath the printed name is covered by a solid bar and nothing from it is reproduced here. The headings “History”, “Home” and “Privacy” are bold on the sheet. The extraction of the top line reads “CONFIDENTIAUPRIVILEGED/SEALED”; the sheet prints slashes. The elision marked in the blockquote of numbered paragraph 2 above stands for one further sentence of that paragraph concerning his children, which is not set out here under the policy stated in the text. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

7. E-mail, G Maxwell to Scott Stackman, Sent 3/17/2016 4:25:50 PM, subject “FW: CargoMetrics fund opening”, attachment “CM Feb. tearsheet.pdf”, carrying below it a message addressed “Dear Ghislaine” and signed “sgb”, and below that a forwarded message whose header reads “From: Borgerson, Scott” (bold on the sheet), “Date: Mon, Mar 14, 2016 at 10:01 AM”, “Subject: CargoMetrics fund opening”, signed “sgb” over “Scott Borgerson, Ph.D. / CEO - CargoMetrics Technologies LLC”. Read at the image at 400 dpi, and the line “Scott – see bellow for infö on the fund I told you about” re-read at 600 dpi to settle the diaeresis. https://epstein-data.com/EFTA00238074 p.1. Stamped UBSTERRAMAR00002518 and marked CONFIDENTIAL. Every e-mail address on the sheet is covered by a bar and none is reproduced here. The words “here’s a link” are underlined on the sheet. The top-of-message Sent field carries no time zone and no clock time from this sheet is printed on this page. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

8. E-mail, subject “Epstein update”, Tue, 17 Sep 2019 20:29:17 +0000, subscribed with a signature block reading “Crimes Against Children/Human Trafficking / FBI New York”. Read at the image at 600 dpi. https://epstein-data.com/EFTA00103746 p.1. The From: and To: lines, the sender’s name in the signature block, the salutation and the sign-off, and the office and mobile telephone lines are all covered by bars; nothing from any of them is reproduced here and no role or attribute is supplied for the barred sender beyond the two lines the signature block itself prints. The sheet prints “Scott Borgenson” and “subpoena’d”; both are reproduced as printed. ↩ ↩² ↩³

9. E-mail chain, subject “FW: [EXTERNAL EMAIL] - Epstein again”, Mon, 05 Oct 2020 14:05:09 +0000, carrying beneath it an outside correspondent’s message of “Saturday, October 3, 2020 9:24 PM” under the subject “[EXTERNAL EMAIL] - Epstein again”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00038124 p.1. Stamped EFTA00038124. The From:, To: and Cc: lines of both messages, both salutations, both sign-offs, one quoted line in the body and the desk, cell and name lines of a signature block reading “Special Agent / FBI – Boston” are covered by bars; nothing from any of them is reproduced here, and no role, employer or gender is supplied for any barred sender beyond the two lines that signature block itself prints. The sheet prints “Scott Bergerson”; that spelling is the correspondent’s and not an artefact of the extraction, which was the point of rendering it. ↩ ↩²

10. E-mail, Scott Borgerson, Sent 7/5/2019 2:43:54 PM, subject “[External] Re: Montpelier Trust: Blackrock European L/S”, quoting a message of “On Jul 5, 2019, at 10:30” whose sender line is barred and which is signed “Matt” over a signature block printing, in the clear and in bold, “Matthew R. Klein, CFA, CFP”, “UBS Private Wealth Management” and “Stackman | Casriel Group”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00239672 p.1. Stamped UBSTERRAMAR00004408 and marked CONFIDENTIAL. The address values in the From:, To: and CC: lines, the whole of the To: line, the sender line of the quoted message, six lines of the signature block and the two lines beneath his own sign-off are covered by bars, and no address value from any of them is reproduced here. The recipient is therefore not named in the header as produced; the name used above is supplied from his own opening words, “Thanks Matt.”, and from the signature block beneath the message he was answering, both of which stand on this sheet, and not from the To: line. The subject line prints a square bracket and ends “L/S”; the forms “‘External]” and “LA” exist only in the extraction of this sheet and are not on it. A consequence for anyone re-deriving this page: because the extraction of p.1 carries the damaged form, a string search for the subject as printed lands on p.2 of the same run, where a later copy of the thread extracts cleanly. The pin here is to the sheet, which was read at the image; it should not be moved. ↩ ↩²

