I 1 EXHIBIT B I I 1 I l l ‘ UNITED STATES VIRGIN ISLANDS l DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL *****CICO SUBPOENA***** DUCES TECUM SUBPOENA FOR w M IN THE NAME OF THE GOVERNMENT OF THE VIRGIN ISLANDS T0 Ghislnine Maxwell do Quint-ins, Prieto, Wood 8: Boyer, RA 9300 S Dudehnd Blvd 1 4" Floor l Wand FL 33156 I ATTN Kyle R Walther, E59 1 Title 14 V l C § 612(a) provides that Madam? on is My suspected to have engaged in, or to be engaging in, or about to engage in “Jyoti r WfigaWn o f the provisions ofsection 605r the Attomey General may, in his di i 1 . $15an {j f dag :The Attorney General is authorized before the commencement of d if“ "york/finer criminal proc @211 der this chapter to subpoena witnesses, compel their art ‘ We them underin! or to req n of any books, documents records, writings rem fife things (herein t ferred to as do L atefial ) relevant or mammal to the invest] o cation roduc d/cr com/m , \ > 1 E if?» 25 mg? 95.77, {WSW‘V‘ ; Pursuant to we 14 of c S.“? n{my gr W HENRY, I x but)” mange forthwith copies of 1 the documents listedfiimr/A / y 4 {\A : Q {‘9 x \ l a) ,- ‘, x : -. m vi' .': t t. if We}l;f\1//(\fr"l w t Pursuant to 14 V I C; § @1ch the documents) requ ted Min flaw e V Wynn by the Virgin Islands Department We?“ the mpéfltfiggt [oi nM §f yo Find underage girls by Jefi'reyE Epstein hmfieiates in violation of 14 § 133 and 1 as we afi irgin Islands l statutes ‘ 3/ t i ’ i l 3t§‘$\ >":t(\4 £14,: \ J t A 4 e ‘ Personal appearance is alimufisfytmmfinm filefimffizldaglffiegé‘ested Information to , } ‘ Special Agent Tlrlque (9% Pnrtlllent \ ;t (I:i / l “4- t Q\ ' 2 4‘i f PLACE United States 5 {a}? DATE April 17 2020 Department ofJu [I 1 AH A) n‘ 3438 Kronprindsens new , ”L G E RS Complex 2 dFloor TIL/[E 3 00 [I In 1 St Thomas V1 00802 5712 ‘ NOTE Thls subpoena place: you on notice of an invertigatlon by the Virgin Islands Department of Julclce. You must maintain1 end my not destroy, any documents, electronic records, or other material relating to Jeffrey Epstein and the entities described in the subpoena Failure to produce the documents requested may cause the Attemey General to petition the Superior Court to l l l4",, 7, , , ,, 7W, ,,,, , 7 , , l compel you to pIDdULC (in. documents requealed and to the iasuance ofa warrant for your arrest, under Tille14 V l C Q 612m DATED “Iii /? day at Man]! 2020 rlel mi, Esquire Chis] oflie Civil Di\ision V I Departmcux oflusticc Office oflhe Anomey General 3438 Kmnprindaenx Gilda (J E R S Complex 2nd Floor SK Thomas V1 00802 (340)774 5666120 10303 RETURN OF SERVICE Receiied by Server on Plane Sened on (Name) Dale Ai Sened by THIS DECLARATION OF SERVER IDECI ARE UNDER PFNAI [Y 01' PERJURY LNDFR THE LAWS OF THE Unned Slalex of America and the 1 wilon oflhe United Siam: Virgin islands then [In fortgoin" infunnaliun cnmained in me Remm of Serum Slalenlenl is true and can cc! Emma on a) I Exhibit A ‘ Subpoena Dove: Tecum directed to Banco Popular de Puerto Rico ; RECORDS DELIVERY ONLY NO ORAL TESTIMONY WILL BE TAKEN ! IF RECORDS ARE DELIVERED PRIOR TO April 17 2020 YOU NEED NOT APPEAR 1 i If more than thirty (30) days is needed to respond to this subpoena, please contact the Civil 1 Division Chief, Attorney Ariel Smith, at the Virgin Islands Department of Justice 1 t 1 Definitions l 1 Unless otherwise specified, the documents specified below are required to be produced for the time period commencing January 1 1998 and continuing through the present Where } production of account data is provided in electronic format or media the preferred software ‘ format to incorporate the data into is Microsoft Excel As used herein, the following terms are defined as indicated 1 As used herein, the term "Account Holder" shall mean any person or entity in whose name an account is held or where the person or entity has held any ownership or other interest or has had signatory authority 2 “All/Each " The term "all" and "each“ shall be construed as all and each 3 "And/Or " The connectives "and" and "or" shall be construed either disjunctiver or conjunctiver as necessary to bring within the scope ofthe discovery request all responses that might otherwise be construed to be outside of its scope l l 4 "Communication" means the transmittal ofinformation (in the form of facts, ideas, inquiries or otherwise) i l 5 "Concerning" means relating to, referring to, describing, evidencing or constituting l 6 The terms "Document" or "Documents" are defined to be synonymous and equal in scope J‘ to the usage ofthese terms in Federal Rule of Civil Procedure 34(3) including, without 1 limitation any written, drawn printed, typed, photographed or other graphic or i electronically or computerized recorded data or compilations of any kind or nature prepared or received by or in the possession, custody or control ofthe answering party its agents, servants, employees or other representatives Originals, drafts and all non i identical copies are separate documents within the meaning of this term 7 The term "identify" when used with reference to a person means to give to the extent known, the person's full name, present or last known address, and when referring to a natural person additionally, the present or last known place ofemployment Once a person has been identified in accordance with this subparagraph only the name ofthat person need to be listed in response to subsequent discovery requesting the identification ofthat person 8 The term "identify" when used with reference to documents, means to give, to the extent known, the (i) type ofdocument (ii) general subject matter; (iii) date ofthe document, and (iv) author(s) addressee(s) and recipient(s) 9 The term "identify" when used with reference to an oral communication, discussion, conversation or any other oral statement shall mean to describe in detail the substance of each such communication, discussion conversation or statement, state the date of such communication discussion, conversation or statement, the place where such communication, discussion, conversation or statement was held and identify each person present for such communication, discussron conversation or statement 10 "Person" means any natural person or any business, legal or governmental entity or association ll "Referring to" "relating to", "reflecting", "regarding" or "With respect to" mean without limitation the concepts pertain to deal with, concern reflect, record, report, constitute, contain mention, describe discuss, analyze, evaluate estimate, study, survey, project, assess, support, modify, contradict, criticize, summarize continent, or otherwise involve in whole or in part 12 "You means You, along with any organization or entity in which You have management or controlling interests together with all present and former directors officers, employees, agents representatives or any other persons acting or purporting to not, on Your behalf 1 II Instructions 1 when providing Your responses, indicate the Request to which each Document or answer . responds in the metadata field, Request No 2 Documents produced pursuant to these Requests shall be produced as they are kept in the i ordinary course ofbusiness i 3 For each Document that You produce, produce the current version together with all earlier ‘ editions or predecessor Documents during the relevant time period, even though the title l of earlier Documents may differ fiom current versions Format for Documents produced 1 electronically l l a Data shall be produced in single page TIFFs at a 300 DPI resolution which i are named for the Bates Number of the page There shall be no more than l 1000 images per folder Bates numbers confidentiality designations, and i redactions shall be humed into the TUTF image file so as not to unreasonably ‘ obstruct any information on the page l l b Document Unitization Each page of a Document shall be electronically i converted into an image as described above If a Document is more than l one page the unitization of the Document and any attachments and/or i affixed notes shall be maintained as it existed in the original when creating i the image file and appropriately designated in the load files The i corresponding parent/attaclment relationships to the extent possible, shall i be provided in the load files furnished with each production c Include Document level text files containing optical character recognition i (“OCR”) or extracted text named with the Bates Number of the first page ofthe Document ‘ d Include data load files containing all ofthe metadata fields (both system and l application see list below) from the original Native Documents with 1 extension dat for Concordance l ‘ e