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Page EFTA00014671
York, NY 10007 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca Denver. Colorado 80203 Re: Response t
Page: EFTA00014671 →Page EFTA00014672Same page
im Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Seven (7) photocopied pages of this journal, two of which are the front and back covers, were selectively produced by BSF in discovery during civil
Page: EFTA00014672 →vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac
Page: EFTA00014672 →cluding the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Sev
Page: EFTA00014672 →4 mentions1 same-page
Page ?Same page
Maxwell violated and conspired to violate the federal sex trafficking statute, 18 U.S.C. § 1591. Count Five alleges that Ms. Maxwell conspired with Epstein and others to recruit "a person" knowing that the person "had not attained the age of 18 years and would be caused to engage in a commercial sex act
by any means" individuals who were under the age of 18, including Accuser-4, "who were then caused to engage in at least one commercial sex act with Jeffrey Epstein." (Id. 127). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred "[f]rom at least in or about 2001,
A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents s
4 mentions1 same-page
Page ?Same page
f the media and claims to have looked at the journal to "refresh [her] memory about this time." See, e.g., Michael Baker, "The First Women to Report Jeffrey Epstein," The Daily Podcast, NY Times (Aug. 26, 2019), Tr. at 2 ("When I was looking, trying to refresh my memory about this time, I came across this journa
vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac
York, NY 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado
cluding the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Sev
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4 mentions1 same-page
Page ?Same page
Maxwell violated and conspired to violate the federal sex trafficking statute, 18 U.S.C. § 1591. Count Five alleges that Ms. Maxwell conspired with Epstein and others to recruit "a person" knowing that the person "had not attained the age of 18 years and would be caused to engage in a commercial sex act
by any means" individuals who were under the age of 18, including Accuser-4, "who were then caused to engage in at least one commercial sex act with Jeffrey Epstein." (Id. 127). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred "[f]rom at least in or about 2001,
A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents s
2 mentions1 same-page
Page EFTA00010157Same page
el filed seeking to subpoena information from the Epstein Victim Compensation Fund, including information
Page: EFTA00010157 →identiality. On Nov 15, 2021, at 9:29 PM, wrote: Jack, Attached is a motion that Maxwell's has counsel filed seeking to subpoena information from the Epstein Victim Compensation Fund, including information about . We intend to file a motion to quash the subpoena later this week. Happy to have a call if you would like to discuss
Page: EFTA00010157 →2 mentions1 same-page
Page EFTA00010240Same page
el filed seeking to subpoena information from the Epstein Victim Compensation Fund, including information
Page: EFTA00010240 →identiality. On Nov 15, 2021, at 9:29 PM, Jack, wrote: Attached is a motion that Maxwell's has counsel filed seeking to subpoena information from the Epstein Victim Compensation Fund, including information aboune intend to file a motion to quash the subpoena later this week. Happy to have a call if you would like to discuss or h
Page: EFTA00010240 →Sponsored
2 mentions1 same-page
Page EFTA00018192Same page
el filed seeking to subpoena information from the Epstein Victim Compensation Fund, including information
Page: EFTA00018192 →ola.pdf; 2021.11.14_Ex._l_Redacted_for_Scarola.pdf Jack, Attached is a motion that Maxwell's has counsel filed seeking to subpoena information from the Epstein Victim Compensation Fund, including information about' We intend to file a motion to quash the subpoena later this week. Happy to have a call if you would like to discuss o
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Page EFTA00029598Same page
ate: Sat, 04 Sep 2021 01:40:44 +0000 Hey Guys, Per the below FBI reached out to us about a threat being made by a woman who was denied status as an Epstein victim to the woman who oversees the victim compensation fund. We're going to handle in the normal fashion (threat assessment, locate the target, d
Page: EFTA00029598 →iPhone Begin forwarded message: Front: Subject: Re: Availability tomorrow? Sorry for the delay. is our victim and oversees the applications for the Epstein Victim Compensation Fund. is The individual who has been making threats is Allison Huxtable. Thank IM Special Agent FBI I New York Office Violent Crimes Task Force EFT
Page: EFTA00029598 →Sponsored
Mutual Connections (31)
Entities connected to both Jeffrey Epstein and the Epstein Victim Compensation Fund
DI
Darren Indyke
PERSON17,179 w/ Jeffrey·2 w/ the
Prince Andrew
PERSON9,960 w/ Jeffrey·4 w/ the
Ghislaine Maxwell
PERSON8,987 w/ Jeffrey·7 w/ the
Michael Cohen
PERSON3,053 w/ Jeffrey·2 w/ the
JS
Jack Scarola
PERSON1,013 w/ Jeffrey·3 w/ the
David Boies
PERSON978 w/ Jeffrey·2 w/ the
Denver
LOCATION878 w/ Jeffrey·2 w/ the
Colorado
LOCATION805 w/ Jeffrey·2 w/ the
JP
Jeffrey Pagliuca
PERSON577 w/ Jeffrey·4 w/ the
Alaska
LOCATION441 w/ Jeffrey·2 w/ the
Kentucky
LOCATION269 w/ Jeffrey·2 w/ the
Cohen & Gresser LLP
ORGANIZATION234 w/ Jeffrey·2 w/ the
Cynthia Nixon
PERSON222 w/ Jeffrey·2 w/ the
Brady
PERSON181 w/ Jeffrey·4 w/ the
BS
Bobbi C. Sternheim
PERSON168 w/ Jeffrey·2 w/ the
MORGAN & FOREMAN
ORGANIZATION61 w/ Jeffrey·2 w/ the
Michael Barker
PERSON55 w/ Jeffrey·2 w/ the
Bagley
PERSON25 w/ Jeffrey·2 w/ the
the Epstein Estate
ORGANIZATION24 w/ Jeffrey·2 w/ the
Accusers
ORGANIZATION17 w/ Jeffrey·2 w/ the