11. The same letter, third and last sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA00154393 p.4. Carries the page stamp EFTA00154396 and footed “3 | P a g e”. The heading “My support for her bail application” is bold. Two consecutive paragraphs are both numbered 13; that was counted at the image. The letter ends with the sentence quoted in the text and carries no signature line, no rule and no printed name below it. ↩ ↩² ↩³

12. E-mail, “(NY) (FBI)” to a redacted addressee at “(USANYS)”, subject “Analysis of Recent UBS Production”, Date: Mon, 13 Jul 2020 16:49:33 +0000, attachment “Montpelier_Trust_Acct_…_Rollforward_V1.pdf”, the account reference in the filename not being reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA01654877 p.1. Stamped EFTA01654877. Every name and address in the header block is covered by a bar, as are fifteen account references, a telephone line, an e-mail line and a delivery-instruction line in the body; nothing from any of them is reproduced here and no attribute is supplied for any barred person. The sentence “There have no major transfers or disbursements from this account.” is reproduced as printed. The sheet carries three numbered lists: the funding-sources list runs 1, 2, 3; the UBS Trust Signature Page list runs 1, 2, 3; and the UBS Client Information list runs 1, 2, 3, 4, 5, 4, 5. The lists, their items and the fifteen barred account references were counted at the image. ↩ ↩²

13. One of three sheets headed “SUMMARY OF GHISLAINE MAXWELL’S RELATED ACCOUNTS AS OF 6/30/2020 - DRAFT”. Read at the image at 400 dpi. https://epstein-data.com/EFTA01654892 p.1. The “ACCOUNT HOLDER’S STATEMENT ADDRESS” and “ACCOUNT NUMBER” columns are covered by one solid bar running the height of the table, and no value from either is reproduced here. ↩ ↩² ↩³

14. Compilation of Suspicious Activity Report narratives, second of two sheets, carrying the close of the narrative under the heading “SAR - 31000171404867” and, beneath its own heading “SAR - 31000174054068”, the whole of the UBS Financial Services Inc. narrative quoted above. Read at the image at 400 dpi. https://epstein-data.com/EFTA01648787 p.2. Carries the page stamp EFTA01648788. The surname after “Ghislaine” is covered by a bar in three places on this sheet and the value after “may be married to” is covered by a bar; none is supplied here. The heading structure — that the “Conclusion:” paragraph at the head of the sheet closes the preceding report rather than opening this one — was established at the image and not from the extraction: the first sheet of the same document was read at 400 dpi for this page, carries one narrative filed by a different bank, and ends with that preceding report’s heading with no text beneath it. ↩ ↩² ↩³

15. Letter of the United States Attorney for the Southern District of New York, March 2, 2020, “VIA EMAIL”, to USAA – AML FIU, Tampa, Florida, headed, over two lines, “Re: Keep Accounts Open Request,” and “CASE NUMBER C2002421770”. Both lines are bold; the rule runs under the second line only, and the first line is not underlined. Read at the image at 400 dpi, with the heading re-read and cropped at 600 dpi to settle which of the two lines carries the rule. https://epstein-data.com/EFTA00038450 p.1. The attention line, one further addressee line, the named Special Agent, both identity-number lines and the single account-number entry are covered by bars. No date of birth and no identity number printed on this sheet is reproduced here. ↩ ↩²

16. Covering letter of an accounting firm addressed “SCOTT BORGERSON & GHISLAINE MAXWELL”, enclosing 2019 federal, FBAR and Massachusetts returns. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA01654997 p.1. A second copy is at https://epstein-data.com/EFTA00025558 p.1. Cited for the addressee line and the list of enclosures; verifying would cost one page render. ↩ ↩²

