Epstein Data Wiki

SDNY Prosecution Memoranda in the Epstein and Maxwell Investigations

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tagstopic, southern-district-of-new-york, prosecution-memorandum, jeffrey-epstein, ghislaine-maxwell, charging-decisions

26 min read

InstitutionU.S. Attorney’s Office for the Southern District of New York1
Identified bythe exact confidentiality line the office prints on its own memoranda of this kind, searched across the whole corpus2
Documents in this setSix, dated June 11, 2019 to March 14, 2021134567
Two use a different classification lineThe December 5 and December 19, 2019 memoranda, both stamped “PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS” and “CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e)“34
A further memorandum this release does not haveDated April 28, 2020, on Maxwell; named by the March 14, 2021 memorandum and not located in this release78

Every prosecution memorandum the U.S. Attorney’s Office for the Southern District of New York wrote about Jeffrey Epstein or Ghislaine Maxwell in this release carries one of two classification lines, and the office prints those two lines on nothing else in the whole corpus. Searching the exact text “Do Not Disseminate Outside of the SDNY USAO” returns four documents; searching “PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS” together with “CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e)” returns two more; between them, and nowhere else, sit six documents.2 Four are dated June 2019 to April 2020 and use the first line; two, from December 2019, use the second. This page is about that set of six as an institution’s own record of its charging decisions — what each memorandum sought, from whom, under which statutes, and what became of the request — not about the people it discusses. Several of them are already the primary source for what this wiki says about named individuals, and this page links to those pages rather than repeating them.91011125 This set of memoranda is one part of the record described on the Epstein investigations overview.

The six memoranda

June 11, 2019, on Epstein. EFTA02731039 is captioned “United States v. Epstein, 19 Cr. ___ ( )” and “seeks authorization to charge JEFFREY EPSTEIN with one count of sex trafficking of children and one count of conspiracy to commit sex trafficking of children.”1 Its legal-context section concludes that the 2007 Southern District of Florida non-prosecution agreement does not bind the Southern District of New York, and closes that discussion — not the statute-of-limitations discussion that immediately follows it — with the sentence “Accordingly, we believe this SDNY prosecution is in the interests of justice,” printed directly above the heading “B. Statute of Limitations.”131415 Its “Cooperating Defendants” section states “None currently,” and adds that after the initial indictment the office “hope[s] to approach other suspected and alleged co-conspirators.”16 That is exactly what the next memorandum in this set records having done. A federal grand jury returned the indictment three weeks later, on July 2, 2019; the full course of the prosecution, ended by Epstein’s death in custody and the court’s dismissal of the indictment on August 29, 2019, is set out on this wiki’s page on the case.17

December 5, 2019, a corporate-prosecution analysis. EFTA02731069 is not a charging memorandum but an internally requested feasibility study: “we have been asked to analyze the feasibility of bringing criminal charges against one or more Epstein-controlled corporate entities that formally owned properties at which he abused certain minor victims.”3 It identifies the entity that held 9 East 71st Street — Nine East 71st Street Corporation until 2011, then Maple, Inc. — and states that Epstein “appears to have been its sole officer or member,” with no identified corporate purpose beyond holding the property, and that parallel entities held his residences in Florida, New Mexico and the U.S. Virgin Islands on the same footing.18 A footnote cites this office’s own prior prosecution of an LLC, United States v. S.A.C. Capital Partners LP, for the proposition that corporate form is not a bar.19 From there the memorandum’s “II.B” legal analysis, its “III. Prudential Considerations” and its “IV. Assessment” are redacted down to their headings; the production ends on the “IV. Assessment” heading with no visible text and no signature block.202122 This release does not show what the office decided. This wiki’s page on the property records no indictment of Maple, Inc. or its predecessor and no document dated after Epstein’s estate entered probate describing what became of the corporate question.23

