Professional Documents
Culture Documents
EXHIBIT 86
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 2 of 196
Jeffrey Epstein
6l00 Red Hook, Suite 83
St Thomas, VI 00802~1348
The United States Virgin Islands Department of Justice ("USVIDOJ'') understands that
your bus.iness activities require you to make frequent trips outside of the Territory to the United
States destinations and 1ntemationat destinations. While provisions were granted itt the past, upon
our cmefol review and consideration these ar-i the conditions to which you must now comply:
1. Notification of any travel outside of the U.S, Virgin Isla.t1ds must be provided in person
at USVIDOJ when you are in the Territory;
'2. Notification by email ca:n only serve as notification if you are already outside the
jurisdiction and planning on travding to another destination or to notify of a change in
the length of your travels while you are outside the Territory;
3. You are required lo appear in person at USVIDOJ at least twenty one calendar days
prior to any .intended travel outside of the United States; and
When yoll appear in person to inform of your intent to trnvel, you mttst provide the
following infonnatkm:
• Destination
• Dates of travd
• Places of arrival and departure
• Itinerary details
·II' Address or, in lieu, telephone contact .infonnation
• Purpose of travel
• Any other required information
These requirements are pursuant to Chapter 86, Section 1724 (b) of the Virgin Islands Code
and H,R.515 - International tvfegan's Law.
a 4 .oe K1we,1,._1u1<t>sa"" BA:tin 'OBUS lk.t>o., '-""'" Pu:,oi. • .'h. Tuo,u,..,, tU:l, '\hnm><1 Im-""'"-' 008()~ • frMo) H4•tl666 • l'..x (0<1-D) n«••l"l'.11<1
604-'0 CAa'tt..J.I' Co;..ltl..&Y e Dn&1a::i1 C:aM"r8a1 .fh... n~.,.. C.lta1h'T.u..N:r;:-:r-~u):1 ST, C-noi.x,, 'tJ,S. "1/"-:f.kOlN' f~·r...lf....N'n,;s ooa~o {0~1-9) 773,,,0~'95,. FAX. (B-4-0} "1'10 ... 0'i:c::U(j
.
11
Jeffrey Epstein
March 14, 2019
Page2
Mr. Epstein, please understand that the previous provisions for your travel notifications am
no longer accepted by USVIDOJ and you must comply immediately with the conditions noted
above. We thank you for you cooperation and trust that you will adhere to these conditions.
Sincerely,
~~?-~L
, Carol Thomas-Jacobs, " · . ,
Acting Attorney General
Travel to US Jurisdictions
l. That pursuant to Chapter 86, Section 1724 (b) (l) in the event of a change
in temporary lodging, I am required to inform the Virgin Islands Department of Justice, in
person, of any changes to my temporary lodging information and shall notify the jurisdiction
in which I will be temporarily staying. ~ials
International Travel
I. That pursuant to Chapter 86, Section 1724 (b) (4) I am required to appear
in person at the Virgin Islands Department of Justice at least twenty one (21) calendar days
prior to any intended travel outside of the United States and provide pertinent travel
information. i{J:7 Initials
VIDOJISOR-16
VI-JPM-000012330
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 5 of 196
I have also been advised, and understand, that failure to comply with these obligations
subjects me to prosecution for failure to register or update my registration pursuant to:
1. Virgin Islands Code, Title 14, Section 1730, punishable by a fine not less than
$3,000 nor more than $5,000, or imprisonment for not less than three months nor
more than two years, or both; and ...
Signature~
VIOOJ-SOR2
VI-JPM-000012331
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 6 of 196
Page 2 of6
VI-JPM-000012332
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 7 of 196
Page3 of6
•.
emergency situations, shall notify the Department of Justice prior to departure, by telephone or
in writing, of travel outside the United States for periods of 48 hours or less, and shall notify the
Department of Justice in writing at least 24 hours before traveling outside of the United States
for periods of more than 48 hours, and, in any such case, shall notify the Department of Justice
in writing upon the sex offender's return to this jurisdiction; provided, however that the
Attorney General may at his discretion reduce this twenty-one (21) day notice requirement if a
sex offender requests such a reduction and provides information in support of the request.
