Epstein Data Wiki

Grand jury subpoenas to the e-mail providers, 2017–2020

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tagstopic, sdny, grand-jury, subpoena, non-disclosure-order, google, oath-holdings, yahoo, stored-communications-act, 2017, 2018, 2019, 2020
aliasesGoogle subpoenas, subpoena to Google, Oath Holdings subpoena, Yahoo subpoena, 2705(b) non-disclosure orders, service provider subpoenas, Google returns

42 min read

What this page coversFive grand jury subpoenas issued out of the Southern District of New York to two e-mail providers between July 2017 and August 2020, the secrecy orders that accompanied three of them, and the letters the providers sent back. Three of the five are in the released files as instruments; two are known only from the answers to them
13 July 2017, GoogleCase 17MAG5207, USAO reference 2017R00550. Alleged violation: 18 U.S.C. §§ 1341, 1343. Return date 21 July 2017. Secrecy ordered for 180 days by an order dated the day before. Signed in the name of Joon H. Kim, Acting United States Attorney12
19 December 2018, Oath Holdings, Inc. (formerly Yahoo)Case 18MAG10783, USAO reference 2018R01618. Alleged violation: 18 U.S.C. §§ 1591, 1594(c), 2422(b). Return date 4 January 2019. The order grants 365 days of secrecy; the covering letter in the same filing tells the provider 180. Signed in the name of Geoffrey S. Berman, United States Attorney345
19 December 2018, GoogleNot in the documents read for this page as an instrument. Its date, and the three accounts it named, are recorded in Google’s answer to it6
23 October 2019, GoogleCase 19 MAG 9975, USAO reference 2018R01618. Alleged violation: 18 U.S.C. §§ 1591, 371. Return date 7 November 2019. Secrecy ordered for 180 days by an order hand-stamped the same day. The rider names Ghislaine Maxwell789
26 August 2020, GoogleNot in the documents read for this page as an instrument. Its date, its case number 20 MAG 9134 and its reference 2018R01618 are printed in Google’s answer to it10
What a subpoena could reachEach application states that 18 U.S.C. § 2703(c)(2) lets the government obtain “enumerated subscriber information and certain other non-content information” from a provider by grand jury subpoena. Not the contents of the mail1112
What Google producedAccount-information text files, authenticated by a certificate and a list of hash values. Three files in January 2019, two in December 2019, one archive in September 202061314
What Google refusedAny account the government had not named by its own identifier. The December 2019 letter grounds the refusal in the limits of § 2703(c)(2); the September 2020 letter repeats it and adds the First Amendment and a reported case about a bulk subpoena to Amazon1516
Non-disclosure instrumentsThree per filing in each Google case: a court order, a sentence in the covering letter asking to be told before the provider ever notifies anyone, and a separate printed request on the subpoena itself81718
Documents readFourteen, 58 sheets, every sheet read; 27 of those sheets also read at the page image at the only resolution the released files hold, 96 pixels to the inch19

Page limits. Nothing on this page is a finding of wrongdoing, and no allegation is made here against anyone. A grand jury subpoena is an investigative demand, not an accusation, and the printed words “an alleged violation of” above a statute number are not a charge. No person is named here who is not named in print on the sheet cited for them; where a producing party has covered a name or a field, this page does not supply it from the surrounding text, does not characterise it, and says nothing about what any mark covers. No telephone number, fax number, e-mail address, identity number, date of birth, account number or payment-card number is reproduced here from any sheet cited, whether printed on it or demanded by it; where an account is named it is named as a provider’s own prose names it, without a domain. This page does not cover any document whose subject is a complainant or a survivor, and the one document it cites that touches such material is cited for two entries on a different sheet from the one that carries it.

Between July 2017 and September 2020 the United States Attorney’s Office for the Southern District of New York went to two e-mail companies five times for the records behind a set of accounts, and each of the three subpoenas that survives in the released files as an instrument came with a court order forbidding the company to tell anyone. Three of those subpoenas are in the released files; all five are accounted for, because the two that are not are named and dated in the providers’ answers to them. Read side by side the filings and the answers show two things the subpoenas alone do not: that the office was working under two different case references with two different sets of statutes, and that from December 2019 onwards Google was refusing part of what it was asked for and saying in writing why.

The five subpoenas, in order

The earliest of them is the subject of its own page: a nine-sheet filing of 13 July 2017 to Google, Inc. demanding the records of every mail account on a single domain, under the mail-fraud and wire-fraud statutes, with a secrecy order signed the day before. Its face page bears a handwritten signature above a printed block of three lines, reading “JOON H. KIM”, then “Acting United States Attorney for the”, then “Southern District of New York”; its order is dated by hand stamp “JUL 1 2 2017” over the typed rule and carries the typed s-signature “S/Andrew J. Peck”.12 See the July 2017 subpoena to Google for that filing sheet by sheet.

That filing was built over three consecutive days: the application is dated 11 July, the order is stamped 12 July, and the subpoena and its covering letter are dated 13 July.2021 The two later filings were quicker. The Oath Holdings application, order, letter and subpoena are all dated or stamped 19 December 2018; the October 2019 application is dated the 22nd and everything else the 23rd.12453118177

Seventeen months later the same office went to Oath Holdings, Inc., the company that had been Yahoo. A preservation request went by e-mail on 12 December 2018.21 The subpoena followed a week later, on 19 December 2018, in an eight-sheet filing built from the same four instruments as the 2017 one: a sealed application, a signed order, a covering letter, and the subpoena with its rider and a blank custodian’s declaration.3452223 On the same day, on the evidence of Google’s reply to it, a subpoena also went to Google.6

Ten months after that, on 23 October 2019, a third filing went to Google: nine sheets, the same instruments again, under the same case reference as the Oath subpoena but naming different statutes.78179 It appears in the released files twice over, as two separate documents.24

The last of the four is known only from the answer to it. Google’s letter of 1 September 2020 is headed “Re: Grand Jury Subpoena dated August 26, 2020 (Google Ref. No. 3971083)” and, on the line beneath, “2018R01618; 20 MAG 9134”.10 Neither that subpoena nor its order is among the documents read for this page.

