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EFTA02731082

EXTREME CRITICALprosecution memo

SDNY Co-Conspirator Prosecution Memo — Investigation into Potential Co-Conspirators of Jeffrey Epstein

Dataset
Dataset 12: Leon Black Prosecution File
Type
PROSECUTION MEMO
Date
December 19, 2019
Pages
86
Classification
HIGH
File Size
—

Summary

Sealed Grand Jury 6(e) prosecution memo from SDNY AUSAs to U.S. Attorney Geoffrey Berman. Evaluates charging Epstein co-conspirators after his death. Documents 24 minor victims (ages 13-17), 14 adult victims, 3 subject interviews, 4 non-victim witnesses — all interviewed Jul-Dec 2019. Key findings: (1) Staley raped victim during directed massage at Epstein's NYC residence ~2011-2012, corroborated by JPMorgan-produced messages (p32, fn61 p67); (2) Black sexually assaulted victim in separate incident (p32); (3) Weinstein attempted assault during directed massage at Paris residence (p14); (4) Maxwell directed victim to have sex with Prince Andrew and Glen Dubin (p57); (5) Clinton traveled on Epstein's jet to Africa with Maxwell and 4 young women (pp28,37); (6) Epstein stole 'several hundred million dollars' from Wexner — explaining 'virtually all of Epstein's wealth' (pp64-65); (7) Groff scheduled NYC massages 2001-2019, invoked Fifth Amendment; (8) Indyke told assistant not to talk to police (p41); (9) Epstein directed destruction of computers and contact directories during FL investigation (pp40-41). Charging analysis (pp68-85) is 95-98% redacted — institutional decisions completely hidden while victim trauma fully exposed. Memo recommends Maxwell charges (fn62 p72). Evaluates 5 subjects: 3 redacted + Groff + Maxwell. Original SDNY bates range: EFTA00022461-EFTA00022546.

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Linked Entities12

NameTierRole
Jes StaleyT1subject
Leon BlackT1mentioned
Jeffrey EpsteinT1mentioned
Ghislaine MaxwellT1subject
Jean-Luc BrunelT1mentioned
Prince AndrewT1mentioned
Alan DershowitzT1mentioned
Bill ClintonT1mentioned
Harvey WeinsteinT1mentioned
Lesley GroffT2subject
Les WexnerT4mentioned
Glenn DubinT1mentioned

Cited In Stories43

[6]
The Golden Handcuffs

Prosecution memo — Indyke told assistant not to talk to police

p. p. 41
[7]
The Golden Handcuffs

$250,000 payment to assistant days after Miami Herald series

p. pp. 51-52
[8]
The Golden Handcuffs

Evidence destruction — computers and contact directories

p. pp. 40-41
[9]
The Golden Handcuffs

Alessi departure warning: "keep your mouth shut"

p. p. 37
[10]
The Golden Handcuffs

Attorney coercion of minor victim — child custody threat

p. p. 18
[15]
The Golden Handcuffs

$100K wire to associate after negative articles

p. p. 52
[16]
The Golden Handcuffs

Scheduling directory destroyed, never recovered (footnote 47)

p. p. 49
[1]
The Case That Wasn’t

Prosecution memo — 38 victims, 5 subjects analyzed, only Maxwell charged

p. Full document
[2]
The Case That Wasn’t

Staley raped victim during directed massage; JPMorgan corroboration

p. pp. 32, 58, 67
[3]
The Case That Wasn’t

Leon Black sexually assaulted victim during directed massage

p. pp. 22, 32, 55, 58
[4]
The Case That Wasn’t

Maxwell directed victim to sex acts with Glenn Dubin

p. p. 57
[5]
The Case That Wasn’t

Charging analysis (Section IV, pp. 74-85) — 98% redacted

p. pp. 74-85
[6]
The Case That Wasn’t

Footnote 62 — anticipated recommending charges against Maxwell

p. p. 85
[5]
The Heirs With the Most to Hide

Prosecution memo — Maxwell directed victim to sex acts with Glenn Dubin

p. p. 57
[6]
The Heirs With the Most to Hide

Prosecution memo — Eva Dubin present during directed massage

p. p. 57
[10]
The Heirs With the Most to Hide

Prosecution memo — Epstein wealth "virtually all" derived from Wexner misappropriation