(c) Before moving from the United States Virgin Islands to another jurisdiction within the
United States, a person required to register shall register his new address, temporary or
permanent, with the Department of Justice before he leaves the territory. Upon arriving in the
new state, territory or Indian tribe, a person required to register shall report said arrival to the
Department of Justice and register with the agency responsible for registering sex offenders in
the new state, territory or Indian tribe of residency within three (3) days of his arrival. The
registration information of that person will be removed from the Virgin Islands registry when
proof is provided showing that he is registered in the new state, territory or Indian tribe. If a
person required to register moves to a foreign country, he must register his new address with
the Department of Justice before he leaves the territory and register in the foreign country If
there is a registration requirement in that country.
(d) A sex offender who is required to register shall, at a minimum, appear in person at the
Department of Justice for the purposes of verification and keeping their registration current in
accordance with the following time frames:
(1) For "Tier 1" offenders, once every year for 15 years from the time of release from custody
for a sex offender who is incarcerated for the registration offense or from the date of sentencing
for a sex offender who is not incarcerated for the registration offense.
(2) For a "Tier 2" offenders, once every 180 days for 25 years from the time of release from
custody for a sex offender who is incarcerated for the registration offense or from the date of
sentencing for a sex offender who is not incarcerated for the registration offense.
(3) For "Tier 3" offenders, once every 90 days for the rest of their lives.
(4) For sex offenders classified in Tier 1, Tier 2 or Tier 3 who are homeless, once every week
for the period of years prescribed above based upon his or her tier classification until he or she
declares a permanent residence after which the frequency of registration shall be as prescribed
above according to his or her tier classification.
(e) A sex offender may have their period of registration reduced as follows:
(1) A "Tier l" sex offender may have his or her period of registration reduced to 10 years only
after he or she has maintained a clean record for 10 consecutive years and the Sex Offender
Registry Board has made a favorable determination regarding the risk of re-offense and the
degree of dangerousness the sex offender poses to the community.
Pa.gc 3 7
l 4 \/I(L
{14)
( .i)
Page 4 ot ;
{viii)
SECTION F - Internet Identifiers -List any and all email addresses used, Instant Messaging addresses and identifiers, designations or monikers
in internet communications and postings, and all social network identifiers. [ ] NIA
EMAILS ON FILE
As a Sexual Offender (Title 14 V.LC. § 1721-1731) you are required by law to abide by the following:
1. Within three (3) business days of rnoving to or returning to the Virgin Islands you must regis!er in the Virgin ls!ands and keep your
registration current in each jurisdiction in which you reside, and in each jurisdiction where you are employed (including self-employment,
non-compensated and volunteer activities), and in each jurisdiction where you are a student.
2. In the event there is a change in your name, employment, residence, temporary lodging information, vehicle information, or
internet identifiers, you are required to appear in person at the Departmen1 of Justce not later than three (3) working days after such
change,
3. In the event that you move outside of the United States Virgin Islands, you rnust register your new address with the Department of Justice
before you !eave and you must also reg:s!er in your new state not later than three (3} business days after arrival there if your new state
has a registration requirement
4. In the event !hat you are traveling outside of the Virgin Islands your are to required to appear in person at the Department of Justice prior
to your departure and provide your travel destination, dates of travels places of arriva! and departure, itinerary details, address, contact
telephone information, and purpose of traveL
5. Depending on !he type of sex offense for which you have been convicted, you are required to appear in person at the Department of
Justice to verify your information and to take a current photograph, when necessary,
[ l every three (3) months [ ] every six (6) months [ ] every year,
6. Depending on the type of sex offense for which you have been convicted, you are required to appear in person at the Department of
Justice to verify your information and to take a current photograph, when necessary, for a period of
[ ] 15 years [ l 25 years [ 1 for life,
7. Failure to comply wiih these obligations subjects you to prosecu1ion for failure to register or update your registration pursuant to:
a. Virgin Islands Code, Title 14, Section 1730, punishable by a fine not less than $3,000 nor more than $5,000, or
imprisonment for not less than three months nor more than two years, or both; and,,,
b. Federal Law, 18 U.S,C. Section 2250, punishable by up to 10 years of imprisonment.