Two case references, two sets of statutes

The USAO reference number printed in the caption of each filing is the office’s own file number for the grand jury matter. The 2017 filing to Google carries 2017R00550. The December 2018 filing to Oath, the October 2019 filing to Google and the August 2020 subpoena all carry 2018R01618.24810

A search of the released files on 25 October 2026 returns 2017R00550 on 2 sheets in 1 document, and 2018R01618 on 794 sheets across 442 documents. The same search returns helpfulexperts, the domain the 2017 rider was addressed to, on 1 sheet in 1 document. The index searched held 2,925,025 sheets across 1,425,556 documents on the same day; the controls run with these figures are named in the footnote.25

The statute lines do not stay fixed under the second reference. The 2017 subpoena names 18 U.S.C. §§ 1341 and 1343, the mail-fraud and wire-fraud statutes.1 The December 2018 subpoena to Oath, under 2018R01618, names §§ 1591, 1594(c) and 2422(b).3 The October 2019 subpoena to Google, under that same reference, names §§ 1591 and 371. One statute kept, two dropped, one added, ten months apart in the same matter.7 All three statute lines were read at the page image. Why the line changed is not stated on any sheet read for this page.

The order said 365 days. The letter said 180.

The Oath Holdings filing of 19 December 2018 contains both a court order and a covering letter, on consecutive sheets, and they do not agree about how long the company had to keep quiet.

The order’s operative paragraph reads in full: “Oath Holdings, Inc. (the “Service Provider”) shall not, for a period of 365 days from the date of this Order (and any extensions thereof), disclose the existence of this Order or the attached subpoena, to the listed subscriber of the accounts referenced in the subpoena, or to any other person, except that the Service Provider may disclose the attached subpoena to an attorney for the Service Provider for the purpose of receiving legal advice.”4 The application asks for 365 days twice, in paragraphs 1 and 4.12

The covering letter, dated the same day and addressed to the company’s legal department, reads: “Pursuant to the accompanying non-disclosure order issued under 18 U.S.C. § 2705(b), you are prohibited from notifying any subscriber or other third-party of the existence of this subpoena for a period of 180 days from the date of the order. If you ever plan to notify the relevant subscriber(s) of the existence of this subpoena, even after the 180-day period, please advise me before you do so, in case the investigation remains ongoing and the order needs to be renewed.”5

Both figures were read at the page image on their own sheets. The order binds for a year; the letter tells the recipient the bar runs for half that, and then calls it “the 180-day period”.

The letter is a standard form. The covering letter in the October 2019 Google filing is the same letter word for word in this passage, and there the figure of 180 days matches the order it accompanies.178 So does the equivalent passage in the July 2017 filing.26 That is as far as the documents go. Whether the Oath letter’s 180 is an unamended form figure, and whether the company acted on the order or on the letter, is not recorded on any sheet read for this page, and this page does not resolve it.

What a grand jury subpoena could not reach

Each application tells the court what kind of material is being sought and under what authority. The October 2019 application to the court reads: “Section 2703(c)(2) of Title 18 authorizes the Government to obtain enumerated subscriber information and certain other non-content information from a provider of an electronic communication service or a remote computing service via grand jury subpoena.”11 The Oath application carries the same sentence.12

That is the frame for everything the providers sent back. A subpoena of this kind reaches who held the account, when they logged in and from where, how long they had been a customer and how they paid. Not the messages. The riders ask for exactly those categories: subscriber identifying information in a lettered list of ten items, session times and durations and addresses, length and types of service, means and source of payment, account notes and customer-service correspondence, and any investigative file or user complaint about the subscriber.922

The October 2019 rider to Google goes further than either of the earlier riders in two numbered demands that neither of them contains. One asks for “Any and all call records”, with usage details, text-messaging records, login records and “any additional accounts associated with any of the below-listed names, identifiers, addresses, phone numbers, and accounts”, running “from the date of registration of the phone number to present”. The other asks for the subscriber information of any other number on the same account, and of “any other accounts billed to any subscriber at the same address as the listed number(s), or using the same name, email address, phone number, mailing address, or payment information”.27 Those are the demands Google answered by refusing.

The rider’s lead-in asks for “all records for any accounts registered to or associated with the following identifiers:”, and three bulleted labels follow, printed in bold: Name, Phone numbers and Email addresses. The name given is Ghislaine Maxwell. No telephone number and no e-mail address is reproduced from this sheet.9

The Oath rider of December 2018 is addressed differently. It opens “Please provide all records for the following accounts:” and lists four accounts, all at one mail domain, none of which is reproduced here.22 Where the Google rider’s last numbered demand asks for investigative files or user complaints concerning “the subscriber, account, or phone number”, the Oath rider’s asks about “the subscriber, account, or email address”: the same form, with the identifier class changed to suit the provider.922

What Google refused, and how the refusal grew

Google’s letter of 30 December 2019, answering the October 2019 subpoena, says in terms what it would not do:

“Google objects and has not produced records associated with Google accounts for which you have not expressly provided an account identifier or which derive from records or other information of the subject account(s) that you seek to have Google search. Because this exceeds the scope of 18 U.S.C. § 2703(c)(2), Google requires a court order pursuant to 18 U.S.C. § 2703(d) based on specific and articulable facts showing that the account(s) linked by cookies or other identifiers is relevant and material to your investigation for the duration of the time period requested.”15