Include the database field name in the first line ofthe metadata file, in such 1 a manner that it is clear how the metadata is organized in the file I ‘ f Include an image load file for Concordance such as opt 1 g All hidden text (e g , track changes, hidden columns comments notes etc ) i shall be expanded, extracted, and rendered in the TIFF file h Documents created in Excel (spreadsheets), CSV files Access (databases) and audio and video media files shall be produced in Native format The extractable metadata and text shall be produced in the same manner as other Documents that originated in electronic form (as described herein) to the extent that metadata exists or is reasonably accessible i Email attachments and embedded files or links shall be mapped to their parent j Produce all attachments to responsive Documents attached to the responsive Documents k De-duplicate prior to production To the extent that exact duplicate Documents (based on MDS or SHA 1 hash values at the Document level) reside within a party’s data set, each party is only required to produce a single copy of a responsive Document, so long as there is a data field that identifies each custodian who had a copy In addition Documents may be de duplicated in such a way as to eliminate earlier or incomplete chains of emails, and produce only the most complete iteration of an email chain so long as there is a data field that identifim each custodian who had a copy REQUIRED METADATA FIELDS BEGDOC ENDDOC BEGATTACH ENDA'ITACH ATTCOUNT ATTACH CUSTODIAN AUTHOR CC FILESIZE PGCOUNT DATERECD TIMERECD DATESENT TIMESENT CRTDATE CRTTHME \ ‘ l 1 f i l l X ‘ ‘ —— ‘ 4 Format for hard copies ofDocuments produced in response to this Request \ 1 a Re type the question or request to which the Documents respond and firmly I attach the Documents to the rte-typed request; 1 1 tL b Number all Documents consecutively, consistently with the numbers used for the Documents produced electronically 5 Unless othermse indicated the relevant time period for this Request for Production of Documents is January 1 1998 to the present 6 Ifno Documents responsive to a particular request exist, so state 7 As to any Document which no longer exists but which You are aware existed at one time, identify such Document with as much particularity as possible and in addition identify the last known location of the Document, the reason the Document is no longer in existence, and the person responsible for the Document s disposition 8 For information that You withhold on the basis of privilege, provide a descriptive list of each Document stating the grounds for Your refusal and providing the following information the name or title of the Document; 3 description of the nature and subject matter of the Document sufficient to enable a meaningful challenge to the assertion of privilege; the date, author(s), sender(s) and recipient(s) of the Document including whether the person is an attorney and/or was an employee of Banco Popular de Puerto Rico at the time the Document was authored sent or received, and the nature of the privrlege 9 These requests shall be deemed continuing in character so as to require prompt supplemental responses if additional Documents called for herein are obtained, discovered, or become known to You between the time of responding to the Requests and the final disposition of this action 10 Social Security numbers may be redacted from documents to the extent required by applicable law 111 Re nests for the Production of Documents Please produce the following 1 All Documents and discovery obtained or provided in other litigation concerning or concealing allegations that You or Jeffrey Epstein engaged in sexual abuse, human trafficking, commercial sex, or pomography, including in the Virgin Islands 2 Transcripts and Video recordings of all depositions taken ofYou in Gmflre v Maxwell (No 15 CV 07433 RWS) and Romania v Epstein Maxwell et al (No 17 Civ 0616 JGK) l i 3 All Documents You reference or rely on in the complaint in Maxwell v Estate ofJefil‘ey E Epstem Civil Case No ST 20 CV 155 l l 4 All Documents reflecting or concerning travel to or from the Virgn Islands for You I ‘ Jeffrey Epstein, or other individuals 5 All Documents reflecting or concerning communications between You, or Your agent or representative, and Darren indyke, or Richard Kahn 6 All Documents reflecting or concerning communications between You, or Your agent or i representative, and Jeffrey Epstein For this Request provide documents from 1991 to ‘ present l 7 All Documents reflecting or concerning Your allegation that Jeffrey Epstein agreed to i indemnify you pay Your legal fees, or otherwise provide financial support to You including, but not limited to, the notes referenced in Maxwell v Estate ofJeflrey E Epstein Civil Case No ST 20 CV 155 8 All Documents reflecting or concerning your employment for the companies and entities You described in Maxwell v Estate ofJejfi‘ey E Epstein Civil Case No ST 20 CV 155 9 All Documents reflecting or concerning massages or other services You arranged or -‘ compensated for Jeffiey Epstein 10 All Documents reflecting or concerning a list ofmasseuses kept for any ofthe properties owned or controlled by Jeffrey Epstein 11 All photographs ofJeffrey Epstein including but not limited to all photographs ofYou and Jefliey Epstein 12 All photographs or videos taken ofany ofthe women or girls who ever provided a massage for Jeffrey Epstein, regardless of location, or any Visitor at Great St James or Little St James 13 All Documents reflecting or conceming a list ofnames, numbers, and addresses kept at any ofthe properties owned or controlled by Jefii‘ey Epstein 14 All Documents reflecting or concerning lists ofnames, numbers and addresses You ‘ created or kept in the course ofYour employment; as You described in Maxwell v ‘ Estate ofJefii‘ey E Epstein Civil Case No ST 20 CV 155 J 15 All Documents reflecting or concerning the purchase, maintenance, construction, permits, or other services provided to or obtained in connection with Great St James or Little St James 16 All Documents reflecting or conceming tax incentives obtained by Epstein or any Epstein Entity from the Government of the Virgin Islands or any agency or entity associated with the Government 17 All Documents reflecting or concerning communications between You, Jeffrey Epstein or any Epstein Entity with or about the Govemment of the Virgin Islands, or any agency or entity associated With the Government 18 All Documents reflecting or concerning visitors to or houseguests of Great St James or Little St James 19 Documents sufficient to identify all email addresses, telephone numbers and social media accounts used by You and Jeffrey Epstein (You may answer this question, rather than provide responsive documents ) 20 All Documents reflecting or concerning communications between You and/or Jeffrey Epstein and any Person who visited or was a houseguest at Great St James or Little St James regarding the Person’s visit or other visttors to the Island 21 All Documents reflecting or concerning travel on any airplane helicopter or boat owned or used by You or Jeffrey Epstein, including but not limited to Air Ghislaine 22 All Documents reflecting or concerning transfers or payment ofmoney or other assets between You, Jeffrey Epstein, any Epstein Entity or agent any entity ofwhich you are an owner officer, shareholder, or employee 23 All Documents reflecting or concerning bank accounts securities or other investments property, or other assets held by or transferred to or from Jeffrey Epstein or any Epstein Entity or agent 24 All Documents reflecting or concerning visas or other travel arrangements for models or other women or girls transported to the United States including the Virgin Islands 25 All photographs, Videos audio messages and/or any other visual media or audio recording reflecting You Jeffrey Epstein, and/or any Visitor to Little St James or Great St James l 26 All Documents reflecting or concealing the presence ofany Person on Little St James l or Great St James for any purpose, including, but not limited to, any contractors or employees of Epstein or any Epstein Entity 27 All Documents reflecting to any offer ofemployment or contract of employment, severance agreement, or non disclosure agreement for any employee ofJeffrey Epstein or any Epstein Entity, including but not limited to, temporary, part time, or full time employees, in any capactty, at Little St James or Great St James ‘ 28 Your telephone and credit card statements i 29 All Documents reflecting or concerning payments You received from any Epstein Entity 30 All