17. A second draft of the same schedule, carrying “12/11/2020 4:45 PM” on its own top line. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA01654993 p.1. Cited for the existence of a second draft and its timestamp; for its five entity-attribution rows, of which four repeat the first draft’s attributions and the fifth attributes a second Cargometrics partnership row to S. Borgerson; and for the difference between the two drafts’ subtotal columns. The second draft’s rows rest on its extraction alone and verifying them would cost one page render; the first draft’s corresponding rows, including the blank after the dash on its fifth, were read at the image. The difference claim is made only on the TOTAL row of the right-hand block, where the first draft prints two values at the image that the second draft’s extraction does not carry; it deliberately excludes the cells identified in the note above as faults in the first draft’s own extraction, which are not differences between the drafts at all. The second draft’s extraction damages the first of the five rows the same way the first draft’s does, reading “Aiphakeys” for Alphakeys. ↩ ↩²

18. The same letter, second sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA00154393 p.3. Carries the page stamp EFTA00154395 and footed “2 | P a g e”. Paragraphs 6 and 7 run together with no blank line between them on the sheet. The heading “Separation” is bold. The extraction reads “intemet” twice where the sheet prints “internet”. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

19. “FBI Tactical Operation Plan”, U.S. Department of Justice / Federal Bureau of Investigation, case name GHISLAINE MAXWELL, operation date 07/01/2020, briefing location Sutton Police Department, North Sutton NH. Read at the image at 400 dpi. https://epstein-data.com/EFTA00149884 p.1. Stamped EFTA00149884. The case agent, assisting agent and on-scene supervisor names are covered by bars. The Case Number cell is empty printed white space, distinguished at the image from those bars. The ticked boxes were counted at the image. ↩ ↩²

20. Full-text search of the release (full_text_corpus.db, pages_fts, FTS5) on 2026-09-10, in the forms and with the counts set out under “What the search returned”. FTS5 folds case and folds combining accents, so proper-noun counts are upper bounds for exact-case matching and lower bounds wherever the extraction has damaged the name. Statements about what a search returned describe that search and are not claims about the contents of the release as a whole. The "Borgenson", "Bergerson", "Burgerson", "Scott Bor" and "Borgers" sets were resolved document by document; the seven documents identified as this subject and outside the surname set were read in the extraction, and three of them — one copy of the September 2019 FBI message, the October 2020 message and both copies of the wire authorisation — were then read at the image. The characterisation of the remaining "Borgers" documents rests on the extraction only. The act-against-mention table was produced by parsing each page’s e-mail header block label by label and assigning each document its strongest page class; the thirty-document sample of the residual class was read in the extraction only, and the mechanical rule is known to misclassify at least one long expense run as authored. Counts of pages and of documents are stated separately throughout because they are not the same unit. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

21. A second copy of the same thread in the release, carrying a later message of Dietz, Denis of 12/24/2018 12:10:13 PM above it and quoting Borgerson’s message as “On Thu, Dec 20, 2018 at 2:50 PM Borgerson, Scott < > wrote:”. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA00239490 p.1. Stamped UBSTERRAMAR00004162. It is cited only for the quoted-back local stamp used to fix the zone of the unzoned field on the sheet at the previous note; verifying it would cost one page render. ↩

22. A second copy of the same letter in the release. Read at the image at 600 dpi. https://epstein-data.com/EFTA00238164 p.1. Stamped UBSTERRAMAR00002612 and marked CONFIDENTIAL. The same fields are barred. On this copy a manuscript signature in ink, of varying stroke width, crosses the space above the printed name; the signature is described and not reproduced. The extraction of this copy reads “Scott Bor son” and truncates the printed name beneath the signature. ↩ ↩²

23. UBS Financial Services Inc., Resource Management Account statement, May 2016, account name GHISLAINE MAXWELL, friendly account name “Ind:Cash/Saving”, financial advisers SCOTT STACKMAN/LYLE CASRIEL, sheet marked “Page 6 of 8”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00022407 p.6. Carries the page stamp EFTA00022412. The account-number field is covered by a bar and no account number is reproduced here; the adviser telephone lines printed in the header are business numbers and are not reproduced here either. The “Bill payments” block on this sheet carries exactly one entry and its total equals that entry. ↩