The same letter reports a search that found nothing: after “a diligent search and reasonable inquiry” the company had “found no records for the sign-in phone number(s)” named in the rider, and adds a flat correction of the premise. It reads: “The primary account identifier for most Google services is an email address, not a phone number.”28

Eight months later, answering the August 2020 subpoena, the company repeated the objection almost word for word and extended it. The clause about derived accounts is the same, with “cookies or other identifiers” replaced by “secondary email address”. Then it adds a second ground:

“Moreover, bulk requests for information about a large number of unidentified or unspecified Google users is both burdensome to Google and may implicate the First Amendment or other rights of Google users. See In re Grand Jury Subpoena to Amazon.com Dated August 7, 2006, 246 F.R.D. 570, 573 (D. Wis. 2007) (applying First Amendment analysis to grand jury subpoena for bulk Amazon customer data). To the extent you seek information about additional Google accounts, Google can comply with legal process that expressly contains an account identifier for each of those accounts that you determine are relevant to your investigation.”16

The 2020 letter raises a third limit on a further sheet: “Please note that a subpoena is not sufficient process to compel production of the account status associated with the specified account.”29 It reports two further nil results, one for an identifier that “is not unique and cannot be associated to a specific subscriber’s account”, and one where a diligent search found no records for a named account-holder at all.30

A search of the released files for the sentence that opens the objection returns 4 sheets in 4 documents. Two of those four documents are the two letters quoted here; the other two are further copies of the December 2019 letter, which is in the released files three times over. A copy is not an answer: on the documents read for this page, two distinct Google letters carry the objection, in December 2019 and September 2020, and the January 2019 letter does not.256

What Google actually sent

Three Google answers are among the documents read for this page, and each has the same shape: a letter, a certificate of authenticity signed under 28 U.S.C. § 1746 with a typed signature in the form “/s_”, and an attachment listing the files produced with their hash values.

The letter of 15 January 2019 answers the subpoena of 19 December 2018 and names what it enclosed: “Accompanying this letter is responsive information to the extent reasonably accessible from our system associated with the Google account(s), JEEVACATION, JEEITUNES, JEFFREYEPSTEINORG, as specified in the Grand Jury Subpoena.”6 The attachment lists three files, one per account, each an account-information text file.31 The certificate is dated the same day and gives the custodian’s name as Richard Daugherty.32

The letter of 30 December 2019 answers the October 2019 subpoena. Its attachment lists two account-information files; the account names are not reproduced here. The certificate gives the custodian as Jeremy Paduano and is dated 12/30/19.1333

The letter of 1 September 2020 answers the August 2020 subpoena. Its attachment lists a single file, a subscriber-information archive. The certificate gives the custodian as Albert Sanchez and is dated 09/01/20.1434

None of the three letters carries a handwritten signature, and neither does any of the three certificates. Each letter is signed in type over the line “Google Legal Investigations Support”, and each certificate carries a typed signature in the form “/s_” followed by the custodian’s name, on the rule printed “(Signature of Records Custodian)”.63310 Oath’s custodian signed by hand.35

A search of the released files for the line “Google Legal Investigations Support” returns 13 sheets in 13 documents; this page reads three of them.25

The same account name at two providers, and only one had it

The December 2018 subpoena to Oath Holdings and the December 2018 subpoena to Google were issued on the same day, and each named an account whose name is written the same way.

Google’s answer of 15 January 2019 produced an account-information file for JEFFREYEPSTEINORG, and the letter says the accounts it covers were “as specified in the Grand Jury Subpoena”.631 Oath’s answer of 16 January 2019 reports the reverse: “The user accounts … and jeffreyepsteinorg, as specified in your request, are not valid Yahoo email addresses or Yahoo IDs at this time; therefore Oath did not produce any information responsive to your request.”36 The omission marked in that quotation is a second account identifier printed on the sheet, and it is not reproduced here.

The same name therefore existed as a live account at one provider and not at the other, and the office asked both on the same day. Whether the office knew which was which when it asked is not recorded on any sheet read for this page.

Oath did produce material for the remaining accounts in its rider, described in the letter as “the user profile, as produced by the Yahoo Account Management Tool” and “the dates, times, and Internet protocol addresses for logins and authentication events (if any), as produced by the Yahoo Login Tracker Tool”.36 A separate business-records declaration of 15 January 2019, signed by a custodian of records for Oath, authenticates the same two categories.35

The letter also records a limit on what the data is worth: “When reviewing the information provided, please note that Oath may not require or verify user information because it offers many of its services to users for free.”36

How the government counted a refusal

On 1 August 2019 a message in a chain headed “RE: Subpoena Contact” reports what had come back from the providers. It lists negative results from Verizon with a redirect to T-Mobile, negative results from T-Mobile with a redirect to AT&T, and Yahoo results. Then one further line: “has reached out to Amazon at least three times with no response received back.” The message closes: “We have not received anything else as of today.”37

The message beneath it, sent on 31 July 2019, explains how the office’s own index of subpoenas was scored, and the explanation matters for anyone reading such an index:

“Attached is an index listing the subpoenas we have sent out and an indication of whether we have received a response. I only marked an entry as non-responsive if we received nothing from the entity. For instance, if we received a letter stating a lack of records, that was still marked as yes. So for any entry labeled “No”, we received nothing.”38

On that rule, a letter saying there are no records counts as a response. A company that says nothing at all is the only kind of “No”. Neither the index itself nor its attachments are among the documents read for this page.