Documents reflecting or concemrng Your role as Director and Treasurer ofFinancial ‘ Trust Company, including, but not limited to, payroll records, client lists, vendor lists, correspondence bank statements or account documents, and business plans 31 All Documents reflecting or concerning identification documents (such as passports or driver licenses) for visitors to Little St James or Great St James l l r r l EXHIBIT B Subpoena Duces Tatum directed to Ghislaine Maxwell RECORDS DELIVERY ONLY NO ORAL TESTIMONY WILL BE TAKEN IF RECORDS ARE DELIVERED PRIOR TO April 17 2020 YOU NEED NOT APPEAR If more than thirty (30) days is needed to respond to this subpoena, please contact the Civil Division Chief, Attorney Ariel Smith, at the Virgin Islands Department ofJustice WW 1 Jeffrey E Epstein 2 Estate ofIcffiey E Epstein 3 The 1953 Trust 4 Plan D LLC 5 Great St Jim LLC 6 Nautilus Inc 7 Hypen‘on Air LLC 3 Poplar Inc 9 C 0 U Q Foundation 10 Epstem Foundation, Inc 11 Epstein 111th 12 Gmmude America LTD 13 J Epstein Foundanon Inc 14 Southern Trust Co 15 Financial Trust Co Inc 16 IGY AYI-I St Thomas Holdings LLC 17 Maple, Inc 18 Cypress, Inc 19 Laurel Inc 20 JEGE LLC 21 Southem Country International 1 i 1 i EXHIBIT C 1 i i i 4 i , UNITED STATES DISTRICT COURT i SOUTHERN DISTRICT OF NEW YORK i x SEALED UNITED STATES OF AMERICA INDICTMENT i v 20 Cr GHISLAINE MAXWELL 20 C 330 i 1'. 3 Defendant ; x ; § COUNT ONE ' (Conspiracy to Entice Minors to Travel to Engage in ; Illegal Sex Acts) The Grand Jury charges ; x OVERVIEW 1 The charges set forth herein stem from the role § « ‘ of GHISLAINE MAXWELL the defendant in the sexual exploitation . E 1 and abuse of multiple minor girls by Jeffrey Epstein In a particular, from at least in or about 1994, up to and including 1. at least in or about 1997, MAXWELL assisted, facilitated, and . I contributed to Jeffrey Epstein's abuse of minor girls by, among other things helping Epstein to recruit groom and ultimately ‘ 1 abuse victims known to MAXWELL and Epstein to be under the age i of 18 The Victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain Victims were in fact under the age of 18 2 As a part and in furtherance of their scheme to abuse minor Victims, GHISLAINE MAXWELL, the defendant, and 1 Jeffrey Epstein enticed and caused minor victims to travel to i . 1 I Epsteln’s reSIdEHCes 1n different states, which MAXWELL knew and 1ntended would result 1n thelr grooming for and subjectlon to sexual abuse Moreover, 1n an effort to conceal her crimes MAXWFLL repeatedly lled when questicred about her conduct, lncludlng 1n relat1on to some of the mlnor Victims deSCrlDSd hereln, when providlng testimony under oath in 2016 FACTUAL BACKGROUND 3 Durlng the tlme parlods charged 1n this Indlctment GHISLAINE MAXWELL, the defendant had a personal and proresslonal relatlonshlp w1th Jeffrey Epstein and was among hls closest associates In particular, between 1n or about 1994 and 1n or about 1997, MAXWELL was 1n an lntlmate relationshlp with Epsteln and also was paid by EpStEln to manage hls various properties Over the course of their relaLlOnShlp, MAXWELL and Epstein were photographed together on multiple occaslons, 1nclud1ng Ln the below Jmage g ‘5" . A x. g a? h ..n- 2 l i 4 Beginning in at least 1994, GHISLAINE MAXWELL ! i the defendant, enticed and groomed multiple minor girls to engage in sex acts With Jeffrey Epstein, through a variety of 2 means and methods, including but not limited to the folloWing ‘ ‘ a MAXWELL first attempted to befriend some of 1‘ Epstein’s minor Victims prior to their abuse, including by asking the Victims about their lives, their schools, and their ‘ families MAXWELL and Epstein would spend time building ‘ friendships with minor VlctlmS by, for example, taking minor i Victims to the mOVies or shopping Some of these outings would ! ‘ involve MAXWELL and Epstein spending time together with a minor ’ l 1 victim, while some would involve MAXWELL or Epstein spending ' time alone With a minor Victim I i b Having developed a rapport with a Victim, I MAXWELL would try to normalize sexual abuse for a minor Victim ' by, among other things, discussing sexual topics, undressing in l 1 front of the victim, being present when a minor Victim was { i undressed, and/or being present for sex acts involving the minor E ‘ victim and Epstein c MAXWELL’S presence during minor Victims' I ‘ interactions With Epstein, including interactions where the 9 minor Vlctlm was undressed or that involved sex acts With 1 1 Epstein, helped put the Victims at ease because an adult woman i was present For example, in some instances, MAXWELL would 3 l l l i 1 massage Epstein in front of a minor Victim In other instances, i MAXWELL encouraged minor Victims to prov1de massages to Epstein, including sexualized massages during which a minor Victim would be fully or partially nude Many of those massages resulted in Epstein sexually abuSing the minor victims d In addition, Epstein offered to help some ; minor victims by paying for travel and/or educational ] opportunities, and MAXWELL encouraged certain Victims to accept I Epstein’s assistance As a result, Victims were made to feel i! indebted and believed that MAXWELL and Epstein were trying to i help them 1‘ e Through this process MAXWELL and Epstein 1i enticed Victims to engage in sexual activ1ty With Epstein In 1 some instances, MAXWELL was present for and pert1c1pated in the sexual abuse of minor Victims some such incidents occurred in the context of massages, which developed into sexual encounters 5 GHISLAINE MAXWELL, the defendant, facilitated Jeffrey EpStETLn's access to minor Victims knowing that he had a ‘ sexual prefeience for underage girls and that he intended to i engage in seimal actiVity with those Victims Epstein's i resulting abuse of minor victims included, among other things, I touching a Victim's breast, touching a Victim’s genitals, placing a sec toy such as a vibrator on a Victim‘s genitals, i l g 4 i l directing a Victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals MAXWELL AND EPSTEIN S VICTIMS 6 Between approximately in or about 1994 and in or about 1997 GHISLAINE MAXWELL the defendant, facilitated Jeffrey Epstein’s access to minor Victims by, among other things, 1nduCing and enticing, and aiding and abetting the inducement and enticement of, multiple minor Victims Victims were groomed and/or abused at multiple locations, including the follow1ng a A a multi story private res1dence on the Upper East Side of Manhattan, New York owned by Epstein (the “New York Reeldence’), which is depicted in the follow1ng photograph '( PEI 4’ i in... 1%th I». J ‘ i Q "“ ‘ ‘- , ;~»717 2TH -J all , 1‘5 *3 “:4 , \e a “fife“: in? ’9.” ‘ . l' yw ; r as» "q“ l a» . V ' H“; EL?! h . P 3" S ‘é I w 1_ e ‘ » rm ,3; , a x -. f It“?! :3 gm ‘\ ‘ land's "fl 3 4 w a,” , “:1! M an mwx ‘gr l (Rigs! e ' I} J? ‘ 5 '. 5 Hm“ L*E‘\‘§1LJ—$h ;‘ I f1 j? as H "3‘. WW ‘3 “ Aim 9% \ » ,V ‘ . y v , . r y a w: m w :4 a M H <1 4}" *1’!v(.\"“ ; , 4&1 , the). “L PM“ 7'79 is " , 5 b An estate 1n Palm Beach, Florida owned by Epstein (the “Palm Beach Residence ), which is depicted 1n the follow1ng photograph - 1 r W ‘ r I 't \‘ we; a I ’ r Xi H ‘ ' ”53 H M ‘ {‘E ‘ I. .. H ‘4 \ A‘ c A ranch in Santa Fe New Mexlco owned by Epstein (the “New Mexico Residence"), which is depicted 1n the follow1ng photograph ~ ; vb 5-4;)» ,; ’3‘, up i «a: “V“ Kg..;‘§,fu‘m 1‘ * f ‘jltgzv‘ms g a“ V r ‘ ‘ I a. ’ i f . a.» W » w a: 4‘ 1’ a s. ." ‘ ‘ \ V x’ \iv' \ ' * x ‘ A ‘ ‘ m k)» ‘. , h! ..