Be Reminded that under Title l of the Adam Walsh Act entitled the "Sexual Offender Registration and Notification Act "(SORNA), all
individua!s convicted of a sex offense are required to register and keep H1eir registration current in each jurisdiction where he or she
resides, is an emp!oyee and is a student
Witness:
I certify that ! specifically informed the offender of l1is /her duties as set
\ \~
Sig~5re~ t'l 1
fqrtli'above and he indicateJ. to me an understanding of those duties.
'"'''\ ./ . ,_,,,,,. D3 f'S,., 1
D~e
Shan[ A. Pinney
Print Name
'
VIDOJ/SOR-1
Travel to US .Jurisdictions
L That pursuant to Chapter 86. Section 1724 (b) (1) in the event of a change
in temporary lodging, 1 am required to infrmn the Virgin Islands Department of Justice, in
person, of any changes to my temporary lodging infonnation and shall notif)' the jurisdiction
in which I will be temporarily staying, //) ./} Ini~ials
V'
International Travel
l. That pursuant to Chapter 86, Section l 724 (h) (4) 1 am required to appear
in person at the Virgin Islands Department of Justice at !east t,venty one (21) calendar days
prior to any intended tnWi,:.J outside of the United States and provide pertinent trnvel
information. /i Initials
.l-L,t;::
2. ff a reduction in the 21-day notice requirement is requested, I must
submit information in support of the request for approval at the discretion of the Department
of Justice.
ViDOJ/SOR,16
! have also been advised, and understand, that failure to comply with these obligations
sultjccts me to prosecution for friilure to register or update my registration pursuant to:
l. Virgin Islands Code, Titk 14, Section l 730, punishable by a fine not less than
S3,000 nor rnore than $5,000, or imprisonment frff not less than three months nor
more than two years, or both: and .. _
VIDOJ-SOR2
Date Submitted:103/19/19
Aliases(if any}:
Citizenship:
Criminal Record
Date(s) of Conviction: IJun 30, 20081 City and State or Jurisdiction of Conviction: 1......F_lo_r_id_a_______
Sex Offense(sl of which Procurring a person under the age of 18 for prostitution
Convicted:
!E_p_s_te_in
Last Name: ... _____ ___,I FfrH Name: ._p_e_ff_re_Y_ _ _ _ _ _ ---'I Middle Narne: IE_d_w_a_r_d
..... ____.,
Citizenship:
Date(s) of Conviction: pun 30. 20081 my and State or Jurisdiction of Conviction: ,..IF_lo_r_id_a_ _ _ _ _ _ _ _i
Sex Offonse(s) of which Procurring a person under the age of 18 fer prosmutic,n
Convicted:
Other
2 12 73 9
Contact information in Destination Country: 1..._·_ _·5_3_3_-3__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __.;
Ms. s. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. On March 2, 2019, Mr. Epstein
plans to to travel from his vacation home in New York, New York to his vacation home in Palm Beach,
Florida, where he expects to stay until March 6, 2019. On March 6, 2019, Mr Epstein intends to travel
from his vacation home in Palm Beach, Florida to his vacation home in New York. New York, where he
expects to stay until March 9, 2019. On March 9, 2019, Mr. Epstein plans to travel by private aircraft,
N212JE, from his vacation home in New York, New York to his vacation home in Paris, France. He
expects to arrive at Le Bourget Airport in Paris, France at approximately 7:30PM local time on March 9,
2019 and to stay at his vacation home in Paris, France until March 17, 2019. On March 17, 2019, Mr.