A year later, when the office reviewed what it would hand over in discovery, the Google material raised nothing. In a list of subpoena-return folders run through one by one on 2 August 2020, under a bullet reading “Google” the single sub-entry reads “No issues”.39 That sheet is cited for those two entries and nothing else.

The secrecy orders run out

The orders were time-limited and the office tracked them. On 15 August 2019 a calendar item was cancelled, and the whole of the released document is its header block: the subject line reads “Canceled: Epstein: NDO for Google/Apple/Oath Subpoenas Expires”, the date “Thu, 15 Aug 2019 17:28:07 +0000”, and the importance “High”. There is no body.40 Of the 58 sheets read for this page, that is the only one on which the word Apple appears at all.41

Six months later the expiry was reported as having happened. A message timed “Fri, 21 Feb 2020 15:07:01 +0000” carries beneath it a message whose own preamble reads “Sent: Friday, February 21, 2020 10:00 AM” and which says:

“FYI, our NDO for the subpoenas we cut at the beginning of the case for Epstein’s email accounts has expired, so they’re going to notify (unclear to me who they’ll notify, of course). I have no problem with that, but let me know if you think there are any issues there.”42

The reply above it, a separate message, reads in full: “Thanks, agree that shouldn’t be a problem.”43 The signature block on the lower message runs over four lines, reading “Assistant United States Attorney”, then “Southern District of New York”, then “One Saint Andrew’s Plaza”, then “New York, NY 10007”. This page names no sender and no recipient for either message. The two times are in different forms, one carrying a time zone and one not, so no interval is derived from them here.

Which subpoenas “we cut at the beginning of the case” refers to is not stated. Counting on from the dates the orders themselves carry: by 21 February 2020 the 180 days ordered against Google on 23 October 2019 had not run, and the 365 days ordered against Oath Holdings on 19 December 2018 had.84 No document read for this page gives the period of the order that went with the December 2018 subpoena to Google, so this page says nothing about when that one expired.

On the claim that this was the first subpoena in the investigation

The July 2017 subpoena has been described as the first grand jury subpoena in the Southern District’s Epstein investigation. The documents read for this page do not establish that, and this page does not assert it.

What they do establish is narrower and is stated here exactly. Of the subpoenas and orders read for this page, the earliest is dated 13 July 2017 and is the only one carrying the reference 2017R00550; the next in date order is dated 19 December 2018 and carries 2018R01618; and a search of the released files for 2017R00550 returns one document.25 A claim that nothing earlier exists would be a claim about the whole release, and a search returning nothing is a statement about the search. This page has not run a search that could distinguish the absence of an earlier grand jury subpoena from the failure of a search to find one, and it therefore makes neither claim.

The sequence does raise a question the documents do not answer. The reference changed, the statutes changed from fraud to trafficking and conspiracy, and the gap between the first filing and the second is seventeen months. What relation the matter opened under 2017R00550 bore to the matter opened under 2018R01618 is not stated on any sheet read for this page.

How to check this page

Every document cited here is linked. Each link goes to the whole document, and the footnote names the sheet by the page number the served file itself gives it, counting from one.

On two sheets a printed stamp exists and is named: the first and third sheets of Google’s January 2019 letter carry, right-aligned at the foot and read as ink at the page image, USAO_002658 and EFTA_00020568, and USAO_002660 and EFTA_00020570. Those are two different numbering series, and neither can be worked out from the identifier that addresses the document or from the other.44

On every other sheet whose foot band was measured for this page, 30 of them, listed in the footnote, there is no printed stamp at all. The measurement is a pixel count over the bottom band of each sheet against a control box over ordinary body text on the same sheet, and it separates cleanly: the two stamped sheets return 519 and 497 pixels at or below a grey value of 200 with a darkest pixel of 0, while every unstamped sheet returns a darkest pixel of 70 or lighter, and the marks that do appear in those bands are the printing already on the page: a form revision line, the tail of a printed signature block, a scanner edge.44 Sheets not measured are not spoken for.

The identifiers in the footnotes are this project’s addresses for the documents, not stamps printed on paper, and this page does not present them as stamps.

What this page is, and what it is not

This page covers five subpoenas, the orders that went with three of them, and the providers’ answers. It does not cover what was done with anything the providers produced, the contents of any account, the investigation’s charging decisions, or any subpoena to any party other than Google and Oath Holdings. Apple, Amazon and two telephone carriers appear here only in the single line of a single document that names each of them, and nothing else about any of them is reported. Microsoft is named on a sheet this page does not use, and nothing is reported here about it.

Nothing here is a finding of wrongdoing. Naming a statute in the printed line “an alleged violation of” is not a charge, and nothing on any of these sheets charges anyone. A provider’s objection is a provider’s position, not a finding about the government, and the government’s demand is a demand, not a finding about a subscriber.

Every quotation above was read from the sheet named in its footnote, and 27 of the 58 sheets were also read at the page image at 96 pixels to the inch, which is the only resolution the released files hold for these documents. Every footnote says which of the two it rests on. Where the released text and the image disagree this page follows the image and says so in the footnote. Quotations introduced as reading “in full” reproduce a complete sentence or a complete printed line; the others are clauses, embedded as clauses in sentences of this page’s own, and the one cut inside a quotation is marked where it is made. Nothing is joined across two messages, two sheets or two copies.

The counts on this page are dated and are floors. They are taken from a full-text index of the released files that this project holds, not from the Department’s own systems, and they are matched against machine-read text, so a sheet the machine read badly is invisible to them. A figure of nothing in that index is a fact about the index.