December 19, 2019, on co-conspirators. EFTA02731082 is an 86-page memorandum to U.S. Attorney Geoffrey S. Berman that “details the investigative steps taken since the indictment of Jeffrey Epstein” and “analyzes the extent to which certain of Epstein’s associates and employees may or may not be criminally liable.”4 Its own account of the investigation “focused on Ghislaine Maxwell, [REDACTED] and Leslie Groff,” and states that “[t]he potential charges against Maxwell will be further analyzed in a separate prosecution memorandum, which is expected to seek authorization to charge Maxwell with federal offenses for her role in facilitating the transport of minors for illegal sex acts” — the memorandum that became EFTA02731168, just under four months later.24 A “Legal Landscape” section works through the elements of three statutes — sex trafficking under § 1591, transportation of minors under § 2423, and enticement under § 2422 — with a footnote to the same effect: “we anticipate recommending transportation of minors charges against Maxwell and will prepare a separate prosecution memorandum regarding those charges.”25 Its own investigative-steps section records attorney contacts with counsel for Ghislaine Maxwell, Leslie Groff, Jean Luc Brunel and Leslie Wexner, and search warrants executed on Epstein’s New York and Virgin Islands residences in July and August 2019;26 what each of those four proffers contains is set out on the individuals’ own pages rather than here.91011 A final “IV. Analysis” section asks whether there is sufficient evidence to charge two people with a federal crime — the names are themselves redacted in the image at the sentence that states the question, though the section’s own subheadings, further on and unredacted, read “D. Leslie Groff” and “E. Ghislaine Maxwell” — and the analysis under both is withheld in its entirety.2728 No indictment of Groff appears anywhere in this release or on this wiki’s page about her.9

April 10, 2020, on Maxwell. EFTA02731168 is a published page of this wiki and is not duplicated here. In outline: it sought authorization to charge Maxwell with two counts of conspiracy, under 18 U.S.C. § 2423(a) and § 2422, for conduct from 1994 to 1997; its legal analysis, statute-of-limitations application, anticipated-defenses section and recommendation are redacted down to their headings; and the grand jury returned a six-count indictment on June 29, 2020 that took its two proposed conspiracy counts largely unchanged and added two substantive counts and two perjury counts the memorandum does not discuss.5

April 14, 2020, on a member of Epstein’s staff. EFTA02731200 “addresses the investigation into [REDACTED] who worked as an assistant to Jeffrey Epstein,” and “analyzes a potential prosecution against [REDACTED] for participating in a sex trafficking conspiracy with Epstein.”6 It states that it “incorporates the Prosecution Memo regarding Jeffrey Epstein, dated June 17, 2019” and the December 19, 2019 memorandum above — a date that does not match the June 11, 2019 the earlier memorandum carries on its own cover page, a divergence this page reports rather than resolves.291 Its proposed charge is “[s]ex trafficking conspiracy, 18 U.S.C. § 371 (to commit sex trafficking, 18 U.S.C. § 1591).”30 Unlike the other five memoranda in this set, its charging-recommendation section is headed “V. Interests of Justice and Analysis,” with subheadings “Precedent and balancing of equities,” “Views of victim-witnesses,” “Views of the SDNY human trafficking coordinators” and “Efficiencies in process and outcome” — a more elaborated weighing structure than this page found named in the other five, though every one of those subsections is redacted below its heading.31323334 The memorandum’s final section, “VI. Other Relevant Offenses and Recommendation,” and its closing signature block are both withheld; this release does not show what the office decided.3435 This wiki’s pages on Groff, Brunel and Wexner — the other Epstein staff and associates whose proffers this set of memoranda records — describe no indictment resulting from any of them, and this page has not searched further in a way that would risk supplying this memorandum’s own redacted subject an identity the document withholds.91011

March 14, 2021, on the superseding charges. EFTA02731226 “seeks authorization to charge GHISLAINE MAXWELL with additional criminal offenses,” proposing to extend the conspiracies already charged from 1997 to 2004 and to add a new conspiracy and a new substantive count of sex trafficking of a minor under 18 U.S.C. § 371 and § 1591, both keyed to a fourth alleged victim.736 Unlike the other memoranda in this set, its “Discovery & Disclosure Plan” and “Forfeiture/Restitution” sections are unredacted, and record specific difficulties: the office states it is “still in the process of loading scans of the full USAO-SDFL file into Relativity” because of “technical issues with the vendor who scanned the files in Florida and the vendor who handles loading the files into Relativity.”37 It also states that it has “received authorization from the Court to delay production of a small subset of Rule 16 discovery relating to victims who do not form the basis of the charges in the pending Indictment,” and, on forfeiture, that “it would be more complicated to pursue the properties involved in the offense conduct because none belonged to Maxwell.”38 It anticipates “no cooperating defendant(s)” and “no witness(es) who would testify under a grant of immunity,” and records that “[t]rial is scheduled to commence on July 12, 2021.”3940 Trial in fact began on November 29, 2021, and the perjury counts this same memorandum left unchanged were severed for separate trial on April 16, 2021, a month after this memorandum’s date, and were never tried; the full course of the prosecution is set out on this wiki’s page on Maxwell.41