~ ‘33»; \. x ‘ xv ’ fif‘ ; 6 1 ‘ w 1 1 i d MAXWELL's personal residence in London, 1 England 1 7 Among the Victims induced or enticed by GHISLAINE 1 MAXWELL, the defendant, were minor VlctlmS 1dent1fied herein as 1 1 Minor Victim 1, Minor Victim 2, and Minor Vlctim 3 In 1 particular, and during time periods relevant to this Indictment, 1 1 MAXWELL engaged 3.11 the follow1ng acts, among others, with 1 respect to minor Victims ‘ a MAXWELL met Minor Victim 1 when Minor 1 1 Victim 1 was approximately 14 years old MAXWELL subsequently 1 interacted with Minor Victim l on multiple occasnms at Epstezn's residences knowmg that Minor Victim 1 was under the 1 age of 18 at the time During these interactlons, which took 1 place between approxunately 1994 and 1997, MAXWELL groomed Minor 1 Vict1m 1 to engage in sexual acts w1th Epsteln through multiple I > 1 means First MAXWELL and Epstein attempted to befriend Minor 1 Victim 1 taking her to the mov1es and on shopping trips 1 MAXWELL also asked Minor Victim 1 about school, her classes, her 1 1 family, and other aspects of her life MAXWELL then sought to 1 normalize inappropriate and abuslve conduct by, among other 1 things undressing 111 from: of Minor Victlm 1 and being present 1 when Minor Victim 1 undressed in front of Epstein Within the first year after MAXWELL and Epstein met Minor Victim l, Epstein 1 1 began sexually abusing Minor Victim 1 MAXWELL was present for 1 1 1 i 7 1 \ li g and involved in some of thls abuse In partlcular, MAXWELL 1nvolved Minor VlCtlm 1 1n group sexuallzed massages of Epstein \ Durlng those group sexuallzed massages, MAXWELL and/or Minor l victim 1 would engage in sex acts w1th Epsteln Epsteln and ‘ MAXWELL both encouraged M1nor Victlm 1 to travel to Epsteln's E \ residences 1n both New York and Florlda As a result, Mlnor Vlctlm 1 was sexually abused by Epstein 1n both New York and j Florlda Mlnor Vlctim 1 was enticed to travel across state lines for the purpose of sexual encounters w1th Epstein, and I MAXWELL was aware that Epstein engaged in sexual activ1ty w1th ! Mlnor V1ct1m 1 after Mlnor Vlctlm 1 traveled to Epsteln’s propertlee, includlng 1n the context of a sexuallzed massage b MAXWELL 1nteraeted with Mlnor Vlctlm 2 on at E least one occa51on mm or about 1995 at Epstein's residence 1n 1 New Mex1co when M1nor V1ct1m 2 was under the age oi 18 M1nor 1 VlCClm 2 had flown lute New Mexico from out of state at 1 Epstein's inv1tatlon for the purpose of helng groomed for and/or ‘ subjected to acts of sexual abuse MAXWELL knew that Mlnor ‘ Victim 2 was under the age of 18 at the time While in New Mexlco MAXWrLL and Epsteln took Mlnor V1ct1m 2 to a mov1e and MAXWELL took Minor Vlctlm 2 shopplng MAXWELL also dlscuesed Mlnor V1ct1m 2's school, classes, and family with Mlnor Victlm 2 In New Mexico, MAXWELL began her efforts to groom Mlnor Victim 2 for abuse by Epsteln by, among other thlngs, prov1d1ng B an unsolicited massage to Minor Victim 2, during which Minor Victim 2 was topless MAXWELL also encouraged Minor Victim 2 to ‘ massage Epstein i i e MAXWELL groomed and befriended Minor ‘ ‘ Victim 3 in London, England between approximately 1994 and 1995 E including during a period of time in Whlch MAXWELL knew that E 1 Minor Victim 3 was under the age of 18 Among other things, I ‘ MAXWELL discussed Minor Victim 3’s lite and family with Minor { Victim 3 MAXWELL introduced Minor Victim 3 to Epstein and arranged for multiple interactions between Minor Victim 3 and Epstein During these interactions, MAXWELL encouraged Minor 1 1 Victim 3 to massage Epstein, know1ng that Epstein would engage I in sex acts w1th Minor Victim 3 during those massages Minor i ‘ Victim 3 prOVided Epstein With the requested massages, and ' during those massages, Epstein sexually abused Minor Victim 3 ‘ MAXWELL was aware that Epstein engaged in sexual activity With 1 MILDQI‘ Victim 3 on multiple occasions, including at times when ‘ 1 Minor Victim 3 was under the age of 18, including in the context 1 1 of a sexuallzed massage ‘ MAXWELL S EFFORTS To CONCEAL HER CONDUCT i i a In or around 2016, in the context of a deposition 1 ‘ as part of CiVll litigation GHISLAIN‘E MAXWELL, the defendant, repeatedly prov1ded false and perjurious statements under oath, regarding, among other subjects, her role in facilitating the 9 I 3 abuse of minor Victims by Jeffrey Epstein, including some of the 1 specific events and acts of abuse detailed above I STATUTORY ALLEGATIONS »: u 9 From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York E and elsewhere, GHISLAINE MAXWELL, the defendant Jeffrey Epstein, and others known and unknown, willfully and know1ng1y did combine, conspire, confederate, and agree together and With each other to commit an offense against the United States, to wit, enticement, in Violation of Title 18, United States Code, 1 Section 2422 ‘ 10 It was a part and Object of the conspiracy that 1 GHISLAINE MAXWELL the defendant Jeffrey Epstein and Others known and unknown, would and did knOWingly persuade induce I entice, and coerce one and more indiv1duals to travel in E interstate and foreign commerce, to engage in sexual activity 1 for which a person can be charged With a criminal offense, in 4 Violation of Title 13, United states Code, Section 2422 i Overt Acts 1 11 In furtherance of the conspiracy and to effect 1 the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere 10 l I l l ‘ , J i ‘ a Between 1n or about 1994 and in or about H 1997 when M1nor V1ct1m 1 was under the age of 18, MAXWELL ‘1‘ ‘ part1c1pated 1n multiple group sexual encounters wlth Epsteln F and Mlncr Vlctlm 1 In New York and Florlda 4 ‘ h In or about 1996, when Mlnor V1ct1m 1 was i under the age of 18, Mum): Victim 1 was enticed to travel from J 1 Florlda to New York for purposes of sexually abuslng her at the :1 ‘ New York Resldence, 1n violatlon of New York Penal Law, Sectlon J l 130 55 if i c In or about 1996, when Mlnor Vlctim 2 was {I ‘ under the age of 18 MAXWELL prmuded M1nor victim 2 with an < ‘ unsolicited massage in New Mexlco, durlng whlch Minor Vlctim 2 J‘ ‘ was topless l ‘ ‘ d Between m or about 1994 and In or about i 1995, when Minor V1ct1m 3 was under the age of 18, MAXWELL i J ‘ encouraged Minor V1ct1m 3 to provide massages to Epsteln 1n 4: 1 London, England know1ng that Epsteln intended to sexually abuse I: Minor V1ct1m 3 durlng those massages § (Title 18 muted States Code Section 371 ) 11‘ ‘ COUNT TWO ; (Enticemenb of a Minor to Travel to Engage in Illegal Sex Acts) 1 ‘ The Grand Jury further charges E ‘ 12 The allegations contalned in paragraphs 1 ‘ through 8 of this Indlctment are repeated and realleged as if I I fully set forth w1th1n J E 1 11 a i i i i 13 From at least in or about 1994 up to and 1 including in or about 1997, in the Southern District of New York K and elsewhere, GHISLAINE MAXWELL the defendant, know1ng1y did 1 persuade, induce, entice, and coerce an 1ndiv1dua1 to travel in interstate ard foreign commerce to engage in sexual act1v1ty for i which a person can be charged with a criminal offense, and attempted to do the same and alded and abetted the same, to i w1t, MAXWELL persuaded, induced, enticed, and coerced Minor i Vlctlm 1 to travel from Florida to New ¥ork, New York on i multiple occasions with the intention that Minor Victim 1 would i engage in one or more sex acts with Jeffrey Epstein, in 3 v1olatlon of New York Penal Law, Section 130 55 i 2 (Title 18 United States Code Sections 2422 and 2 ) , COUNT THREE (Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity) 1 The Grand Jury further charges i 14 The allegations contained in paragraphs 1 i through a of this Indictment are repeated and realleged as if i fully set forth Within ; 15 From at least in or about 1994, up to and includlng in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL the defendant Jeffrey Epstein, and others known and unknown, w1llfully and knowingly did combine, conspire, confederate, and agree together and Wlth each other to commit an offense agamst the United states, to 12 l l 1I i i mt transportation of minors, in Violation of Title 18, United States Code Section 2423(a) I 1 16 It was a part and obgect of the conspiracy that ‘ 1 ‘ GHISLAINE MAXWELL the defendant Jeffrey Epstein and others known and unknown, would and did, know1ngly transport an } 1nd1v1dua1 who had not attained the age of 18 in interstate and 5 ; foreign commerce, With intent that the individual engage in I sexual act1v1ty for which a person can be charged Wlth a 1 1 crlminal offense, in Violatlon of Title 18, United States Code, ; Sectlon 2423(a) ‘ Overt Acts % < 17 In furtherance of the conspiracy and to effect j ‘ the illegal object thereof the following overt acts among % ‘ others, were committed in the Southern District of New York and i ‘ elsewhere i ‘ a Between in or about 1994 and in or about I 1997 when Minor Victim 1 was under the age of 13, MAXWELL t i participated in multiple group sexual encounters w1th EPSTEIN i I and Minor VlCtlm 1 in New York and Florida 1 b In or about 1996, when Minor Vlctim 1 was 1 ‘ 1 1 under the age of 18, Minor Victim 1 was enticed to travel from s i Florlda to New York for purposes of sexually abusing her at the i \ \ 1 l l 1 13 ‘ New York Residence, in Vlolatlon of New York Penal Law, Sectlon 130 55 c In or about 1996, when Mlnor V1ct1m 2 was under the age of 13, MAXWELL provxded Minor V1ct1m 2 with an unsoliclted Massage 1n New Mexlco, durlng Wthh Minor Victim 2 was topless d Between in or about 1994 and 1n or about 1995, when Minor V1ct1m 3 was under the age of 18, MAXWELL encouraged Minor V1ct1m 3 to provzde massages to Epstein 1n ‘ London, England, know1ng that Epstein 1ntended to sexually abuse i Mlnor V1ct1m 3 during those messages 3 ("rule 18, muted States Code Sectlon 371 ) % COUNT FOUR (Transportation of a Minor