Footnotes

  1. Grand jury subpoena face page, In Re Grand Jury Subpoena to Google, Inc., USAO Reference No. 2017R00550 (S.D.N.Y.), dated New York, New York, July 13, 2017, carrying the appearance date July 21, 2017 at 10:00 a.m., the statute line “18 U.S.C. §§ 1341, 1343”, the form revision mark “rev. 02.01.12”, a handwritten signature above a printed block of three lines reading “JOON H. KIM”, “Acting United States Attorney for the” and “Southern District of New York”, and a second handwritten signature written across an impression of the court’s seal, whose author this page does not identify. Read at the page image. The fifth of nine sheets; the sheet carries no printed Bates stamp. https://epstein-data.com/EFTA00153743 p.5. ↩ ↩2 ↩3 ↩4

  2. § 2705(b) non-disclosure order, same filing, marked SEALED, with the magistrate case number 17MAG5207 hand-stamped at the head, a printed and unfilled “Docket No.” line, 180 days ordered, the date stamped by hand “JUL 1 2 2017” over the typed rule, and the typed s-signature “S/Andrew J. Peck” above the printed title “UNITED STATES MAGISTRATE JUDGE”. Read at the page image. The ninth of nine sheets; no printed Bates stamp. https://epstein-data.com/EFTA00153743 p.9. ↩ ↩2 ↩3 ↩4

  3. Grand jury subpoena face page, same filing, dated New York, New York, December 19, 2018, with the appearance date January 4, 2019 at 10:00 a.m., the statute line “18 U.S.C. §§ 1591, 1594(c), 2422(b)”, and a handwritten signature above a printed block of three lines reading “GEOFFREY S. BERMAN”, “United States Attorney for the” and “Southern District of New York”. Read at the page image. The sixth of eight sheets; no printed Bates stamp. https://epstein-data.com/EFTA00152432 p.6. ↩ ↩2 ↩3 ↩4

  4. § 2705(b) non-disclosure order, same filing, marked SEALED, 365 days ordered in paragraph 2, dated by hand stamp “DEC 1 9 2018” over the typed rule, with the typed s-signature “S/Debra Freeman” above the printed title “UNITED STATES MAGISTRATE JUDGE” and a printed block naming Debra Freeman, United States Magistrate Judge, Southern District of New York. Read at the page image; the inner double quotation marks in the quoted paragraph are the order’s own. The fifth of eight sheets; no printed Bates stamp. https://epstein-data.com/EFTA00152432 p.5. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  5. Letter on United States Attorney, Southern District of New York letterhead to Oath Holdings, Inc., Attn: Legal Department, marked “BY EMAIL”, December 19, 2018, over a printed block of two lines reading “GEOFFREY S. BERMAN” and “United States Attorney”, with a “By:” line for an Assistant United States Attorney. The quoted passage is set in bold on the sheet. Read at the page image. The fourth of eight sheets; no printed Bates stamp. https://epstein-data.com/EFTA00152432 p.4. ↩ ↩2 ↩3 ↩4

  6. Letter from Google LLC to an Assistant United States Attorney at One Saint Andrew’s Plaza, dated 1/15/2019, headed “Re: Grand Jury Subpoena dated December 19, 2018 (Google Ref. No. 2247754)”, signed in type over two lines reading “Richard Daugherty” and “Google Legal Investigations Support”, with no handwritten signature. The three account names are printed in italics on the sheet. Read at the page image. The first of three sheets, carrying the printed stamps USAO_002658 and EFTA_00020568 right-aligned at the foot. https://epstein-data.com/EFTA00170256 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  7. Grand jury subpoena face page, same filing, dated New York, New York, October 23, 2019, with the appearance date November 7, 2019 at 10:00 a.m., the statute line “18 U.S.C. §§ 1591, 371”, the form revision mark “rev. 02.01.12”, a handwritten mark above a printed block of three lines reading “GEOFFREY S. BERMAN”, “United States Attorney for the” and “Southern District of New York”, and a second handwritten signature written across an impression of the court’s seal, whose author this page does not identify. Read at the page image. The fifth of nine sheets; no printed Bates stamp. https://epstein-data.com/EFTA00082565 p.5. ↩ ↩2 ↩3 ↩4

  8. § 2705(b) non-disclosure order, same filing, marked SEALED, with “19 MAG 9975” hand-stamped at the head in two stamp faces, 180 days ordered, the date stamped by hand “OCT 2 3 2019” over the typed rule, and the typed s-signature “S/Debra Freeman” above the printed title “UNITED STATES MAGISTRATE JUDGE”. Read at the page image. The released text renders the stamped date as “OCT 2.3 2010” and the stamped case number variously; neither is followed here. The ninth of nine sheets; no printed Bates stamp. https://epstein-data.com/EFTA00082565 p.9. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  9. Rider, same filing, headed “RIDER (Grand Jury Subpoena to Google, Inc., dated October 23, 2019)”, opening “Please provide all records for any accounts registered to or associated with the following identifiers:” above three bulleted lines whose labels are printed in bold as “Name”, “Phone numbers” and “Email addresses”, each followed by a colon. The name line reads “Ghislaine Maxwell”. No telephone number and no e-mail address is reproduced from this sheet or any other sheet cited on this page. Six numbered demands follow, the first of them a lettered list of ten items; in the second, the words “and at any time during” are underlined on the sheet. Read at the page image. The sixth of nine sheets; no printed Bates stamp. https://epstein-data.com/EFTA00082565 p.6. ↩ ↩2 ↩3 ↩4 ↩5