Epstein plans to retum by private aircraft. N212JE, from his vacation home in Paris, France to his
permanent residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King International
Airport in St Thomas, U.S. Virgin Islands on March 17, 2019 at approximately L-OOPM local time. While
traveling abroad, he can be contacted on his mobile telephone number at 212•533-3739. In addition,
he can be contacted through his business office at 340-775-2525 or through me at Mr.
Epstein will email your office upon his return to the U.S. Virgin Islands on March 17, 2019.
If you need any furth • 1. • , •.ti please feel free to caJI me at r on my mobile
telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
hUps://oulloolc..office.comhnalf/aearcQJcAGVkOGY11VWVzLTVlcMTktNGNl2i110DgzLTRhNjclM2E10TJkZOAOAOmxH!mwJS1AmwtHfJ4CMBc... 112
hllps://oullook.Gffiatoom/malllaearchlld/AAQlcAGVkOGYltYWYzt.TVlcMTldNGNIZi1iOl>gzLTRIIHJczM2E10TJkZQA0AOmxHlmwJ51AmWIHfJ4CMBc.•• 2/2
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. On March 2, 2019, Mr. Epstein
plans to to travel from his vacation home in New York, New York to his vacation home in Palm Beach,
Florida, where he expects to stay until March 6, 2019. On March 6, 2019, Mr Epstein intends to travel
from his vacation home in Palm Beach, Florida to his vacation home in New York, New York, where he
expects to stay until March 9, 2019. On March 9, 2019, Mr. Epstein plans to travel by private aircraft,
N212JE, from his vacation home in New York, New York to his vacation home in Paris, France. He
expects to arrive at Le Bourget Airport in Paris, France at approximately 7:30PM local time on March 9,
2019 and to stay at his vacation home in Paris, France until March 17, 2019. On March 17, 2019, Mr.
Epstein plans to return by private aircraft, N212JE, from his vacation home in Paris, France to his
permanent residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King International
Airport in St Thomas, U.S. Virgin Islands on March 17, 2019 at approximately 1:00PM local time. While
traveling abroad, he can be contacted on his mobile telephone number at 212-533 -3739. In addition,
he can be contacted through his business office at 340-775-2525 or through me at M r.
Epstein will email your office upon his return to t he U.S. Virgin Islands on March 17, 2019.
If you need any further information, please feel free to call me at .-...illlor on my mobile
telephone numbe
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectful ly,
******************************************************************************************************
The information contained in this communication is confidential, may be attorney-client
privileged, and is intended only for the use of the addressee. It is the property of
Darren K. Indyke. Unauthorized use, disclosure or copying of this communication
or any part thereof is strictly prohibited and may be unlawful. If you have received this
communication in error, please notify us immediately by return e-mail, and destroy this
communication and all copies thereof, including all attachments.
Copyright of Darren K. Indyke - © 2019 Darren K. Indyke - All rights reserved.
*********'lrit********************************************************************************************
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. On March 2, 2019, Mr. Epstein
plans to to travel from his vacation home in New York, New York to his vacation home in Palm Beach,
Florida, where he expects to stay until March 6, 2019. On March 6, 2019, Mr Epsteln intends to travel
from his vacation home in Palm Beach, Florida to his vacation home in New York, New York, where he
expects to stay until March 9, 2019. On March 9, 2019, Mr. Epstein plans to travel by private aircraft,
N212JE, from his vacation home in New York, New York to his vacation home in Paris, France. He
expects to arrive at le Bourget Airport in Paris, France at approximately 7:30PM local time on March 9,
2019 and to 5tay at his vacation home in Paris, France until March 17, 2019. On March 17, 2019, Mr.