A shared template, and where it breaks

Three of the six memoranda open with a variant of the same sentence: “This memorandum seeks authorization to charge [name] with” one or more offenses.157 The other three are framed differently because their own subject is different — the December 2019 memorandum “analyzes the extent to which” named associates “may or may not be criminally liable” without itself seeking to charge anyone, the corporate-prosecution memorandum answers a feasibility question it says it “ha[s] been asked” to answer, and the April 14, 2020 memorandum “addresses the investigation into” its subject and “analyzes a potential prosecution” rather than announcing that it seeks one.436 Where a memorandum does seek charges, it works through a consistent sequence of numbered parts: an overview of the scheme, a proposed-charges section with a statutory-elements table and a venue line, a section on cooperating defendants, a section on discovery issues, a section on forfeiture and restitution, a one-line answer to whether the case involves fraud on a federally funded program, a victim-issues section, a Speedy Trial Act calculation, and a plans-for-arrest section.161542393840 The two 2019 memoranda that are not themselves charging documents do not carry this structure at all. The April 14, 2020 memorandum is shorter than that template in a different way: it ends at a sixth numbered part, with no separate sections on cooperating defendants, discovery, forfeiture, coordinated proceedings, the Speedy Trial Act or plans for arrest, and it replaces the office’s usual one-line “in the interests of justice” conclusion — the form used for Epstein himself — with the four-part “Interests of Justice and Analysis” section described above.1534

What the redactions withhold

In four of the six memoranda — the corporate-prosecution memorandum, the co-conspirators memorandum, the April 14, 2020 memorandum, and the April 10, 2020 Maxwell memorandum — the section that reaches a legal-analysis or recommendation follows the same pattern: the heading and the general statement of law above it are visible, and the application of that law to the office’s own evidence is blacked out beneath it.212728345 The published page on the April 10, 2020 Maxwell memorandum sets out that pattern in detail for one document in this set; it recurs, at less length, in the corporate-prosecution memorandum’s “Prudential Considerations” and “Assessment,” in the co-conspirators memorandum’s “IV. Analysis,” and in the April 14, 2020 memorandum’s “Interests of Justice and Analysis” and “Recommendation.”212227283134 The other two memoranda in this set do not fit that pattern, and neither is counted toward it. The March 14, 2021 memorandum’s comparable sections — its “Discovery & Disclosure Plan” and “Forfeiture/Restitution” — are fully unredacted, as described above.3738 The June 11, 2019 Epstein memorandum shows a different redaction shape again: its “V. Legal Context” section states its reasoning on the non-prosecution agreement in the clear, redacting only the names of associates within it, and the sentence that closes that section and the sentence that opens the statute-of-limitations section after it are both visible, with only the material between them blacked out.131415 None of the redacted material identified for this page concerns any victim’s identity; in every instance the visible heading states that what follows is the office’s own legal reasoning about its own case.

One page of this set was found, on inspection, not to be as clean as its extracted text suggested; this page reports the caution rather than the shortcut. The “IV. Analysis” section’s opening sentence, stating that the section evaluates whether to charge two named people, is redacted at the page image itself where it names them, and this page treats it as redacted rather than relying on any machine-readable copy of that page. Both people are identified instead from the section’s own later subheadings, checked separately at the image, which read “D. Leslie Groff” and “E. Ghislaine Maxwell.”2728

A memorandum this release does not have

The March 14, 2021 memorandum states that “[t]he evidence supporting those charges and the legal issues surrounding those charges were discussed at length in previous prosecution memos dated April 10, 2020 and April 28, 2020.”7 The first of those is EFTA02731168, in this set. The second, an April 28, 2020 memorandum on Maxwell, is not.

