EFTA02731082
EXTREME CRITICALprosecution memoSDNY 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.
Linked Entities15
| Name | Tier | Role |
|---|---|---|
| Jes Staley | T1 | subject |
| Leon Black | T1 | mentioned |
| Jeffrey Epstein | T1 | mentioned |
| Ghislaine Maxwell | T1 | subject |
| Jean-Luc Brunel | T1 | mentioned |
| Prince Andrew | T1 | mentioned |
| Alan Dershowitz | T1 | mentioned |
| Bill Clinton | T1 | mentioned |
| Harvey Weinstein | T1 | mentioned |
| Lesley Groff | T2 | subject |
| Les Wexner | T3 | mentioned |
| Glenn Dubin | T1 | mentioned |
| Eva Andersson-Dubin | T4 | mentioned |
| Apollo Global Management LLC | T4 | mentioned |
| Sultan Ahmed bin Sulayem | T4 | mentioned |
Extracted Images87
Cited In Stories52
Prosecution memo — Maxwell directed victim to sex acts with Glenn Dubin
p. p. 57Prosecution memo — Epstein wealth "virtually all" derived from Wexner misappropriation
p. pp. 64-65Prosecution memo — 38 victims, 5 subjects analyzed, only Maxwell charged
p. Full documentStaley raped victim during directed massage; JPMorgan corroboration
p. pp. 32, 58, 67Leon Black sexually assaulted victim during directed massage
p. pp. 22, 32, 55, 58Prosecution memo — Staley rape during directed massage, JPMorgan corroboration
p. pp. 32, 67Prosecution memo — 38 victims, 5 subjects analyzed, charging analysis 98% redacted
p. pp. 74-85Prosecution memo — rape allegation: Staley forced victim during directed massage
p. p. 32JPMorgan corroboration — messages between Staley and Epstein around period of assault
p. fn. 61, p. 67SDNY prosecution memo — modeling agency recruitment pattern documented across multiple victims
p. pp. 28, 37Prosecution memo — Kahn wired $250K to assistant after Miami Herald
p. pp. 51-52Prosecution memo — charging analysis entirely redacted (pp. 74-85)
p. pp. 74-85SDNY prosecution memo — Groff's operational role: scheduling massages, booking interstate flights for victims
p. p. 63Prosecution memo — Epstein directed Groff to buy Victoria's Secret underwear for victim
p. p. 26Prosecution memo — victim recalls Groff "right outside the closed door" during forced oral sex
p. p. 28Prosecution memo — prosecutors warned no agreement without proffer, Fifth Amendment invoked
p. pp. 63-64Prosecution memo — Section D (Groff charging analysis) entirely redacted, Category C protection
p. pp. 75-85SDNY 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. 64-65SDNY 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. 3-8SDNY 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 sectionSDNY prosecution memo — Harvard donations during Larry Summers' presidency and MIT connections (Marvin Minsky) as institutional access points.
p. Network analysis sectionSDNY prosecution memo — Jean-Luc Brunel's MC2 modeling agency as international recruitment pipeline.
p. Co-conspirator analysisSDNY prosecution memo — 2007 NPA blanket immunity provision covering unnamed "potential co-conspirators," negotiated by Epstein's defense team.
p. Legal framework sectionSDNY prosecution memo — Dershowitz role as Epstein defense attorney who negotiated NPA, later named as having sexually abused victims.
p. NPA analysis sectionSDNY prosecution memo — no charges filed against journal-named individuals, no law enforcement interviews of D.C. cluster members.
p. Charging recommendationsSDNY 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 DSDNY prosecution memo — 2007 NPA blanket immunity provision covering unnamed "potential co-conspirators"
p. Legal framework sectionSDNY prosecution memo — Maxwell conviction December 2021; sex trafficking, conspiracy, transporting minor; 20-year sentence
p. Legal framework sectionSDNY 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. 47-48SDNY 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. 63-65SDNY 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 sectionSDNY 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 section2007 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 sectionWeinstein 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 recordNew York Court of Appeals overturns Weinstein conviction, April 25, 2024 — ruling trial judge improperly allowed testimony about prior uncharged conduct. Retrial ordered.
p. Public recordWeinstein 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