Epstein plans to return by private aircraft, N212JE, from his vacation home in Paris, France to his
permanent residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King International
Airport in St. Thomas, U.S. Virgin Islands on March 17, 2019 at approximately 1:00PM local time. While
traveling abroad, he can be contacted on his mobile telephone number at 212-533-3739. In addition,
he can be contacted through his business office at 340-775-2525 or through me at Mr.
Epstein will email your office upon his return to the US. Virgin Islands on March 17, 2019.
If you need any further information, please feel free to call me at ~ ron my mobile
telephone n u m b e , _
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
ht1pa://ouUook.oftlce.comlmalllaearc:hlld/AAQ!cAGVkOGYxVWVzl.1VkMTklNGNm1IOOgzllfUINJc:rM2E10TJkZQAQAOmxH!mwJ51AfflWIHfJ4CMBc... 112
httpa://outlook.office.comfmaillaeardtlld/AAQkAGVkOGYicYWVzLTVlcM1tdNGNIZffTRhNjc:zM2E10TJkZQAOAOmxHfrnwJS1AmWIHfJ4CM8c... '12
Felony: _ _ Misdemeanor: _ __
\
VIDOJ!SOR-7
B'{ ____Nh._ _ _ _ _ __
(Mi\lfl)D/YY)
Completed By;
(You are required to notify the Sexual Registry Coordinator when you return to the Territory)
50R•5
Driver's L i c e n s e # : - - - - - - - - - - - - - - - - - - - - - -
felony: __ Misdemeanor: _ _
VIDOJISOR.7
Felony: _ _ Misdemeanor:
BY _ _ _->=-L-------
(MMIDD/Y\')
Date:
(You are required to notify the Sexual Registry Coordinator when you return to the Territory)
iOR•S
8
VIRGIN ISLANDS DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
VIRGIN ISLANDS SEXUAL OFFENDER REGISTRY
Driver's license #:
Felony: __ Misdemeanor: _ _
I WIOJISOR-7
Felony: _ _ Misdemeanor:
BY _ _ _~ - - - - -
(MMIDDIYV)
Date:
(You are required to notify the Sexual Registry Coordinator when you return to the Territory)
iOR•S
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands .
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein plans to remain at his vacation home in Paris, France until April 21 2019. On
April 2, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in Paris, France to his vacation home in New York New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 6:15PM tocal
time on April 2, 2019 and to stay at his vacation home in New York, New York until
April 8, 2019. On April 8, 2019, Mr. Epstein plans to travel from his vacation home in
New York, New York to his vacation home in Palm Beach, Florida, where he expects
to stay until April 11, 2019. On April 11, 2019, Mr. Epstein plains to retum from his
vacation home in Palm Beach, Florida to his permanent residence in the U.S. Virgin
Islands. He will email your office upon his return to the U.S. Virgin Islands on April
11, 2019.
This is also to advise you that Mr. Epstein plans to travel on April 15, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 15, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St Thomas, U.S. Virgin Islands at approximately 11AM on
April 30, 2019 and will email your office upon his return. While traveling abroad, he
can be contacted on his mobile telephone number at 212-533-3739. In addition, he
can be contacted through his business office at 340-775-2525 or through me at -
llttp&://outlool.cffic&.ciomlma~dlAAQlcAGVkOGYxVWYzt.NkMTktNGNIZl110Dgzl.TRhHjczM2E10TJkZQAQAJl%28TFD22S9tmxl90TBlW8g... 1/2
If you need any further information, please feel free to call me at oron
my mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
DARREN K. INDVKE
httpa://ouUook.offlce.com/maWsean:hlldlAAQlcAGVkOGYicYWYzLTVlcMlktNGNIZl1100gd..TRhNjc:zM2E10TJlcZQAQAJt%28TF022881m,ci90TBIWeg...