This page searched for it directly. The exact confidentiality line common to four of the six memoranda in this set, and the different line common to the other two, together return only the six documents already described here and nothing dated April 28, 2020.2 The genre’s own opening phrase, “This memorandum seeks authorization to charge,” returns only three documents, all already in this set.2 Four written forms of the date — “April 28, 2020,” “4/28/2020,” “4/28/20” and “2020.04.28” — were searched across the whole corpus; excluding the six documents already described on this page, none returns a page also carrying either confidentiality line or the case caption “United States v. Maxwell.” One of the six does match all three at once: the March 14, 2021 memorandum’s own first page carries the confidentiality line and the caption, and names the missing memorandum by the date “April 28, 2020” — it is the document that refers to the missing one, not a copy of it, and is excluded from the count on that basis.8 The Bates stamps of the two memoranda immediately adjacent in this set are not themselves adjacent: the April 14, 2020 memorandum’s last page is stamped EFTA_00022746, and the March 14, 2021 memorandum’s first page is stamped EFTA_00023120, a gap of 373 stamped pages that this wiki’s own identifier-to-Bates map does not otherwise resolve.43 A gap of that kind is weak evidence on its own — elsewhere in this same set of documents a June 2019 memorandum’s Bates range sits after a December 2019 memorandum’s, so Bates order does not track document order here — and this page treats it as corroboration only, not as proof.43

This is reported as an absence in this release, not as a claim about whether the memorandum was ever written, sent, or exists somewhere else. It is a lead for the desk.

Cited in

EFTA02731168 (published); Les Wexner; Lesley Groff; Jean Luc Brunel; Jes Staley; 9 East 71st Street; Ghislaine Maxwell; United States v. Epstein.

Footnotes

  1. EFTA02731039, p. 1 of 30 (header, “Prosecution Memorandum,” “Privileged and Confidential — Attorney Work Product / Do Not Disseminate Outside of the SDNY USAO,” “United States v. Epstein, 19 Cr. ___ ( ),” “June 11, 2019”; “This memorandum seeks authorization to charge JEFFREY EPSTEIN with one count of sex trafficking of children and one count of conspiracy to commit sex trafficking of children.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731039 ↩ ↩2 ↩3 ↩4 ↩5

  2. Full-text search of the corpus, pages_fts, run for this page: the phrase “Do Not Disseminate Outside of the SDNY USAO” returns EFTA02731039, EFTA02731168, EFTA02731200 and EFTA02731226, one page each; the phrase “PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS” together with “CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e)” returns EFTA02731069 (13 of 13 pages) and EFTA02731082 (76 of 86 pages); the phrase “This memorandum seeks authorization to charge” returns EFTA02731039, EFTA02731168 and EFTA02731226, one page each, and no others. ↩ ↩2 ↩3 ↩4

  3. EFTA02731069, p. 1 of 13 (“PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS,” “CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e),” “December 5, 2019,” “Analysis of Possible Corporate Prosecution”; “In connection with the investigation of Jeffrey Epstein for sex trafficking, we have been asked to analyze the feasibility of bringing criminal charges against one or more Epstein-controlled corporate entities that formally owned properties at which he abused certain minor victims.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731069 ↩ ↩2 ↩3 ↩4

  4. EFTA02731082, p. 1 of 86 (“PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS,” “CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e),” “December 19, 2019,” “Investigation into Potential Co-Conspirators of Jeffrey Epstein”; “This memorandum details the investigative steps taken since the indictment of Jeffrey Epstein in this District on July 2, 2019 and analyzes the extent to which certain of Epstein’s associates and employees may or may not be criminally liable for their conduct during their employment with Epstein.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731082 ↩ ↩2 ↩3 ↩4

  5. EFTA02731168, the published page on the April 10, 2020 Maxwell memorandum, with its own citations for the charges sought, the redacted sections, and the indictment returned. ↩ ↩2 ↩3 ↩4 ↩5