24. UBS Financial Services Inc., Resource Management Account statement, June 2020, account name MONTPELIER TRUST, friendly account name “Mont Hedge Fund”, financial advisers SCOTT STACKMAN/LYLE CASRIEL, sheet marked “Page 3 of 6”, closing account value $4,841,818.09. Read at the image at 400 dpi. https://epstein-data.com/EFTA01597667 p.155. Carries the page stamp EFTA01597821 and the control number SDNY_GM_00010158. This document is SUPPRESSED in this desk’s registers; citation and quotation are permitted. The account-number field and one further value at the foot are covered by bars and no account number is reproduced here. The run at this identifier is 160 sheets, so p.155 is not its last sheet. Cited only for the control number and the sheet’s own page marking. The same account and balance are also covered at Angara Trust and Montpelier Trust. ↩

25. “Tax Return Carryovers to 2018” schedule headed “SCOTT G. BORGERSON & GHISLAINE MAXWELL”, carrying the line “INCOME LIMITATION - CARGOMETRICS TECHNOLOGIES LLC” against Form 6765 and “SCH E P2”. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA00025624 p.9. Carries the page stamp EFTA00025632. Verifying would cost one page render. No identifier printed on this sheet is reproduced here. ↩

26. First sheet of a three-sheet run of schedules, headed “DRAFT - FOR DISCUSSION PURPOSES ONLY”, “Year: 2019”, “(IN USD)”, breaking total income reported on Form 1040 down by source. Read at the image at 400 dpi. https://epstein-data.com/EFTA01655019 p.1. The run is three sheets, not one: pp.2 and 3 are the 2018 and the 2017 schedules in the same design, each read at the image at 400 dpi for this page and neither set out here. Five rows on p.1 name an entity and a partnership or trust; the fifth ends at the dash, with no name printed after it, no bar over the space where a name would stand and no rule beneath it. The cell carrying 389,357 in the “Income (Loss) Trusts / Partnerships / LLC” column and the legend “(A) Guaranteed payment” are filled green; in the TOTAL row, seven cells of the left-hand block and the Other Income Subtotal cell of the right-hand block are filled yellow and the other five cells of the right-hand block are unfilled. Those fills were counted and read at the image. The sheet sets the company’s name “Cargometrics”. ↩

27. The second sheet of the same schedule, carrying the comment against a second Montpelier Trust account. Read at the image at 400 dpi. https://epstein-data.com/EFTA01654892 p.2. The account references inside the comment column are covered by bars, as is the whole of the statement-address and account-number block for the row. No residential address printed on this sheet is reproduced here. ↩ ↩²

28. Suspicious Activity Report record, “Type of Report Initial Report / Joint Report”, filing date 03/11/2020, received 03/11/2020, entered 03/12/2020, “Submission Method Electronic batch filing”; Subject Information entering “Last(or Entity) Name BORGERSON / First Name SCOTT / Middle Name G” and, as a second subject, “Last(or Entity) Name MAXWELL / First Name GHISLAINE”. Read at the image at 400 dpi, with the Suspicious Activity block on sheet 3 re-read at 600 dpi and cropped. https://epstein-data.com/EFTA01654856 pp.1-4. This document is SUPPRESSED in this desk’s registers; citation and quotation are permitted. The date-of-birth, identity-number, address, telephone and e-mail fields against each subject are covered by bars, and no value from any of them is reproduced here in any state. The structured “Date or Date Range of Activity” field on sheet 3 prints 02/18/2015 - 10/17/2019; the extraction of that row reads 02/18/2016, and the sheet, not the extraction, is followed here. ↩ ↩²

29. The same report, the sheet carrying the Filer Information and Law Enforcement Information blocks and the opening of the narrative, including “Agency Name FBI New York Office”, “Contact Date 03/02/2020” and “CASE ID: C2002421770 DISCOVERY DATE: 02/11/20 ADVISORY HUMAN TRAFFICKING”. Read at the image at 400 dpi. https://epstein-data.com/EFTA01654856 p.5. Carries the page stamp EFTA01654860. SUPPRESSED; citation permitted. The filer’s name, its identity number, every line of its address, its contact name and telephone, and the law-enforcement contact’s name and telephone are covered by bars; nothing from any of them is reproduced here. The narrative’s “BETWEEN 02/18/15 AND 10/17/19” and the structured field’s “02/18/2015 - 10/17/2019” on sheet 3 were each read at the image and they agree. ↩ ↩²