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein plans to remain at his vacation home in Paris, France until April 2, 2019. On
April 2, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in Paris, France to his vacation home in New York New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 6:15PM local
t ime on April 2, 2019 and to stay at his vacation home in New York, New York until
April 8, 2019. On April 8, 2019, Mr. Epstein plans to travel from his vacation home in
New York, New York to his vacation home in Palm Beach, Florida, where he expects
to stay until April 11, 2019. On April 11, 2019, Mr. Epstein plains to return from his
vacation home in Palm Beach, Florida to his permanent residence in the U.S. Virgin
Islands. He will email your office upon his return to the U.S. Virgin Islands on April
11, 2019.
This is also to advise you that Mr. Epstein plans to travel on April 15, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 15, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 11AM on
April 30, 2019 and will email your office upon his return. While traveling abroad, he
can be contacted on his mobile telephone number at 212-533-3739. In addition, he
can be contacted through his business office at 340-775-2525 or through me at -
If you need any further information, please feel free to call me at oron
my mobile telephone numbe
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
Mr. Epstein will rema in at 22 Avenue Foch in Paris, France until July 14, 2019. On July
14, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from 22 Avenue
Foch in Paris, France to 9 East 71st Street, New York, New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 11AM local
t ime on July 14, 2019 and to stay at 9 East 71st Street, New York, New York until
July 20, 2019. On July 20, 2019, Mr. Epstein plans to travel from New York, New
York to 358 El Brillo Way in Palm Beach, Florida, where he expects to stay until July
21, 2019. On July 21, 2019, Mr. Epstein plans to return from Palm Beach, Florida to
his permanent residence in the U.S. Virgin Islands. He will email your office upon
his return on July 21, 2019.
This is also to advise you that on July 24, 2019, Mr. Epstein plans to travel by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
22 Avenue Foch in Paris, France. He expects to arrive at Le Bourget Airport in Paris,
France at approximately 7:30PM local time on July 24, 2019 and to remain at 22
Avenue Foch in Paris, France until August, 3, 2019. On August 3, 2019, Mr. Epstein
plans to return by private aircraft, N212JE, from Paris, France to his permanent
residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 12:00PM
local time on August 3, 2019 and will email your office upon his return on August 3,
2019.
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein plans to remain at his vacation home in Paris, France until April 2, 2019. On
April 2, 2019, Mr. Epstein plans to travel by private aircraft, N212J E, from his vacation
home in Paris, France to his vacation home in New York New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 6:15PM local
time on April 2, 2019 and to stay at his vacation home in New York, New York until
April 8, 2019. On April 8, 2019, Mr. Epstein plans to travel from his vacation home in
New York, New York to his vacation home in Palm Beach, Florida, where he expects
to stay until April 11, 2019. On April 11, 2019, M r. Epstein plains to return from his
vacation home in Palm Beach, Florida t o his permanent residence in the U.S. Virg in
Islands. He will email your office upon his return to the U.S. Virgin Islands on April
11, 2019.
This is also to advise you that Mr. Epstein plans to travel on April 15, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 15, 2019 and t o remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 11AM on
April 30, 2019 and will email your office upon his return. While traveling abroad, he
can be contacted on his mobile telephone number at 212-533-3739. In addition, he
can be contacted through his business office at 340-775-2525 or through me a t -
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
hltps://oullook.office.com/maiVsearch/id/AAQkAGVkOGYxYWYzL1VkMTktNGNIZi1iODgzLTRhNjczM2E1OTJkZQAQAJt%2BTFO22S9Imxi9OTBtW6g... 2/2
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein plans to remain at his vacation home in Paris, France until April 2, 2019. On
April 2, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in Paris, France to his vacation home in New York New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 6:15PM local
time on April 2, 2019 and to stay at his vacation home in New York, New York until
April 8, 2019. On April 8, 2019, Mr. Epstein plans to travel from his vacation home in
New York, New York to his vacation home in Palm Beach, Florida, where he expects
to stay until April 11, 2019. On April 11, 2019, Mr. Epstein plains to return from his
vacation home in Palm Beach, Florida to his permanent residence in the U.S. Virgin
Islands. He will email your office upon his return to the U.S. Virgin Islands on April
11, 2019.