with Intent to ‘ Engage in criminal Sexual Activity) The Grand Jury further charges 18 The allegatlons contalned 1n paragraphs 1 through 8 of thls Indlctment are repeated and realleged as 1f fully set forth w1th1n 19 From at least in or about 1994 up to and includlng in or about 1997, 1n the Southern D15tr1ct of New York and elsewhere, GHISLAINE: MAXWELL the defendant, knowlngly did transport an indlvidual who had not attamed the age of 18 m 1nterstate and forelgn commerce, w1th the 1ntent that the 1nd1v1dual engage in sexual actlvity for whlch a person can be charged w1th a crlmlnal offense, and attempted to do so, and 14 i I 1 aided and abetted the same, to Wit MAXWELL arranged for Minor 3 Victim 1 to be transported from Florida to New York, New York on 1 1 multiple occasions with the intention that Minor Victim 1 would 1 1 engage in one or more sex acts With Jeffrey Epstein, in 1 violation of New York Penal Law, Section 130 55 (Title 15 United States Code Sections 2423(a) and 2 ) 1 1 COUNT FIVE (Perjury) 1 1 The Grand Jury further charges 1 20 The allegations contained in paragraphs 1 1 through a of this Indictment are repeated and realleged as if fully set forth Within 1 21 On or about April 22 2016 in the Southern 1 District of New York GHISLAINE MAXWELL, the defendant having 1 1 taken an oath to testify truthfully in a deposition in 1 1 connection with a Case then pending before the United states 1 1 District Court for the Southern District of New York under 1 1 docket number 15 civ 7344, knowingly made false material 1 declarations, to Wit, MAXWELL gave the follow1ng underlined 1 false testimony 1 Q Did Jeffrey Epstein have a scheme to recruit 1 underage girls for sexual massages9 If you know 1 A I don't know what gou're talking about 1 1 1 1 15 l i I 1 i Q List all the people under the age of 18 that you interacted With at any of Jeffrey’s properties? A I'm not aware of anybody that I interacted With, other than ObVlOuSlZ [the Elalntlff] who was 17 at this Eoint 3 (Title is United States Code Section 1623 ) 1 COUNT SIX 1 (Perjury) ‘ The Grand Jury further Charges 22 The allegations contained in paragraphs 1 1 through 8 of this Indictment are repeated and realleged as if 1 fully set fOlth within l 23 On or about July 22 2016 in the Southern I District of New York GHISLAINE MAXWELL, the defendantl haVing 1 taken an oath to testify truthfully in a deposition in 1 connection with a case than pending before the United States ‘ District Court for the Southern District of New York under I ‘ docket number 15 Civ 7344, knowingly made false material i declarations to wit, MAXWELL gave the follow1ng underlined 1 false testimony Q Were you aware of the presence of sex toys or deVices used in sexual actiVities in Mr Epstein's Palm Beach house? A No not that I recall Q Do you know whether Mr Epstein possessed sex toys or deVices used in sexual activities? A No 16 ‘ \ I ‘ t i ! 3 Q other than yourself and the bland and brunette ‘ that you have 1dent1f1ed as havlng been involved in three way sexual activ1t1es, with whom am Mr } Epstein have sexual act1v1t1es? ‘ A I wasn't aware that he was hav1ng sexual i activitles w1th anyone when I was wlth hlm other ’ than myself } i 1 Q I want to be sure that I'm clear Is 1t your 1 1 testimony that 11') the 19905 and 20005 you were not aware that Mr Epstezn was having sexual activ1t1es w1th anyone other than yourself and { the blond and brunette on those few occa51ons . ‘ when they were involved with you? I ‘1 A That is my testlmony, that 15 correct I \ 1 Q Is 1t your testlmony that you’ve never glven anybody a massage? 1 A I have not glven anyone a massage : x Q You never gave Mr Epsteln a massage, is that ‘ your testlmony? ; A That 15 my testlmony Q You never gave [Minor Vlctlm 2} a massage 13 your ‘ testlmony? 1 A I never gave [Mlnor V1ct1m 2] a massage 1 ‘ (T1t1e 13 United States Code, Section 1623 ) 1 Show WPERSCN“ AUDREY RAUSS Acting n1ted states Attorney 17 I A i 1 Form No USA 335 274 (Ed 9 25 58) 1 ] UNITED STATES DIETRICI‘ COURT : SOUTHERN DISTRICT OF NEW YORK W i UNITED STATES or AMERICA 3 J GHISLAINE MAXWELL 1 Defendant j W ' I INTJICTMENT 1 (18 U S C §§ 371, 1623 2422 2423 (a), and 2) AUDREY STRAUSS I Actlng muted states Attorney i . i I / Foreperson ‘ g L \ 1 \ ‘ 18 l \ \ EXHIBIT D x \ I 1 UNI II I) b I ATFS VIRGIN ISLANDS DFI’ARTIVIENT 01" IUQTICI‘ OFFICE OF 'lHL Al 10Rva ( I NLRAL III re Subpoena In! Records for GIIiilniue M ““0" Case M) N/»\ m Ah I [DA y IT QF S! EVICE I Rand Pun: 1 p. Ivan: Proms 501'ch Ming duly mom Ilepose and say HIM I h M. bun duly Ju|lmriLud [0 make sen/in Billie Subpocn I Dunes Icon"! mlhl Vliibils in [he lbw: wlillul was Hm I «In our the age 01 cigluccn yum and not a pally [a m ollmwisc irl|clesled in mi: «mun Hm on v 20/2020 al 12 IO PM, I served (JIIISIIIIIIL Maxwell do Quiluallos Plum Wood 8L Bayer P A \\ill| Ilia Suhpncm Dumas chllm with I xhlblts m 9300 50ml] Dadclalld Boulcvmd, 401 I I00! Miami Florida all if: b) SLIviIIg LriL Boys! DESIgMHCd Agni! Mm stifled ”If“ he/she is allllmrllexl In duepl Service on bLlhllI DI Gllislflulc Maxwell (2/0 Quilll mos I‘IICK) Wood & Boyer PA LuL Emu is desclibcd [min as Gaul“ Malt Ram/5km \VIIIIL my. 40 V \Vciglvl IX!) ”Eight 1'6 I In“ WIHIC (ilMiCs NO I dulam mule: new“) 09 pexjury llIle \his mfolnmliun IS nu: and mum Sum" to below me on 3l1‘1l 101° E] ‘” El mm mm Mm . " ,1. It: M . ,. I my Pam sun at Floflda 3: ‘ ’3'”) \Gabriala Padmn El ”Y CWMIIIIW 66 925484 Chem Rel Numbel N/A 3,"; may" “me/2w: Jab # 1576402 C1piIoI Prunes SLI was In: l 1827 13m Sinai NW \\ 1Sllinglun DC 2000‘) I (202) 667 0050 $0M '4’ UNITED STA’l ES VIRGIN ISLANDS WYJD i DEPARTMENT OF JUSTICE OFFICE OF TIIE ATTORNEY GENFRAL \ \O? 1* *****CICO SUBPOENA***** E tf DUCES TECUM Cf t ‘— V SUBPOENA FOR RECORDs CASE IN THE NAME on THE covutNiviENr or THE VIRGIN ISLANDS T0 Ghislalnn Maxwell do Qulntairos, Frielo, Wood & Boyer, P A 9300 s Dadelnuu Blvd i 4‘” Hour t Miami FL 33m ATTN an R Waitiner Es! Title 14 v [C p anti) provides dial [leieneverpngpersaii ig reasanahiy smpecied to have engaged in or to be engaging in or about to engage in any (dint! @5138“? aging/151g“ ufianuprthe provisions oieeetion 605r the Attorney General may, in his diaereirpnegeiégei afiiiiiesEggiig (eithegenégueitghe Attorney General is authorized heiore the cummeneenient mfg-El dufng an; 0in or criminal préceedtg‘g‘b gamer under this chapter to subpoena witnesses, compel their Winnipegt e)\ra/mfi‘ie them under eggs, or to requnetite’ppengLipn of any hanks, documents, records, writings, recordiiggfs/g/figiigplate things (hereinajo eferred to as ‘ dmumenturyfiiateriat ') relevant or material to the investigafien: minimum, reproduging,‘ajidlqr gopying ‘. v , (i v; / I 'V In / l" \ Pursuant to Title 14 vi (2 Section 6121a) remnant: HEREBvfiigjviivrAgfiutn to predupe forthwith Copics of the documents listed in Exhibit, A ' ‘ \ i ’ i ‘ i r \ f T t t t Pursuant to N V I C § Q an) the documents requ§§ledi5 in gramme 1% gngoingpnyesiiggtion by the Virgin Islands Department g marker hr the rupegihuse gxpluilhtiqn anti unfit}; gig! young @rfienand underage girls by Jeffrey I: Epstein anti hisfidcintcs in violation or 14 v, I q 9 l3} and l «as welt mutafivngin Islands statutes 5;, ‘ Persoml appearance is net{@ifié: sallsfy this sukiyaenn instead Wise fiF0leigstliz twinned biennium to Speclal Agent Tarique tannin git, ‘gparlnlenl QfiJusliQEn / { j ’/_/ PLACE Unjled States virgin regain; N DATE April 17 2020 Department unwise r I it, 3430 Kmnpnndsells Gide G E RS Complex 2 “Floor TIME 3 on p in st Thomas VI 00302 5712 f NOTE This suhpnena places you on notice of an investigation by the Virgin Islands Department or ‘ Justice You must maintain, and may not destroy, any documents, electronic records, or other material relating to Jeflrey Epstein and the entities described in the subpoena ‘ Failure to produce |hc documents requested may cause the Attorney General to petition the Superior Court to ' compel you in produce the dominating mqucMed and lo me. ismaucc ofa “mum in: yum mm, uudci This” VIC i2 512(k) W m1 :0 [his H day DiMarcii 2020 Ami M ?Ilifl|, Esquiic Chief cine (hi1 Division V I Deparimcm of Justice Office or [he Aliomcy General 3438 Kmnprihdwns Clark G E R 5 Complex 2nd Floor SI 'llmlmx‘ V100802 (340) 774 56661:“ [0303 RETURN OF SERVICE Received by Sewn on Plum: Sen/rd on (Name) Date At Served by Time DECLARA'J {ON or SERVER l DECLARE UNDER PizNAL I \ 0|" PERIU'RY UNDER THE LAWS OF THE Uniled Sula: ofAmerica and (he lei-filmy oflllc Unncd 51mm Virgln Hands that ”in [ongoing information con|aiucd in Illa Relum ofService: Slalemem i: true and correct Executed an B) i 1 y 1 