  6. EFTA02731200, p. 1 of 26 (“Privileged and Confidential — Attorney Work Product / Do Not Disseminate Outside of the SDNY USAO”; “April 14, 2020”; “This memorandum addresses the investigation into [REDACTED] who worked as an assistant to Jeffrey Epstein. In particular, this memorandum analyzes a potential prosecution against [REDACTED] for participating in a sex trafficking conspiracy with Epstein,”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩ ↩2 ↩3

  7. EFTA02731226, p. 1 of 28 (“Prosecution Memorandum,” “Privileged and Confidential - Attorney Work Product,” “Do Not Disseminate Outside of the SDNY USAO (or other DOJ COMPONENT, as needed),” “United States v. Maxwell, S2 20 Cr. 330 (AJN),” “3/14/2021”; “This memorandum seeks authorization to charge GHISLAINE MAXWELL with additional criminal offenses based on her participation in the recruitment, grooming, and abuse of minor girls with Jeffrey Epstein in a superseding indictment.”; “The evidence supporting those charges and the legal issues surrounding those charges were discussed at length in previous prosecution memos dated April 10, 2020 and April 28, 2020.”; the corpus’s machine-extracted text for this page misreads “DOJ COMPONENT” as “DOS COMPONENT”; this page follows the image; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731226 ↩ ↩2 ↩3 ↩4 ↩5

  8. Full-text search of the corpus for four date forms — “April 28, 2020,” “4/28/2020,” “4/28/20” and “2020.04.28” — run for this page: one page, EFTA02731226 p. 1 (the March 14, 2021 memorandum, already in this set), matches the date “April 28, 2020” together with both a confidentiality line and the caption “United States v. Maxwell” at once, because it is the document that names the missing memorandum by that date; it is excluded as a self-match, not counted as a hit. Excluding the six documents already described on this page, no other page returned by any of the four date searches also carries either confidentiality line or the caption. The genre’s opening phrase, “This memorandum seeks authorization to charge,” returns only the three documents cited in this set. This is a report of the searches run and their results, not a claim that no such memorandum was ever written. ↩ ↩2

  9. Lesley Groff, with its own citations to EFTA02731082 and EFTA02731200. ↩ ↩2 ↩3 ↩4

  10. Jean Luc Brunel, with its own citations to EFTA02731082. ↩ ↩2 ↩3

  11. Les Wexner, with its own citations to EFTA02731069 and EFTA02731082. ↩ ↩2 ↩3

  12. Jes Staley, with its own citation to EFTA02731082 p. 33. ↩

  13. EFTA02731039, p. 16 of 30 (“V. Legal Context / A. The Florida Non-Prosecution Agreement,” concluding that the 2007 non-prosecution agreement “was signed only by representatives of SDFL and spoke, in relevant part, only to binding that Office” and would not preclude prosecution in another district; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731039 ↩ ↩2

  14. EFTA02731039, p. 20 of 30 (“The Independent Interests of the Southern District of New York,” a subheading within the same non-prosecution-agreement discussion; the page is otherwise redacted above and below it; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731039 ↩ ↩2

  15. EFTA02731039, p. 21 of 30 (“Accordingly, we believe this SDNY prosecution is in the interests of justice.”; “B. Statute of Limitations”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731039 ↩ ↩2 ↩3 ↩4

  16. EFTA02731039, p. 15 of 30 (“IV. Cooperating Defendants / None currently. Following the filing of the initial indictment charging Epstein, we hope to approach other suspected and alleged co-conspirators, and to further develop evidence against such individuals through the overt investigation, with the possibility of utilizing certain such individuals as cooperating defendants.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731039 ↩ ↩2

  17. United States v. Epstein, with its own citations for the indictment, arrest and dismissal. ↩

  18. EFTA02731069, p. 2 of 13 (“I. Background and Ownership of Property”; the Nine East 71st Street Corporation to Maple, Inc. transfer; n.3, assuming Epstein “was the sole member of the Nine East 71st Street Corporation”; n.4, describing parallel entities holding the Florida, New Mexico and U.S. Virgin Islands properties on the same footing; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731069 ↩

  19. EFTA02731069, p. 5 of 13 (describing the Corporation as having “no formal business or corporate purpose”; n.7, citing this office’s prosecution of United States v. S.A.C. Capital Partners LP, 13 Cr. 541, as precedent for charging an LLC; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731069 ↩

