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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 Entities15

NameTierRole
Jes StaleyT1subject
Leon BlackT1mentioned
Jeffrey EpsteinT1mentioned
Ghislaine MaxwellT1subject
Jean-Luc BrunelT1mentioned
Prince AndrewT1mentioned
Alan DershowitzT1mentioned
Bill ClintonT1mentioned
Harvey WeinsteinT1mentioned
Lesley GroffT2subject
Les WexnerT3mentioned
Glenn DubinT1mentioned
Eva Andersson-DubinT4mentioned
Apollo Global Management LLCT4mentioned
Sultan Ahmed bin SulayemT4mentioned

Extracted Images87

Cited In Stories52

[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
[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
[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
[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
[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
[8]
The Recruitment Trip

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

p. pp. 28, 37
[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
[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
[1]
The Source of All His Wealth

SDNY prosecution memo — Wexner attorney proffer summary: Epstein controlled all Wexner personal finances with "virtually no oversight." Fees and misconduct "appears to account for virtually all of Epstein's wealth." Townhouse and plane sold at "deeply discounted price."

p. pp. 64-65
[5]
The Source of All His Wealth

SDNY prosecution memo — describes 9 East 71st Street mansion as primary abuse site. Search warrant executed July 6, 2019; photographs of victims found. Maxwell coordinated logistics from this address.

p. pp. 3-8
[2]
The Washington List

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

p. Evidence inventory section
[15]
The Washington List

SDNY prosecution memo — Harvard donations during Larry Summers' presidency and MIT connections (Marvin Minsky) as institutional access points.

p. Network analysis section
[16]
The Washington List

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

p. Co-conspirator analysis
[17]
The Washington List

SDNY prosecution memo — 2007 NPA blanket immunity provision covering unnamed "potential co-conspirators," negotiated by Epstein's defense team.

p. Legal framework section
[18]
The Washington List

SDNY prosecution memo — Dershowitz role as Epstein defense attorney who negotiated NPA, later named as having sexually abused victims.

p. NPA analysis section
[19]
The Washington List

SDNY prosecution memo — no charges filed against journal-named individuals, no law enforcement interviews of D.C. cluster members.

p. Charging recommendations
[20]
The Washington List

SDNY prosecution memo — Section D (charging analysis) entirely redacted under Category C institutional protection. The section that would have addressed these names remains sealed.

p. Section D
[10]
The Governor's Ranch

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

p. Legal framework section
[13]
The Four Names

SDNY prosecution memo — Maxwell conviction December 2021; sex trafficking, conspiracy, transporting minor; 20-year sentence

p. Legal framework section
[7]
The Conveyor Belt

SDNY prosecution memo — victim visa sponsored by Brunel agency while not working; Epstein "paid Brunel $1 million to keep her in the country"; Brunel brought ~15-year-old to Virgin Islands

p. pp. 47-48
[12]
The Conveyor Belt

SDNY prosecution memo — Brunel attorney: "not willing to meet with us for a proffer and would invoke his Fifth Amendment privilege" (Aug-Sept 2019)

p. pp. 63-65
[3]
They Use It to Find Us

SDNY prosecution memo — AOL chat rooms documented as environment where adults routinely accessed minors in early 2000s. Child safety enforcement described as reactive.

p. Evidence context section
[10]
The Other Predator

SDNY prosecution memo — documents Epstein's employment contracts with "golden handcuffs" provisions: loyalty clauses threatening termination and financial forfeiture for cooperation with law enforcement.

p. Employment section
[12]
The Source of All His Wealth

2007 Non-Prosecution Agreement — blanket immunity provision for unnamed "potential co-conspirators." May extend to Wexner as an uncharged individual connected to Epstein's financial infrastructure.

p. NPA section
[12]
The Other Predator

Weinstein New York conviction, February 24, 2020 — criminal sexual act in the first degree and rape in the third degree. Sentenced to 23 years.

p. Public record
[13]
The Other Predator

New York Court of Appeals overturns Weinstein conviction, April 25, 2024 — ruling trial judge improperly allowed testimony about prior uncharged conduct. Retrial ordered.

p. Public record
[14]
The Other Predator

Weinstein Los Angeles conviction, December 19, 2022 — rape, forced oral copulation, sexual penetration by foreign object. Sentenced to 16 years consecutive to New York sentence.

p. Public record

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