Epstein Secrets

vely "Radar Online") seeks records at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current prosecution of Ghisaille Maxwell. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions. To make sure this

District of New York and one of the lead prosecutors in this matter. )ecl. ¶¶ 1, 9-10, 13-32. The withheld records include possible exhibits at the Maxwell trial, information about which numerous witnesses are expected to testify, and information and documents authored by potential trial witnesses. See

d interfere with the pending prosecution against Ghislaine Maxwell, as logically and plausibly explained in

The withheld records include possible exhibits at the Maxwell trial, information about which numerous witnesse

pending or reasonably foreseeable at the time of the withholding. See,e.g., Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the government need only show that

739110438 and 739470663, which are related to Jeffrey Epstein, and for account numbers 739116312, 3149920008, and 2916490721, which are related to Ghislaine Maxwell. To the extent that we identify any other JPMorgan accounts in the name of Mr. Epstein, Ms. Maxwell, or Ms. we will produce those in a separate pr

and 2916490721, which are related to Ghislaine Maxwell. To the extent that we identify any other JPMorgan accounts in the name of Mr. Epstein, Ms. Maxwell, or Ms. we will produce those in a separate production. In addition, enclosed at JPM-SDNY-00000009 through JPM-SDNY-00000011 are Excel files refl

3149920008, and 2916490721, which are related to Ghislaine Maxwell. To the extent that we identify any other

er JPMorgan accounts in the name of Mr. Epstein, Ms. Maxwell, or Ms. we will produce those in a separate pro

ephone the undersigned rather than rely upon the United States mail for such notice. If the Department is not satisfied that the See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). 2 See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). 3 See, e.g., Chrysler Corp. v. Brown, 441

SDNY-00003382 through JPM-SDNY-00054724. Enclosed at JPM-SDNY-00003382 through JPM-SDNY-00054724 are account statements related to Jeffrey Epstein, Ghislaine Maxwell, and . For your convenience, Appendix A includes a chart identifying the account numbers, account names, and date ranges of account statements by B

ith the Firm, but Mr. Epstein does not necessarily have control of or access to those accounts. Certain accounts associated with Mr. Epstein and Ms. Maxwell overlap with accounts related to "JE DM," and are identified as such. As discussed, we anticipate making further productions on a rolling basis. P

2020 Page 8 Esq. Terra Mar Project, Inc. - Savings Account 4/30/2012 4/30/2014 JPM-SDNY-00045132 - JPM-SDNY-00045259 U 5. Maxwell Accounts Ghislaine Maxwell - OAP IHD, TAP DYS, TAP ARFI 1/31/2013 6/30/2014 JPM-SDNY-00045260 - JPM-SDNY-00046933 Ghislaine Maxwell - Asset Account Portfolio

Certain accounts associated with Mr. Epstein and Ms. Maxwell overlap with accounts related to "JE DM," and ar

tial Material; or (2) refer to any conference, meeting, telephone conversation, or interview between (a) our client's current or See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). 2 See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). 3 See, e.g., Chrysler Corp. v. Brown, 441

DNY-00054737 through JPM-SDNY-00055530. As you know, on November 15, 2019, we produced wire data for certain accounts related to Jeffrey Epstein or Ghislaine Maxwell (JPM-SDNY-00000004 through JPM-SDNY-00000011). We have since identified additional wire data for certain accounts related to Mr. Epstein, Ms. Maxwel

axwell (JPM-SDNY-00000004 through JPM-SDNY-00000011). We have since identified additional wire data for certain accounts related to Mr. Epstein, Ms. Maxwell, or Enclosed at JPM-SDNY-00054737 through JPM-SDNY-00054772 are Excel files reflecting the wire activity for account numbers related to Mr. Epstei

r certain accounts related to Jeffrey Epstein or Ghislaine Maxwell (JPM-SDNY-00000004 through JPM-SDNY-00000

data for certain accounts related to Mr. Epstein, Ms. Maxwell, or Enclosed at JPM-SDNY-00054737 through JPM-S

activities of JPMorgan, its employees, and its clients and their employees and agents, and not to the activities of any federal See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). Confidential Treatment Requested by JP Morgan Chase JPM-SDNY-CL-007-0002 EFTA00096343 WILMERHALE September 2, 2020 Page

ccount numbe in the name of Jeffrey Epstein (JPM-SDNY-00065494 -SDNY-00065499); and account documentation related to account number in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY- 00065518). Should you require any additional materials, please do not hesitate to contact us. * * * Pursuant

lated to account number in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY- 00065518).

ntation related to account number in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY- 0006

iates, representatives, agents, auditors, or counsel and (b) employees of the Department (or any other government agency). 2 3 See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). See, e.g., Chrysler Corp. v. Brown, 441 U.S.

e the charges against him were pending. OA (citing United States v. Epstein 19 Cr. 490 (RMB), Nolle Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was indicted by a grand jury in this District on "one count of conspiracy to entice minors to travel to engage

Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was

ntent to engage in criminal sexual activity"; "and two counts of perjury." (Third Comey Decl. (Dkt. No. 59) 1 6) On December 29, 2021, a jury found Maxwell guilty of enticing a minor to travel to engage in illegal sex acts, transporting minors with the intent to engage in criminal sexual activity, and

would result from disclosure, the FBI notes that "the Maxwell criminal prosecution is still pending on appeal,

r in the name of Jeffrey Epstein (JPM-SDNY-00065494 throw h JPM-SDNY-00065499); and account documentation related to account number in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY- 00065518). Should you require any additional materials, please do not hesitate to contact us. * * * Pursuant

lated to account number in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY- 00065518).

ntation related to account number in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY- 0006

iates, representatives, agents, auditors, or counsel and (b) employees of the Department (or any other government agency). 2 3 See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). See Dept ofJustice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). See, e.g., Chrysler Corp. v. Brown, 441 U.S. 2