  20. EFTA02731069, p. 3 of 13 (“II. Principles and Requirements of Corporate Prosecution / A. Legal Framework and Application,” redacted after the opening statement of law; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731069 ↩

  21. EFTA02731069, p. 8 of 13 (“III. Prudential Considerations,” redacted below the heading; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731069 ↩ ↩2 ↩3

  22. EFTA02731069, p. 13 of 13 (“IV. Assessment,” redacted below the heading; this is the last page of the document; no signature block follows; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731069 ↩ ↩2

  23. 9 East 71st Street, “The records this page draws on end there. A search of the released files under ‘9 East 71st Street,’ ‘East 71st,’ ‘Maple, Inc.’ and the block and lot number returned the documents described above and nothing dated after the probate petition about what became of the house.” ↩

  24. EFTA02731082, p. 2 of 86 (“that investigation focused on Ghislaine Maxwell, [REDACTED] and Leslie Groff”; “The potential charges against Maxwell will be further analyzed in a separate prosecution memorandum, which is expected to seek authorization to charge Maxwell with federal offenses for her role in facilitating the transport of minors for illegal sex acts.”; read from the page image at 400 dpi, which shows Maxwell and Groff named in the clear and one further name redacted). https://epstein-data.com/EFTA02731082 ↩

  25. EFTA02731082, p. 73 of 86 (n.66: “As discussed below, we anticipate recommending transportation of minors charges against Maxwell and will prepare a separate prosecution memorandum regarding those charges. That prosecution memo will detail the applicable state statutes for the conduct relevant to the proposed charges against Maxwell.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731082 ↩

  26. EFTA02731082, p. 66 of 86 (“2. Search Warrants / In July and August 2019, we obtained and the FBI executed search warrants for Epstein’s residences in New York and the Virgin Islands. We subsequently obtained warrants to search all electronic devices, drives, and discs seized from those residences.”; read from the page image at 400 dpi). Search warrants are subsection 2 of the memorandum’s section F on additional investigative steps; the attorney meetings with counsel for Maxwell, Groff, Brunel and Wexner are subsection 1 of that same section and run to p. 66, where subsection 2 begins. The subheadings “c. Counsel for Jean Luc Brunel” and “d. Counsel for Leslie Wexner” are at p. 65 of this run, read from the page image at 300 dpi; the Wexner narrative continues across the sheet break and occupies the upper part of p. 66, with the search-warrants heading beginning below it (measured on a 300 dpi render of p. 66, 2550 by 3375 px: the narrative’s last inked row at y=2224 and the heading band at y=2302-2333, about 69% of the way down the sheet). See the individual pages cited for what each contains. https://epstein-data.com/EFTA02731082 ↩

  27. EFTA02731082, p. 75 of 86 (“IV. Analysis / In light of the evidence gathered during our investigation, as well as the legal tools available, in this section, we evaluate whether there is sufficient evidence to charge [REDACTED AT THE IMAGE, read at 400 dpi] with a federal crime and, if so, whether such charges would be in the interests of justice.”). The corpus’s machine-extracted text for this page does not match the image at the redacted span; this page rests nothing on that text and reports the discrepancy to the desk separately. https://epstein-data.com/EFTA02731082 ↩ ↩2 ↩3 ↩4

  28. EFTA02731082, p. 86 of 86 (“D. Leslie Groff” and “E. Ghislaine Maxwell,” both headings genuinely unredacted at the page image, both subsections otherwise redacted in full; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731082 ↩ ↩2 ↩3 ↩4

  29. EFTA02731200, p. 2 of 26 (“This memorandum incorporates the Prosecution Memo regarding Jeffrey Epstein, dated June 17, 2019 (the ‘Epstein Memo’), and the Investigation Update Memo dated December 19, 2019 (the ‘Update Memo’).”; read from the page image at 400 dpi, which confirms “June 17, 2019” as printed). https://epstein-data.com/EFTA02731200 ↩

  30. EFTA02731200, p. 14 of 26 (“IV. Potential Charge and Legal Analysis / Sex trafficking conspiracy, 18 U.S.C. § 371 (to commit sex trafficking, 18 U.S.C. § 1591). The crime of sex trafficking conspiracy has three elements…”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩

  31. EFTA02731200, p. 16 of 26 (“V. Interests of Justice and Analysis / Precedent and balancing of equities,” redacted below the heading; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩ ↩2

  32. EFTA02731200, p. 20 of 26 (“Views of victim-witnesses,” redacted below the heading; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩

  33. EFTA02731200, p. 21 of 26 (“Views of the SDNY human trafficking coordinators,” redacted below the heading; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩

  34. EFTA02731200, p. 22 of 26 (“Efficiencies in process and outcome”; “VI. Other Relevant Offenses and Recommendation,” redacted below both headings; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩ ↩2 ↩3 ↩4 ↩5

  35. EFTA02731200, p. 26 of 26 (“By:,” signature line redacted; this is the last page of the document; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731200 ↩

  36. EFTA02731226, p. 2 of 28 (“Count One: Conspiracy to Transport Minors from 1994 to 2004, in violation of 18 U.S.C. § 371. This charge would expand the end date of the conspiracy from 1997 to 2004 and would add an overt act involving Minor Vicitm-4.”; “Count Three: Conspiracy to Entice Minors from 1994 to 2004, in violation of 18 U.S.C. § 371. This charge would expand the end date of the conspiracy from 1997 to 2004 and add an overt act involving Minor Vicitm-4.”; read from the page image at 400 dpi, which confirms the document’s own “Vicitm-4” spelling). https://epstein-data.com/EFTA02731226 ↩

  37. EFTA02731226, p. 26 of 28 (“we are still in the process of loading scans of the full USAO-SDFL file into Relativity so that our team can conduct a full review of that file. Due to technical issues with the vendor who scanned the files in Florida and the vendor who handles loading the files into Relativity, this process remains ongoing.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731226 ↩ ↩2

  38. EFTA02731226, p. 27 of 28 (“We have received authorization from the Court to delay production of a small subset of Rule 16 discovery relating to victims who do not form the basis of the charges in the pending Indictment.”; “VI. Forfeiture/Restitution… We are still exploring whether we have a basis to seek forfeiture in this charging instrument, but we note that it would be more complicated to pursue the properties involved in the offense conduct because none belonged to Maxwell.”; “VII. USAO Civil/Criminal Coordinated Proceedings”; “VIII. Victim Issues”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731226 ↩ ↩2 ↩3

  39. EFTA02731226, p. 25 of 28 (“IV. Cooperation Defendants and/or Immunized Witnesses / In presenting this case at trial, we anticipate presenting the testimony of no cooperating defendant(s)… [and] no witness(es), who would testify under a grant of immunity.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731226 ↩ ↩2

  40. EFTA02731226, p. 28 of 28 (“IX. Speedy Trial Act Calculations & Deadline / The defendant was arrested on July 2, 2020. Trial is scheduled to commence on July 12, 2021, and Judge Nathan has excluded time under the Speedy Trial Act through that date.”; “X. Plans for Arrest”; signature block, signer redacted; this is the last page of the document; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731226 ↩ ↩2

  41. Ghislaine Maxwell, with its own citations: trial began November 29, 2021; the perjury counts were severed for separate trial by order of April 16, 2021 and never tried. ↩

  42. EFTA02731039, p. 30 of 30 (“IX. Coordinated Proceedings” through “XIII. Plans for Arrest,” including “We expect to arrest the defendant following the filing of the proposed indictment.”; read from the page image at 400 dpi). https://epstein-data.com/EFTA02731039 ↩

  43. Documents table of the corpus: EFTA02731200 (26 pages, Bates EFTA_00022721-00022746) and EFTA02731226 (28 pages, Bates EFTA_00023120-00023147) are the two entries immediately adjacent in the identifier sequence used for this set, with no document identified in between; the Bates stamps between them are not accounted for by any identifier this page located. Elsewhere in this same set, EFTA02731039 (dated June 11, 2019, Bates beginning EFTA_00022556, read from the page image) carries a Bates range after EFTA02731082 (dated December 19, 2019, Bates beginning EFTA_00022461, read from the page image), so Bates order does not track chronological or document order in this run. EFTA02731069, the other December 2019 memorandum, carries no separate Bates stamp of this kind at all on the page checked; it is paginated only by its own document identifier. ↩ ↩2

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