EXHIBIT E l 1 1 1 1 1 From david cattichattie law com Sent Wednesday April 15 2020 12 43 PM To Ariel Smith Subject [EXTERNAL MAIL]Ghis|aine Maxwell Good day Attorney Smith Please note that I have been retained by Ghislaine Maxwell in regard to two subpoenas from your office which were delivered to Quintairos Prieto Wood & Boyer in Miami Florida lam not sure about yourwork schedule in light ofthe COVlD 19 issues but I would like to meet orset up a conference call with you to discuss these matters Unfortunately I am having emergency surgery tomorrow so i will likely not be in a position to meet/Conference with you until the middle of next week Please let me know If/when you would be able to meet and your preferred method to conduct a meeting Thank you and I hope you are staying safe Dave 1310101; C1((18,Esq The Carrie Law Firm, P C [7.0 kongens Gade s: Thom15,V|rgin Islands 00300 T 340 7751200/1: 800 878 3237 www cattle law Com \ i * i EXHIBIT F 1" 1 fi 1 From Singer Linda Sent Friday May 1 2020 9 42 AM To David Callie Cc Ariel Smith Scott Carmen Subject flu on our conversation this week Attorney Cattie Hope that you are well when we spoke on Monday, you Indicated that you expected to have a response from your client by the end of this week Can you let us know where things stand? I would be happy to set up a call for this afternoon ifyou would preferto speak by phone Best Linda Linda Singer | Attorney at Law l Motley Rice LLC 401 9th St NW Suite 1001 lWashington DC 20004 0 202 385 9626 x5626 | f 202 386 9622 | lslnger@motleyrice com 1 \ i \ \ EXHIBIT G l I t 1 1 I V \ 1 E From david cattichattie law com Sent Tuesday May 12 2020 12 52 PM To Singer Linda lsingeerotleyrice coml Cc ArielSmith‘ Scott Carmen CarolJacobs‘ Subject RE EXTERNAL RE f/u on our conversation this week Good day counsels I thank you for your consideration in this matter I cannot waive the issue of service of the subpoenas nor can I disclose my client 5 location to anyone at this time in the interest of resolving this issue however lam willing to collect and provide the documents/items on the attached list As you know there are rather broad protective orders in the non VI litigation which preclude even me from accessing most ofthe information in those cases I have determined that I can provide the items on the attached list without running afoul ofthose protective orders If you are amenable to resolving the subpoenas in this manner please confirm that in writing (perhaps we should draft a short agreement to that effect) and I will collect and produce this information to you in short order If you would like to discuss this matter further, please let me know Dave David J Cattie, Esq l Attorney 8t Counselor at Law l The Cattie Law Firm, P C l tel 340 7751200/ fax Boo 878 5237 l e mail david cattie (Dcatrie law com l web 1ww Callie law mm l address I710 Kongens Gade, St Thomas V I 00802 1 l g ‘ EXHIBIT H 1 1 i From Singer Linda Sent Thursday May 28 2020 401 PM To david cattie@cattie law com Cc Ariel Smith Scott Carmen Carol Jacobs Subject RE EXTERNAL RE W on our conversation this week David Apologies for the slow response, and thank you for reaching out First my reading ofthe protective order as with most protective orders is that Ms Maxwell can share any document that she produced or other discovery material that she designated confidential Second, also perthe protective order, Ms Maxwell could seekthe consent of opposing counsel to produce the materials produced by the opposing party I suspect that would cover at least substantially all of the documents in that litigation Please let me know if you disagree with my interpretation In part we focused on these litigation materials because we believe that they would not be burdensome to collect and produce However, we also would be happy to discuss emails orother records that are relevant to the Governments investigation in Ms Maxwell‘s custody and control that could be produced outside of the protective order Please let me know ifyou would like to discuss Best Linda Linda Singer | Attorney at Law| Motley Rice LLC 401 9th St NW Suite 1001 |Wash|ngton DC 20004 0 202 386 9628 x5626 if 202 386 9622 | Isinger@motleyrlce Corn ‘ x 1 J1 EXHIBIT I 1. 3 ; 1 \ 1 S UNITED STATES VIRGIN ISLANDS DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL *****CICO SUBPOENA***** DUCES TECUM 1 SUBI’OENA FOR RECORDS CASE ST 20 CV 014 i IN THE NAME OF THE GOVERNMENT OF THE VIRGIN ISLANDS T0 Ghixlaine Maxwell i do David J Cattie, Esq 1710 Kongens (has St Thomas V I 00802 ATTN David J Came Esq l ‘ Title 14 V I C § 612(a) provides that “[w]henever any person is reasonably suspected to have engaged in, or to be engaging in’ or about to engage in any conduct constituting a violation of any of the provisions of section 605r the Attorney General may in his discretion, conduct an investigation of the conduct The Attorney General is authorized before the commencement ofand during any civil oi ‘ criminal proceeding or action under this chapter to subpoena witnesses, compel their attendance, examine l them under oath or to require the production of any books, documents records, writings recordings or l tangible things (hereinafter referred to as documentary material”) relevant or material to the investigation, for inspection, reproducing, and/or copying Pursuant to Title 14 V I C Section 612(a) YOU ARE HEREBY COMMANDER to produce forthwnh copies of the documents listed below in Exhibit/i ‘ Pursuant to 14 V I C § 612(c) the documents requested is in reference to an ongoing investigation by the l Virgin Islands Department of Justice of the rape, abuse, exploitation and trafficking ofyoung women and underage girls by Jeffrey B Epstein and his associates in Violation of 14 V I C § 133 et seq , as well as other Virgin Islands statutes Personal appearance is not required to deliver the documents required by this subpoena instead, please provide them io Special Agent Tarique Turnhnll, Department of Justice PLACE United States Virgin Islands DATE July 2 2020 Department of Justice ‘ 3438 Kronprindseris owe l G E R S Complex 2 d Floor TIME 3 00 p m l St Thomas VI 00802 S7l2 l NOTE This subpoena places you on notice of an investigation by the Virgin Islands Department of Justice You must maintain, and may not destroy, any documents, electronic records, video or other material ‘ relating to Jeffrey Epstein l Failure to produce “1: documents requested may cause the Attnmey General to petition the Superior Court to compel you to produce the documents requested 1nd to the itsuance Ufa warrant for yam an est, under Titlel4 V l C § 6120:) \ K DA [ED this 11‘" day offline 2020 rie Sml , quile Chief of the ivil Divisiun VI Department of Justice Olfice 0f [ht Attorney General 3438 Kronprindsens Cutie G E R S Complex 2nd Floor St Thomas V100802 (340) 774 5666 Ext [0155 RETURN OF SERVICE Received by Server on Place Served on (Name) Date Al Sctvetl by Title DECLARATIOB OF SERVER I DECLARE UNDEP PENALTY OF PERJURY UNDER THE LAWS OF THE Untled Suites cfAInerica 1nd “16 Territory ofthe [lulled “was Virgin Island: that the foregoing information contained in the Relum of SeiViccs Statement is true and correct Executed on By y l N l EXHIBIT J I \ 1 1 i i i —— From david cattie@cattie law com Sent Wednesday June 17 2020 2 00 PM To Singer Linda C: Ariel Smith Scott Carmen Carol Jacobs SubJECl RE EXTERNAL RE f/u on our conversation this week Attachments 2020 06 11 Subpoena Duces Tatum to Ghislaine Maxwell pdf Good day Please note that I have previously advised you that I am not authorized to accept service on behalf ost Maxwell Today lwhile l was actually on a Zoom call with Attorney Smith) the Attorney Generals Office attempted to complete service of a CICO Subpoena (attachedl through me I advised the office that I was not authorized to accept service on her behalf Also please note that while the subpoena demands documents attached as Exhibit 'A there is no such exhibit attached thereto David Cattle David] Cane, Esq i Attorney at Counselor u Law l The Cattie Law Firm, P C l tel 34,0 775 1200/ fax 800 878 5237 is mail dzvid muegrocme law com lweb gww cattle law mm laddress mo Kongens Gade, St Thomas V I 00802 a 1 i EXHIBIT K 1 i 1 I i Case 1 17 CV 00616 JGK SN Document 97 Filed 01/05/18 Page 1 of 8 l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK i JANE DOE 43 Plaintiff No 17 Civ 00616 (16K) ‘ JEFFREY EPSTEIN GHISLAINE MAXWELL SARAH KELLEN LESLEY GROFF and ‘ NATALYA MALYSHEV Defendanm i i PLAINTIFF S RENEWED MOTION TO APPROVE ALTERNATE SERVICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE £116!le 1 Plaintiff, Sarah Ransornel by and through her undersigned counsel