30. The same report, the last narrative sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA01654856 p.8. Carries the page stamp EFTA01654863. SUPPRESSED; citation permitted. Two centred blocks at the head of the sheet, a tall bar down the right margin and one block at the foot are covered by bars; the right-margin bar stands on every sheet of this run. The closing line of the narrative prints a business telephone number and a law-enforcement mailbox address; neither is reproduced here. “POTENTIALINVOLVEMENT” is set as one word on the sheet. ↩ ↩² ↩³ ↩⁴

31. The same report, the narrative sheet preceding the last. Read at the image at 400 dpi and the quoted paragraph re-read at 600 dpi. https://epstein-data.com/EFTA01654856 p.7. Carries the page stamp EFTA01654862. SUPPRESSED; citation permitted. The sheet prints “MR. BORGENSON”; the alternation with “MR. BORGERSON” across this narrative is described at the note above. The published article the sheet refers to is not named, dated or otherwise identified on it, and nothing here is offered for the article’s own accuracy. ↩

32. Transcript of a recorded call from a caller identifying themselves as “with USAA’s Compliance Department”, concerning the expiry of a keep-account-open letter. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA00104842 p.1. The transcript masks the caller’s name, callback number and address with asterisks on its own face. Verifying would cost one page render. ↩

33. Two further copies of the same message in the release, at https://epstein-data.com/EFTA00037554 p.1 and, quoted inside a reply of Tue, 17 Sep 2019 20:30:38 +0000 reading “Very helpful, thanks. Much appreciated. Keep me posted.”, at https://epstein-data.com/EFTA00039885 p.1. UNVERIFIED, from a search hit: neither sheet was rendered. Cited for the existence of the copies and for the reply; verifying would cost two page renders. ↩

34. Screenshot of a sent message headed “New Hampshire”, reading “Borgerson’s New Hampshire transactions from USAA checking and credit card.” above sixteen dated merchant entries and the opening of a distance table. Read at the image at 400 dpi. https://epstein-data.com/EFTA00037958 p.1. One value at the head of the message is covered by a bar. The screenshot’s own status bar shows a clock with no date; no date is asserted for the message itself. The image is cut off part way through the first line of the distance table and that truncation is on the face of the screenshot. The count of sixteen entries was made at the image. ↩

35. Amended Agent Affidavit in support of a second warrant and order, filed under docket number 20 Mag. 6770, paragraph 11. Read at the image at 400 dpi. https://epstein-data.com/EFTA00020372 p.12. Carries the page stamp EFTA00020383 and footed “5” over the date stamp “2019.07.24”. One value in footnote 1 on the same sheet is covered by a bar and is not reproduced here. ↩ ↩²

36. The same affidavit, next sheet, carrying the continuation of paragraph 11 and paragraph 12. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA00020372 p.13. Carries the page stamp EFTA00020384. Cited for the explanation of the mechanism of the error, quoted above from the extraction; verifying would cost one page render. ↩

37. The Amended Agent Affidavit, the sheet carrying sub-paragraph e of the probable-cause paragraph and, beneath it, numbered paragraph 13 and the heading “III. Request for Second Warrant and Order”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00020372 p.14. Carries the page stamp EFTA00020385 and footed “7” over the date stamp “2019.07.24”. This is the same document as the two sheets at the previous notes, and the quotation above is its own text and not the original Agent Affidavit’s: sheet 12 of the same run states that the original Application and Agent Affidavit are attached to it as “Exhibit C”, and searching this twenty-sheet run for "Scott Borgerson Phone" returns pp.12, 13 and 14 only, so no sheet of that exhibit as produced here carries the clause.³⁵ Numbered paragraph 13, printed two lines below the clause on this sheet, reverts to calling the device “the Target Cellphone”. ↩