p. pp. 64-65
[8]
The Trustee With No Exit

Prosecution memo — rape allegation: Staley forced victim during directed massage

p. p. 32
[10]
The Trustee With No Exit

JPMorgan corroboration — messages between Staley and Epstein around period of assault

p. fn. 61, p. 67
[14]
The Trustee With No Exit

Charging analysis — 5 subjects evaluated, Staley not among them

p. pp. 74-85
[9]
The Man Who Held Every Key

Prosecution memo — Kahn wired $250K to assistant after Miami Herald

p. pp. 51-52
[10]
The Man Who Held Every Key

Prosecution memo — Indyke told assistant not to talk to police

p. p. 41
[12]
The Man Who Held Every Key

Prosecution memo — charging analysis entirely redacted (pp. 74-85)

p. pp. 74-85
[2]
The System

Prosecution memo — Staley rape during directed massage, JPMorgan corroboration

p. pp. 32, 67
[4]
The System

Prosecution memo — Maxwell directed victim to sex acts with Glenn Dubin

p. p. 57
[7]
The System

Prosecution memo — Indyke told assistant not to talk to police

p. p. 41
[8]
The System

Prosecution memo — 38 victims, 5 subjects analyzed, charging analysis 98% redacted

p. pp. 74-85
[1]
The Scheduler

SDNY prosecution memo — Groff's operational role: scheduling massages, booking interstate flights for victims

p. p. 63
[4]
The Scheduler

Prosecution memo — Epstein directed Groff to buy Victoria's Secret underwear for victim

p. p. 26
[5]
The Scheduler

Prosecution memo — victim recalls Groff "right outside the closed door" during forced oral sex

p. p. 28
[6]
The Scheduler

Prosecution memo — Groff trained other schedulers, served as direct supervisor

p. p. 41
[16]
The Scheduler

Prosecution memo — prosecutors warned no agreement without proffer, Fifth Amendment invoked

p. pp. 63-64
[18]
The Scheduler

Prosecution memo — Section D (Groff charging analysis) entirely redacted, Category C protection

p. pp. 75-85
[8]
The Recruitment Trip

SDNY prosecution memo — modeling agency recruitment pattern documented across multiple victims

p. pp. 28, 37
[1]
The Washington List

SDNY prosecution memo — references Giuffre victim journals with forensic authentication (gel pen analysis, contemporaneous dating), lists journal-named individuals

p. Evidence inventory section
[2]
The Washington List

SDNY prosecution memo — Epstein contact directory ("black book") with 1,571 names, multiple entries for D.C.-area figures

p. Evidence inventory section
[3]
The Washington List

SDNY prosecution memo — documents 24 minor victims and 14 adult victims, journal evidence cross-referenced with flight logs and contact records

p. Victim accounts section
[4]
The Washington List

SDNY prosecution memo — Epstein's institutional relationships including Harvard donations during Summers' presidency and MIT connections

p. Network analysis section
[5]
The Washington List

SDNY prosecution memo — Jean-Luc Brunel's MC2 modeling agency as international recruitment arm

p. Co-conspirator analysis
[6]
The Washington List

SDNY prosecution memo — references 2007 NPA blanket immunity provision covering unnamed "potential co-conspirators"

p. Legal framework section
[7]
The Washington List

SDNY prosecution memo — Dershowitz role as Epstein defense attorney who negotiated NPA immunity, later named by Giuffre

p. NPA analysis section
[8]
The Washington List

SDNY prosecution memo — no charges filed against journal-named individuals, investigation scope limited to Maxwell and select co-conspirators

p. Charging recommendations
[9]
The Washington List

Public reporting — Dan Snyder sold Washington Commanders July 2023 for $6.05 billion amid separate House Oversight investigation

p. Public record
[10]
The Washington List

SDNY prosecution memo — Section D (Groff/co-conspirator charging analysis) entirely redacted under Category C institutional protection

p. Section D

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