and pursuant to i Federal Rule of Civil Procedure 4(e)(l) and the New York Civil Practice Law and Rules Section 1‘ 308(5) files this Renewed Motion to Approve Alternative Service and for grounds thereof states As this Court is aware, Defendant Maxwell is also a defendant in another action in the 1 Southern District ofNew York Gut/fie v Maxwell Case No 15 cv 07433 RWS In that action, Maxwell is represented by counsel who appeared before that Court on her behalf as recently as ‘ November 8, 2017 Despite that fact, Maxwell will apparently not authorize her counsel to accept service of the complaint in this case Indeed, Maxwell‘s counsel has gone so far as to hire ‘ their own separate legal counsel to argue to this Court that they should not have to accept service i in this case Yet in this very case, Maxwell has already actively participated, Including havmg i counsel make a request for additional time to serve her answer and attempting to impose ‘ gPlatintiffhas decided to reveal her identity in connection with this matter and has filed aNotice to Change Case ap Km 1 l l Case 1 17 ev 00616 JGK SN Document 97 Filed 01/05/18 Page 2 of 8 restrrelrons on the L850 ofdiscovery materials Sac DE 69 and November 23, 2017 Letter to Judge Koeltl Exhibit D While this Lourt originally granted Plaintiff Ms Ransonre s Motion for Alternate Service (DE 57) Maxwell s counsel sought reconsideration ofthat Order on October 30, 2017 This Court held a hearing on November 28, 2017 and issued an Order on November 30, 2017 instructing Ms Ransome to again attempt service on Defendant Maxwell on or before January 5, 2018 By that date the plaintiffwill file either proofofservicc or a renewed application to the alternate service DE 90 As directed, Ms Ransome has made the following attempts to effectuate sen ice on Maxwell . Ms Rarrsorne provided Maxwell 5 counsel ofreeord in the Girl/fit \ Mann]! case a copy ofthe summons and complaint; - Ms Ransom: emailed a copy ofthe summons and complaint to the following email address which is publicly associated with Maxwell, gmax a)ellmax com See McCawley Decl at Exhibit 1 Deeember4 2017 E mail 0 Ms Ransome retained, at significant expense, a private investigation frnn to attempt to effectuate service at locations associated with Maxwell in New York and New lerscy including the following addresses 1 116 E 65th Street New York NY 10065 2 457 Madison Atenue 4th Floor New York NY 10022 and 3 35 Monterey Avenue, Teaneck, NJ 07666 As detailed in the affidavit of Investigator Douglas Mercer (Sec McCawley Decl at Exhibit 2), at one location, it was clear that individuals were present in the home but were refusing to answer the door and accept scrvree - Ms Ransomc conducted a public record search ofthe London Townhome that was identified in Epstein 5 Phone Directory as being associated with Detendant Maxwell 44 Kinnerton Street, London The UK government record request demonstrates that title to the property was changed on March 17 2016 to Eaton Square Properties Limited and is no longer owned by Defendant Maxwell rendering attempts at service in London futile Sec MeCawley Decl at Exhibit 3 Summary ofTitle NGL948023 and 2 Case 1 17 cv 00616 JGK SN Document 97 Filed 01/05/18 Page 3 of 8 0 Defendant Ghislaine Maxwell is also identified as the founder ofthe TerraMar Project on its website The organization has a New York address for its headquaners at 326 E 65‘h Sheet #326 New York New York 10065 The email address identified with the organization is hello a)Lheterrama1;gro eet org On January 4, 2018, we sewed a copy of the summons and complaint to the following potential email addresses 1 gmaxwell a>theterramamro ect org, 2 maxwellg wtheterramggro eet org; 3 ghislainegaltheterramamro]ect org, 4 gmax wthetenamarpro ect org; 5 maxwell wtheterramamro ect org; and 6 ghislaine maxwell @theterramagzro ect org See McCawley Decl at Exhibit 4 The only email addiess which received a delivery failure message was maxwell a)theteirama_1r_oro ect org Accoidingly, having made renewed and unsuccesstul efforts to serve Maxwell through conventional means, Ms Ransome now renews hei request for altemative service as such means as the Court may find appropriate Ms Ransome iespectfully suggests that, as the Court allowed in its previous order, that seniee ofthe complaints on current legal counsel representing her in a related matter before this Court and othei publicly identified email accounts be permitted as a means of alternative service MEMORANDUM OF LAW Sen/ice of a Complaint should not be a game of cat and mouse particularly where the defendant is represented by counsel in a mattei pending in the same district See Carillo v Hageny No 3 05CV1417 (MRK) 2006 WL 2165679 at *1 (D Conn July 31 2006) (court 3 Case 1 17 CV 00616 JGK SN Document 97 Filed 01/05/18 Page 4 of 8 finding defendant should not benefit from service gamesrnanship reasoning that ”service of process is not intended to be a game ofhide and seek or cat and mouse ") Based on the exhaustion of the other methods of service delineated above Ms Ransome moves, pursuant to Federal Rule of Civil Procedure 4(e)(1), for an order permitting serv1ce by an alternative method Federal Rule ofCivil Procedure 4(e)(1) provides that service upon a party may be effected by “following state law for serving a summons in an action brought in courts of generaljurisdiction in the state Where the district court is located or where service is made Accordingly Defendant Maxwell may be served pursuant to CPLR § 308, which provides several methods by which service upon a natural person may be effectuated, including personal service, service by ‘delivering the summons to a person of suitable age and discretion at the actual place of business dwelling place or usual place ofabode ofthe person to be served and then mailing the summons to the individual’s “last know residence,” or service by “affixing the summons to the door of either the actual place of business, dwelling place or usual place of abode within the state ofthe person to be served” and then “mailing the summons to such person at his or her last known residence” or to his or her place of business so called “nail and mail" service CPLR §§ 308(1) (2) & (4) If service under CPLR §§ 308(1) (2) & (4) is impracticable CPLR § 308(5) permits service “in such manner as the court, upon motion without notice directs ” The determination of whether service is impracticable ‘ depends upon the facts and circumstances of a particular case ” Sawmills & Exch Comm n v HG] Inc No 99 Civ 3866 (DLC) 1999 WL 1021087 at *1 (S D N Y Nov 8 1999) Although the plaintiff must Show impracticability of service there is no requirement of “proof of due diligence or of actual prior attempts to serve a party under the other provisions of the statute " Id “When usual methods of service prove impracticable, service 4 1 Case 1 17 cv 00616 JGK SN Document 97 Filed 01/05/18 Page 5 of 8 that is reasonably calculated, under all the circumstances, to apprise the interested party ofthe pendency ofthe action will suffice D R I Inc v Dennis No 03 Civ 10026 (PKL) 2004 WL i 1237511 at‘1(SDNY June3 2004) % New York Courts consistently affirm their right to direct or approve alternative methods 1 of service where regular service has been deemed “impracticable ” For example, in Dobkm v i Chapman 21 N Y 2d 490 498 289 N Y S 2d 161 168 (1968) the New York Court oprpeals ‘ held that where a plaintiffcould not follow the prescribed methods of service as set forth in § l 308, Courts are “given the discretion to fashion other means adapted to the particular facts of the ‘ case before it pursuant to § 308(5) (referred to in Dob/mt as § 308(4) the predecessor to § i 308(5)) Moreover, the Court of Appeals held that a Court's discretion to fashion such methods of service must be broad ifthe statute is to be meaningful 1d at 499 289 N Y S 2d at 168 i There is no doubt that Defendant Maxwell has had actual notice and knowledge of the ‘ claims asserted in this Complaint Ms Ransome has tried multiple alternative avenues to serve Maxwell including (1) sending the documents to her current counsel in another matter, (2) i investigating and attempting service at multiple locations known to be associated With Defendant ‘ Maxwell, and (3) emailing the documents to Defendant Maxwell 5 publicly available email ‘ address As a result, this Court should deem the service methods attempted to be sufficient and 1 grant the Motion for Alternate Service See Ramperrad v Deidre/re Bank Secs Inc , No 02 Civ 7311 (LTS) 2003 WL21073951 at *1 (S D N Y May 9 2003) (authorizing altemative service i under § 308(5) when Plaintiffwas