Epstein Secrets

21.04.12 3501.097 Daniel Groff Date Desialptloa Attorney Produced to Defense 3501 097 0)1 2007.08.15 Law enforcement report rcsatclina Donp6 Groff WA 202: Ca :2 3501.098 Groff Date DienalPtlom Attorney ProducedtoDefense 3501.098 C01 2007.0815 Law enforcement report regarding Lesley Gr

np6 Groff WA 202: Ca :2 3501.098 Groff Date DienalPtlom Attorney ProducedtoDefense 3501.098 C01 2007.0815 Law enforcement report regarding Lesley Groff Michael Bachner 2021.04.12 3501098.002 2007.08.21 Letter regarding Interview of Wiley Groff 2021.111.12 3501098.003 2007.08.21 Lesley Groff

ch regarding Tony Figueroa 3501476014 2007.01.06 Research regarding Tony Figueroa 3501476015 2007.01.06 National comprehensive mpan resin:m.7am Figueroa 3501.076016 2007.01.10 Fns memorandum regarding intavieerof Tony Figueroa 3501.076017 2007.01.10 Tony Figueroa Miamian notes 1501.0760113 200

g in earnest to end this investigation. FBI New York agents are interviewing several girls identified by Jane Doe #11. At this time, we do not have Lesley Groff's phone records, so we do not have sufficient evidence to charge her. She is referred to by her initials in the indictment, and we will hopefully be

e would pay her to bring more girls. Jane Doe #11 implicates two other Epstein assistants — Lesley Groff and Cecilia Steen. We had anticipated that Groff would be a witness, not a target. When the agents went to Groff's house to interview her, she went upstairs, claiming she needed to change her baby

. D. M A. (Jane Doe #18) and H. (Jane Doe #19) Jane Doe #18 was recruited by her brother's friend, Tony (referred to in indictment as "A.F."). Figueroa also was the former boyfriend (Jane Doe #1). Figueroa recruited several girls to Epstein's home includin R. Jane Doe #18 attended R2 al Palm Beac

f Epstein, including but not limited to Lesley Groff, or NPA at 5; Def. Mot. 1 at 20-21. Aside from t

d States also agrees that it will not institute any criminal charges against any otential co-cons irators of Epstein, including but not limited to Lesley Groff, or NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defendant does not poin

39 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 2

d States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 8,20,27 United States v. Fennel!, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284,286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

39 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

39 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

tates v. Feldman, 939 F.3d 182 (2d Cir. 2019) 6, 18, 22 United States v. Fennell, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 192, 194 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 167 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 48 United States v. F

simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa, 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an

g in earnest to end this investigation. FBI New York agents are interviewing several girls identified by Jane Doe #11. At this time, we do not have Lesley Groff's phone records, so we do not have sufficient evidence to charge her. She is referred to by her initials in the indictment, and we will hopefully be

#11 that he would pay her to bring more girls. Jane Doe #11 implicates two other Epstein assistants — Lesley Groff and M. We had anticipated that Groff would be a witness, not a target. When the agents went to Groff's house to interview her, she went upstairs, claiming she needed to change her bab