  10. Letter from Google LLC to a recipient at the Federal Bureau of Investigation, New York, NY 10278, dated 09/01/20, headed “Re: Grand Jury Subpoena dated August 26, 2020 (Google Ref. No. 3971083)” with the line “2018R01618; 20 MAG 9134” printed in italics beneath it. Signed in type over “Google Legal Investigations Support” on the following sheet; no handwritten signature. Read at the page image. The first of four sheets; no printed Bates stamp. https://epstein-data.com/EFTA00019636 p.1. ↩ ↩2 ↩3 ↩4

  11. Application for a § 2705(b) grand jury non-disclosure order to a service provider, In Re Grand Jury Subpoena to Google, Inc., dated October 23, 2019, USAO Reference No. 2018R01618 (S.D.N.Y.), marked SEALED. Paragraph 2 carries the § 2703(c)(2) sentence quoted in the text. The third sheet is dated New York, New York, October 22, 2019, carries the printed folio “3” at the foot, which is the document’s own internal numbering and not a production stamp, and paragraph 6, “No prior request for the relief set forth herein has been made.” Sheets 1 to 3 of nine; sheets 1 and 3 read at the page image, sheet 2 from the released text. No printed Bates stamp on either sheet measured. https://epstein-data.com/EFTA00082565 pp.1–3. ↩ ↩2 ↩3

  12. Application for a § 2705(b) grand jury non-disclosure order to a service provider, In Re Grand Jury Subpoena to Oath Holdings, Inc., dated December 19, 2018, USAO Reference No. 2018R01618 (S.D.N.Y.), marked SEALED, with the magistrate case number 18MAG10783 at the head. Paragraph 1 asks for 365 days; paragraph 2 carries the § 2703(c)(2) sentence quoted in the text; paragraph 4 asks for 365 days again; paragraph 6 reads “No prior request for the relief set forth herein has been made.” The closing sheet is dated New York, New York, December 19, 2018. Sheets 1 to 3 of eight; sheets 1 and 3 read at the page image, sheet 2 read from the released text. No printed Bates stamp on either sheet measured. https://epstein-data.com/EFTA00152432 pp.1–3. ↩ ↩2 ↩3 ↩4

  13. “Attachment A: Hash Values for Production Files (Google Ref. No. 3011708)”, same letter, listing two account-information text files, each with an MD5 and a SHA-512 value. The file names are not reproduced here. Read from the released text of the sheet; this sheet was not read at the page image for this page. The fourth of four sheets. https://epstein-data.com/EFTA00082559 p.4. ↩ ↩2

  14. “Attachment A: Hash Values for Production Files (Google Ref. No. 3971083)”, same letter, listing one file, a Google account subscriber-information archive, with an MD5 and a SHA-512 value. Read from the released text of the sheet; this sheet was not read at the page image for this page. The fourth of four sheets. https://epstein-data.com/EFTA00019636 p.4. ↩ ↩2

  15. Letter from Google LLC to an Assistant U.S. Attorney at 1 St. Andrew’s Plaza, dated 12/30/19, headed “Re: Grand Jury Subpoena dated October 23, 2019 (Google Ref. No. 3011708)”, carrying the quoted objection paragraph. Signed in type over “Google Legal Investigations Support” on the following sheet; no handwritten signature. Read at the page image. The first of four sheets; no printed Bates stamp. https://epstein-data.com/EFTA00082559 p.1. ↩ ↩2

  16. The same sheet. The case citation is printed in roman type on the sheet and is reproduced here as printed. https://epstein-data.com/EFTA00019636 p.1. ↩ ↩2

  17. Letter on United States Attorney, Southern District of New York letterhead to Google, Inc., Attn: Legal Department, marked “VIA EMAIL”, October 23, 2019, with “19 MAG 9975” hand-stamped across the middle of the sheet, over a printed block of two lines reading “GEOFFREY S. BERMAN” and “United States Attorney”, with a “By:” line for an Assistant United States Attorney. Its non-disclosure paragraph gives 180 days, matching the order. Read at the page image. The fourth of nine sheets; no printed Bates stamp. https://epstein-data.com/EFTA00082565 p.4. ↩ ↩2 ↩3 ↩4

  18. The non-disclosure request on that seventh sheet reads, under its bold capitalised heading: “Due to the ongoing nature of the investigation, it is requested that you do not disclose any information relating to this Grand Jury subpoena request to any third party.” Read from the released text. https://epstein-data.com/EFTA00082565 p.7. ↩

  19. Fourteen documents, 58 sheets, were read for this page: every sheet of each, from the machine-read text the project holds. Thirty-two of those sheets were also fetched as served and rendered; 27 were read as page images, and the five that were not are EFTA00153743 p.6, EFTA00074886 p.1 and the three rendered sheets of EFTA00091937, which are measured for the foot-band table and cited for nothing. The images were obtained by one read-only request each to the site’s own per-document path, with an invented identifier used as a control: the control returned HTTP 403 with an access-denied body on both occasions it was run, and each of the fourteen real documents returned HTTP 200 with a valid file header. Each file’s page count matches the number of sheets this project’s index records for it, document by document, across all fourteen. Every page is a grayscale or colour raster at 96 by 96 pixels per inch, and in all fourteen files the only text render mode present is the invisible overlay, so the visible content of each sheet is the scan. No sheet was enlarged beyond that resolution except the two foot bands carrying a printed stamp, because enlarging a 96-pixel-per-inch scan invents apparent detail rather than revealing it. Measured 25 October 2026. ↩