unable to determine Defendant's residence or place of i business afier “extensive Intemet searches” and inquires with Defendant's former clients), Javter ‘ H v Garcia Batello 217 F R D 308 309 (W D N Y 2003) (service by publication authorized when indiVidual Defendant was a fugitive from the criminal justice system; was likely aware of j 5 l Case 1 17 cv 00616 JGK SN Document 97 Filed 01/05/18 Page 6 of 8 the pending civil action through his relatives who were co Defendants and when the Court determined that Defendant would likely read a newspaper that was circulated in the region of his last known residence) see also HG] [no 1999 WL 1021087, at *1 (service by publication in USA Today authorized when Defendant's whereabouts were unknown eflorts to locate his home or business address by searching computer databases failed, and there existed no record that he designated an agent for service) D R I Inc 2004 WL 123751] at *2 (after Plaintiff unsuccessfully attempted to serve Defendant through a process server and searched databases for his address, Court authorized service by sending process by certified mail to Defendant‘s last known address by publishing the action in a local newspaper and by emailing it to Plaintiffs last known email address) WHEREFORE Plaintiff prays for this Court to enter an Order granting Plaintiff‘s Motion to Approve Alternative Servrce Pursuant to Federal Rule of Civil Procedure 4(e)(l) and New York Civil Practice Law and Rules Section 308(5) upon Defendant Ghislaine Maxwell and finding that the service efforts made by Plaintiff’ s counsel herein are sufficient Dated January 5 2018 Respectfully submitted BOIES SCHILLER FLEXNER LLP /s/Sigrid McCawlgy Sigrid S McCawley (Admitted Pro Han Vice) Meredith Schultz (Admitted Pro Hue Vice) Boies Schiller Flexner LLP 401 E Las Olas Blvd Suite 1200 Ft Lauderdale FL 33301 Tel (954) 356 0011 Bradley J Edwards Esq Stanley Pottinger Esq 425 North Andrews Avenue Suite 2 Fort Lauderdale Florida 33301 Tel (954) 524 2820 Fax (954) 524 2822 6 Case 1 17 cv 00616 JGK SN Document 97 Filed 01/05/18 Page 7 of 8 Paul G Cassell (Admitted Pro Hue VICE) S J Quinney College of Law University of Utah 383 University St Salt Lake City UT 84112 (801) 585 52022 i i i i i i i i i 2 This daytime business address is provided for identification and correspondence purposes only and IS not i intended to imply institutional endorsement by the University of Utah for this private representation 7 Case 1 17 av 00616 JGK SN Document 97 Filed 01/05/18 Page 8 of 8 CERTIFICATE OF SERVICE I HEREI“ CERTIFY that on the 5th day ofJanuary 2018 1 electronically filed the folegoing document with the Clerk of Coutt by using the CM/ECF system I also Lemfy that the foregoing document is being sewed to all parties of tecotd via transmission ofthe Electionie Court Filing System genetated by CM/ECF Kimo S Peluso Alexandei S LOienzo Shel T1 emonte LLP ALSTON & BIRD LLP 90Broad Stteet, 23rd F1001 90 Park Avenue New Ymk NY 10004 New York NY 10016 kgelusogwshenremonte com alexander lotenzo ®alston com Cozumel/0r Huddurt Mulgan & Forcing)? Cozumel/rm DLfendzznt Sam/1 Kellen P C Michael Millet Laura A Menninger, Esq Justin Y K Chu Ieffrey Pagliuca Esq Michael A Keough HADDON MORGAN & FOREMAN P C STEPTOE & JOHNSON LLP 150 East 10th Avenue 1 1 14 Avenue ofthe Americas Denvex Colomdo 80203 New York NY 10036 Email lmenningergzfihmflaw com mmillet' a)stegtoe com paghucauflhmflaw com "Chu wsteptoe com Conan/f0; Defendmm JLfflrLy Epstem and John E Stephenson, l1 Lat/Ly GI 01/ Jonathan D Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta GA 30309 John Stephenson (Dalston com Jonathan Qarente dialston com A? Sigrid McCaM [at Sigrid McCawley 8 1 i J i EXHIBIT L I I 1 1 Ransome v Epstein Not Reported in Fed Supp (2018) 2018 WL 637421 the Court may applets alteiuative service methods 53 2018 WL 637421 erg .mlsersad v Deutsche bank Sec inc No 02 Only the Westlaw cit ltion is currently available cv 73lltLTS)(AJP) 2002 WI utmost at ‘1 (S D iv Y Unrtcd States Distttct Court, 3 D New York May 9 2003) Service under§ 303(5) requires a shoving or impiacticabiiity at the other methods ofservice but does not 5m“ RANSUMEr Plaintiff: require a showing ofdue diligence m \ Jeffrey EPSTEIN etal , Defendants The plaintiff has tahen various steps in an effort to serve hiaxuell personally all to rto avail The plairitrffrelained ‘7 C” 616 (JGK) a piivate investigation firm to atteirlpt to determine where l Maxueil resides, and that firm attemptLd sorticc at three Sign“ 01/30/2018 physical addresses potentially associated with Maxwell The “(new and I m “m“ plaintirralso emailed the surumons and complaint to several email addresses that are publicly associated with Maxwell Justin YK Chu Michael Campion Miller Steptoe & only one ni'vvhreh has been reunited as undelivered The Johnson LLP AlexanderstionLoreuzo Alston&Biid LLP plaintiff has also Provided a copy of the summuns and New York, Np LaumA Manning” Haddon, Morgan and complaint to Haddou Viorgan who currently represents boreman P( Denver CO JohnE Stephenson Jr Alston Maxwellin another litigation pending in this diflriu at Bird LLP Atlanta (1A tor Defendants Under these circumstances the plaintiff has demonstrated impracticabilrty because she has made numerous efforts to MEMORANDUM OPINION AND ORDER obtain information about the defendants cuircnt residence and general contact information to efiectuate peisonal service m“ G “an ”we“ 5”“ mm“ “We": but has been ititable to locate Maxwell See e g "s E C a (7Hwy ‘0 ”WWW a"“"“"“ “m” ‘3" "‘° d°f°“d"‘"‘ G"‘5'ai"e Court finds that the plaintiff has demonstrated that service A”??? ““‘ftsihgnje‘sha: if“ ‘1‘“ m“ 32:“? J“ on Ma‘OVe" is impracticable and thus grants the tttotion tor paint asse pie rrgerr measures s e as een unable to serve Maxwell personally Thc plaintiff argues “mauve “me however that site has taken reasonable measures to provide ‘2 Further ma steps already lake“ by me plaintif‘rto serve WWW” WM“ ”we “”19 “mm“ ”“5“" a“ ”We“ ‘1‘“ htaxuell are reasorrabl calculated under tlrecircunrstartces his service should be deemed sufficient Non party Haddon y ‘ Morgan & Foreman PC t Haddnn Morgan l Maarvell s to “ppm ”7'10”” pendency “We a?“ “Tm ”Mme" counsel in anoilierlmgatioir pending in this Court has refused 3" °Ppmu"“y w New“ [Mr “new“; “d the com therefore deems servtce ofthc summons and complaint to be to accept service on behalror Maxwell and has objected to ample” as ‘0 defend“ Maxwell Ste E 7 Bow V Love becomrng a general agent of process for Maxuell but has ND is CV 3271mm) 2015 WL 494039849 m 31(an Y taken imposition entireplaintiffsapplicationtodeemservice My 1 2015) (holding the“ service “PM “I: defendants effected through the email cflorts that the plailttiffhas already . tnade Neither Maxwell nor any representative of Maxwell counsel in an unrelated mailer was sufficient)» mm has olllemise opposed the current niotiou 2003 WL 2107395 I r at *1 Federal Rule of Civil Procedure Melt l) pennrts a plaintrff Finally Haddon Morgan 5 chicane" to becoming a general to serve a defendant by following the procedures set tortlt agent of News for Maxwell is unfounded The Court’s by state law in the state where the district court is located ruling that service by email and Pelsonal delivery ‘0 Halide" New york my“ practice Law and was Section 303 sets Morgan has been reasonably calculated to provide Maxwell forth available iiieihods of servrce where service under Viithlwticenfthisminim“ allopponuniwlorespond does §§ 303”)» (I) or (attiwmch genera"y Provide variants of not turn Haddon Morgan iilto a general agent for Maxwell Imm“. swing is impmcficable § 3035) provides that Indeed this order does notevcu require Haddon Morgan Io WESTLAW Ransome v Epstein Not Reported in Fed Supp (201 s) 2018 WL 637421 new“ service on behalf of Maxwell, bin rather find: that or answer is iii/em) one (in): from ihe date of [his ordei service on Hadrian Mom" is likely to provide malice oflhe ”Mame” “"0”” "m ‘0 we“ U” 91""“m may ””5“ mm to Maxwell given [liailladdon Moigan is presumany “a“? ”memes ”’3 “mm "‘°'“d““=’ "‘9 “my Of a in comm! with Maxwell with regards to men representalion defa"'”“dg"‘°"' of her in thc other pending maner See Bozza, 2015 WL 9‘ 4039849 in 2 so ORDERED Accordingly me mmion for ahemaiive service is granted All (muons The Clerk ofCoun is dimmed to close the mciion pending m Decker Number 97 Defendant Maxneils lime to move NutRCPonedm Fed S“PP 2018 WL {“7421 Footno‘es 1 The Chem of Court is direcied to amend the case caption in name Sarah Ransome as the plaintiff See Docket No 96 End orDocumcm a i\, ‘i')i)1HN UH no i um amid J» Harman an“ WESTLAW