38. How the descriptive clause was traced through the release. pages_fts (FTS5) was searched on 2026-09-11 for the phrase "Scott Borgerson Phone", which returns 31 pages in 13 documents; every one was read in the extraction, and fourteen pages in thirteen documents carry the clause itself. On seven of them the device is named The Target Cellular Device and the recency figure is in or about March 2020: https://epstein-data.com/EFTA00020372 p.14, https://epstein-data.com/EFTA00018663 p.6, https://epstein-data.com/EFTA00080555 p.14, https://epstein-data.com/EFTA00091719 p.14, https://epstein-data.com/EFTA00096012 p.14, https://epstein-data.com/EFTA01251062 p.14 and https://epstein-data.com/EFTA01251115 p.52. On the other seven the device is named Target Cellphone-1 and the figure is in or about August 2019: https://epstein-data.com/EFTA00016349 p.12, https://epstein-data.com/EFTA00026494 p.12, https://epstein-data.com/EFTA00073438 p.12, https://epstein-data.com/EFTA00091750 p.12, https://epstein-data.com/EFTA00100600 p.12, https://epstein-data.com/EFTA00152347 p.12 and https://epstein-data.com/EFTA01251062 p.46. Three of the fourteen were read at the image at 400 dpi: EFTA00020372 p.14, EFTA01251115 p.52 and EFTA00073438 p.12. So was the caption sheet of the second of those, https://epstein-data.com/EFTA01251115 p.48, which reads “IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE” over “AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR A SEARCH WARRANT” and is sworn by Amanda Young, a Special Agent of the Federal Bureau of Investigation. The remaining eleven clause-bearing sheets rest on the extraction and none of the device names or recency figures listed here is quoted from an image except on those four sheets. The search "Scott Borgerson Phone occurred within the last 30 days" returns 0 pages and "the Scott Borgerson Phone occurred" returns 14; no sheet returned by either carries the erroneous form. Those are statements about those searches and about the 31 pages read, and a form the extraction has damaged would not be returned by any of them. ↩

39. Law-enforcement document headed “Review of individuals who submitted letters for Maxwell”; its first sheet lists Scott Borgerson, Isabel Maxwell and Christine Maxwell. Read at the image at 400 dpi. https://epstein-data.com/EFTA01653692 p.1. The run is six sheets, not one: the review continues on pp.2-6 with further letter-writers on the same form, and none of those sheets is cited, quoted or relied on here. On that sheet the heading and the three names are bold and underlined. Under each name a line is covered by a bar; under “a. Accurint:” five sub-items are listed of which four are covered by bars, the third labelled “SSN:”. No value from any barred field is reproduced here. Against the third name the line “b. NYPD Checks:” is followed by nothing — an empty printed field, distinguished at the image from the bars elsewhere on the sheet. ↩

40. E-mail, subject “Borgerson article”, Fri, 06 Dec 2019 18:02:02 +0000, carrying a link, a headline and preview text for a New York Post item of 15 August 2019, and subscribed “Detective / NYPD / FBI / Child Exploitation Human Trafficking Task Force”. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA00037580 p.1. The From: and To: lines and the office, cell and fax lines of the signature block are blank in the extraction and their state on the sheet was not established; verifying would cost one page render. No telephone or fax value from this sheet is reproduced here. ↩

41. Press text held in the release, 27 sheets, reporting on Maxwell after Epstein’s death and carrying the sentence quoted. UNVERIFIED, from a search hit: this sheet was not rendered. https://epstein-data.com/EFTA00040358 p.9. Cited only for the refusal it reports; verifying would cost one page render. The same sheet reports that Maxwell’s lawyer had not responded to requests for an interview. ↩

42. A second copy of the same three-sheet letter, also produced as “Exhibit A”, at https://epstein-data.com/EFTA00065658 pp.2-4. UNVERIFIED, from a search hit: these sheets were not rendered. Cited only for the existence of a second copy and for the fact that its extraction of the head of the letter reads “Dr. Scott Bor erson”, which is why no correct spelling of the surname returns this document; verifying the sheets would cost three page renders. ↩