  20. Application for a § 2705(b) grand jury non-disclosure order to a service provider, same filing, marked SEALED, with the magistrate case number 17MAG5207 at the head and a printed and unfilled “Docket No.” line. Paragraph 1 asks for 180 days; paragraph 2 carries the § 2703(c)(2) sentence quoted later on this page; paragraph 4 gives 180 days twice more; paragraph 6 reads “No prior request for the relief set forth herein has been made.” The closing sheet is dated New York, New York, July 11, 2017 and carries the printed folio “3”. Sheets 1 to 3 of nine, read from the released text of each; these sheets were not read at the page image for this page. https://epstein-data.com/EFTA00153743 pp.1–3. ↩

  21. E-mail to the law-enforcement request address of Oath Holdings, subject “Preservation Request”, dated Wed, 12 Dec 2018 23:55:13 +0000, with one attachment, named in the attachments line as a letter to Oath Holdings dated 12-12-18; the body reads “Please see the attached preservation request.” The signature block runs over four lines, reading “Assistant United States Attorney”, “Southern District of New York”, “One Saint Andrew’s Plaza” and “New York, NY 10007”. This page names no sender for it. The attached letter is not part of this document. One sheet, read at the page image; no printed Bates stamp. https://epstein-data.com/EFTA00037896 p.1. ↩

  22. Rider, same filing, headed “RIDER (Grand Jury Subpoena to Oath Holdings, Inc., dated December 19, 2018)”, opening “Please provide all records for the following accounts:” above four bulleted account identifiers, all at one mail domain, which are not reproduced here; six numbered demands follow, the first of them a lettered list of ten items. Read at the page image. None of the four is reproduced here. The seventh of eight sheets; no printed Bates stamp. https://epstein-data.com/EFTA00152432 p.7. ↩ ↩2 ↩3 ↩4

  23. Declaration of Custodian of Records under 28 U.S.C. § 1746, same filing: a blank template with the declarant’s name, date, signature, title, business and business address left as printed rules. The eighth of eight sheets, read from the released text. https://epstein-data.com/EFTA00152432 p.8. ↩

  24. A second document in the released files carries the same nine-sheet filing of 23 October 2019. This page cites the first throughout and makes no comparison between them. https://epstein-data.com/EFTA00091937. ↩

  25. Counts taken on 25 October 2026 against a full-text index of the released files that this project holds, not against the Department’s own systems. Each phrase was matched whole and in order, with no wildcard and no partial-word matching; the index ignores full stops and is not case-sensitive, so a search for a domain name also finds addresses at that domain. “Sheets” counts matching sheets in that index and “documents” counts the distinct documents they belong to; the index held 2,925,025 sheets across 1,425,556 documents when these counts were taken. For scale against those denominators, the same run returned the word Epstein on 879,730 sheets across 578,565 documents, which is 40.6 per cent of the documents indexed; five separate passes of this project have now derived that figure and the two denominators independently and identically. Controls: in one invocation, an invented string returned 0 sheets and 0 documents while 2018R01618 returned 794 sheets across 442 documents and 2017R00550 returned 2 sheets in 1 document, so the search was demonstrated to be working in both directions. A phrase that returns nothing in that index has not been shown absent from the release: only from the machine-read text this project holds. Every figure here is a floor. ↩ ↩2 ↩3 ↩4

  26. Covering letter to Google, Inc., same filing, July 13, 2017, whose non-disclosure paragraph is the same form passage quoted in the text from the later filings, there giving 180 days. Read from the released text of the sheet; this sheet was not read at the page image for this page. https://epstein-data.com/EFTA00153743 p.4. The filing is set out sheet by sheet, from the page image, at EFTA00153743. ↩

  27. The same rider’s continuation, carrying numbered demands 7 and 8 and, beneath them, a printed note on personal appearance and the heading “IMPORTANT: REQUEST FOR NON-DISCLOSURE”. Read from the released text of the sheet; this sheet was not read at the page image for this page. The seventh of nine sheets. https://epstein-data.com/EFTA00082565 p.7. ↩

  28. The same sheet, two paragraphs above the objection. The released text renders “diligent” as “dilldiligent” at that point; the quotation above is taken from the image, where the word is printed once. https://epstein-data.com/EFTA00082559 p.1. ↩

  29. The same second sheet. The paragraph continues with two further sentences about the scope of § 2703(c)(2), which are not reproduced here; the released text damages the statute reference in one of them and the quotation above stops before it. Read at the page image; the second of four sheets, no printed Bates stamp. https://epstein-data.com/EFTA00019636 p.2. ↩

  30. The identifier sentence is on the first sheet; the sentence reporting that a diligent search found no records for a named account-holder is the opening paragraph of the second. No name and no identifier is reproduced from either. Read at the page image. https://epstein-data.com/EFTA00019636 pp.1–2. ↩

  31. “Attachment A: Hash Values for Production Files (Google Ref. No. 2247754)”, same letter, listing three account-information text files, one named for each of the three accounts, each with an MD5 and a SHA-512 value. Read at the page image. The third of three sheets, carrying the printed stamps USAO_002660 and EFTA_00020570 right-aligned at the foot. https://epstein-data.com/EFTA00170256 p.3. ↩ ↩2

  32. Certificate of Authenticity, same letter, under 28 U.S.C. § 1746, dated 1/15/2019 over the typed signature “/s_Richard Daugherty” and the name “Richard Daugherty”. Read from the released text of the sheet; this sheet was not read at the page image for this page. The second of three sheets. https://epstein-data.com/EFTA00170256 p.2. ↩

  33. Certificate of Authenticity, same letter, under 28 U.S.C. § 1746, dated 12/30/19 over the typed signature “/s_Jeremy Paduano” and the name “Jeremy Paduano”. Read at the page image. The third of four sheets; no printed Bates stamp. https://epstein-data.com/EFTA00082559 p.3. ↩ ↩2

  34. Certificate of Authenticity, same letter, under 28 U.S.C. § 1746, dated 09/01/20 over the typed signature “/s_Albert Sanchez” and the name “Albert Sanchez”. Read from the released text of the sheet; this sheet was not read at the page image for this page. The third of four sheets. https://epstein-data.com/EFTA00019636 p.3. ↩

  35. Business Records Declaration of a Custodian of Records for Oath Holdings Inc., made under Federal Rule of Evidence 902(11) and California Evidence Code § 1561 “in response to a subpoena dated December 19, 2018”, dated January 15, 2019, naming the same internal reference number 399267 and authenticating the user profile and the login and authentication records. Read at the page image. One sheet; no printed Bates stamp. https://epstein-data.com/EFTA00083913 p.1. ↩ ↩2

  36. E-mail from a legal analyst in Oath Holdings Inc.’s law-enforcement response team, subject “Request for Information Pertaining to User Account: … (Internal Reference No. 399267)”, dated Wed, 16 Jan 2019 14:42:01 +0000, with a single attachment named for that reference number. An account identifier printed in the subject line is omitted here. The body answers “a subpoena issued on December 19, 2018” and is signed over three lines reading “Alyssa Anderson”, “Legal Analyst, Law Enforcement Response” and “Oath Holdings Inc. (formerly Yahoo Holdings, Inc.)”. The cut marked in the quotation in the text removes a second account identifier, which is not reproduced here. Read at the page image. One sheet; no printed Bates stamp. https://epstein-data.com/EFTA00152147 p.1. ↩ ↩2 ↩3

  37. Top message of an e-mail chain, subject “RE: Subpoena Contact”, dated Thu, 01 Aug 2019 14:22:25 +0000, importance “Normal”. This page names no sender, no recipient and no copied party for it, and reproduces no attachment name from this sheet. The sentence quoted in the text is a clause of a longer sentence and is embedded as one. Read at the page image. The first of three sheets; no printed Bates stamp. https://epstein-data.com/EFTA01660712 p.1. ↩

  38. The next message down in the same chain, whose preamble on the sheet reads “Sent: Wednesda , Jul 31, 2019 5:56 PM” in the released text. The inner double quotation marks in the passage are the message’s own. The index it describes is not in this document. Read at the page image, from which the quotation is taken. https://epstein-data.com/EFTA01660712 p.1. ↩

  39. Message of Sun, 02 Aug 2020, forwarded within a chain headed “RE: discovery review”, setting out a reviewing lawyer’s instructions folder by folder for a set of subpoena-return folders. Under a bullet reading “Google” a single sub-entry on the next line reads “No issues”; the two are separate lines on the sheet and are quoted here as separate items. This page cites this document for those two entries only. Read at the page image. The second of four sheets; no printed Bates stamp. Other sheets of this document concern material this page does not cover. https://epstein-data.com/EFTA00074886 p.2. ↩

  40. Calendar cancellation, subject “Canceled: Epstein: NDO for Google/Apple/Oath Subpoenas Expires”, dated Thu, 15 Aug 2019 17:28:07 +0000, importance “High”. This page names no sender and no recipient for it. The whole of the released document is this header block above a rule; there is no body text on the sheet and none in the released text. One sheet, read at the page image; no printed Bates stamp. https://epstein-data.com/EFTA00014338 p.1. ↩

  41. Word-bounded, case-insensitive search for Apple, Amazon, Microsoft, Verizon and Google across the machine-read text of all 58 sheets read for this page, run on 25 October 2026 with controls: Google fired on 30 of the 58 sheets and an invented company name fired on none. Apple returned one sheet, https://epstein-data.com/EFTA00014338 p.1. Amazon returned two, Verizon one, Microsoft one, the Microsoft sheet being one this page does not use. This is a statement about those 58 sheets and about the machine-read text of them, not about the release. ↩

  42. The lower of two messages on a single sheet, whose preamble reads “Sent: Friday, February 21, 2020 10:00 AM” and whose subject is “Google”. This page names no sender and no recipient for it. The sheet’s own line breaks fall inside the quoted sentences and are reproduced here as continuous text; no words are added or removed. Read at the page image. One sheet; no printed Bates stamp. https://epstein-data.com/EFTA00029774 p.1. ↩

  43. The upper message on the same sheet, subject “RE: Google”, dated Fri, 21 Feb 2020 15:07:01 +0000. It is a separate message and is quoted separately; nothing is joined to the message beneath it. https://epstein-data.com/EFTA00029774 p.1. ↩

  44. Foot bands measured on the rendered page images at their own resolution, 96 pixels to the inch, each against a control box over ordinary body text on the same sheet. Stamped: the first and third sheets of https://epstein-data.com/EFTA00170256, returning 519 and 497 pixels at or below a grey value of 200 in the bottom band with a darkest pixel of 0, against body controls of 9,454 and 6,490 pixels, and the strings were then read in a magnified crop of each band. Measured and unstamped, 30 sheets: EFTA00153743 pp.5, 6 and 9; EFTA00082565 pp.1, 3, 4, 5, 6 and 9; EFTA00091937 pp.1, 5 and 9; EFTA00152432 pp.1, 3, 4, 5, 6 and 7; EFTA00019636 pp.1 and 2; EFTA00082559 pp.1 and 3; EFTA00074886 pp.1 and 2; EFTA00029774 p.1; EFTA00014338 p.1; EFTA00152147 p.1; EFTA00083913 p.1; EFTA00037896 p.1; and EFTA01660712 p.1. Every one returns a darkest pixel of 70 or lighter in that band, and the ink that does appear there is the printing already on the page. No sheet other than those 32 was measured and none is spoken for. ↩ ↩2

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