This is also to advise you that Mr. Epstein plans to travel on April 15, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 15, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 11AM on
April 30, 2019 and will email your office upon his return. While traveling abroad, he
can be contacted on his mobile telephone number at 212-533-3739. In addition, he
can be contacted through his business office at 340-775-2525 or through me at -
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
https://outlook.office.com/maiVsearch/id/MQkAGVkOGYxYWYzLTVkMTktNGNIZi1IOOgz:LTRhNjczM2E1OTJkZQAQAJt%2BTFD22S91mxi9OTBtW6g... 2/2
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein plans to remain at his vacation home in Paris, France until April 2, 2019. On
April 2, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in Paris, France to his vacation home in New York New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 6:15PM local
time on April 2, 2019 and to stay at his vacation home in New York, New York until
April 8, 2019. On April 8, 2019, Mr. Epstein plans to travel from his vacation home in
New York, New York to his vacation home in Palm Beach, Florida, where he expects
to stay until April 11, 2019. On April 11, 2019, Mr. Epstein plains to return from his
vacation home in Palm Beach, Florida to his permanent residence in the U.S. Virgin
Islands. He will email your office upon his retum to the U.S. Virgin Islands on AprU
11, 2019.
This is also to advise you that Mr. Epstein plans to travel on April 15, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 15, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 11AM on
April 30, 2019 and will email your office upon his return. While traveling abroad, he
can be contacted on his mobile telephone number at 212-S33-3739. In addition, he
can be contacted through his business office at 340-775-2525 or through me a t .
hltpa:l/outloot.offioe.comhnallfsoan:Nld/AAQtcAG\lkOGVxVWYzLTVkMTlltNQNIZl110DgizLTRltNJczM2E10TJlcZQAQAJ~fmldSOT8tW8g... 112
Carol Thomas~Jacobs
Good morning Caro!. ! hope this email finds you well and certainly hope you are enjoying your day off. Is there a time we
could speak this week regardin,g your letter to Mr. Epstein of March 14, 2019?
Erika A Kellerhals
Member
Kellerhals Ferguson Krob!in PLLC
Royal Palms Professional Building
9053 Estate Thomas Suite 101
St. Thomas, VI 00802
Notice: This comrnuolca!ion may contain pfiviley<1!:! or ether confidential infonnation. If you are not tile !ntendel'.i recipient, -or betfeve that y<iu have received lhis
cornmunicaHon itl error, please do not prlnL wpy, re-transmit, disseminate. or otherwise use this information. Also, please indicate to the sender. \oat you have
received 1his e-muil in error, and delete it1e copy you received, Thank you.
If you need any further information, please feel free to call me at oron
my mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
htlpa:lloutlook.offlce.comlmell/sean:Md/AAQkAC3Vk0GYxYWYzLTVkMTktNGNIZl110Dgzl.TRht<,czM2E10TJkZQAQAJl%2BTFD22SGlmlcl80T8tW8g... 212
Driver's license #:
Felony: __ Misdemeanor: _ _
VIDOJJSOR-7
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
7, 2019, Mr. Epstein will travel from his vacation home in New York, New York to his
vacation home in Palm Beach, Florida, where he expects to stay until April 9, 2019.
On April 9, 2019, Mr. Epstein plains to return from his vacation home in Palm Beach,
Florida to his permanent residence in the U.S. Virgin Islands. He will email your
office upon his return to the U.S. Virgin Islands on April 9, 2019. . .
This is also to advise you that Mr. Epstein plans to travel on April 20, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 20, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 11AM local
time on April 30, 2019 and will email your office upon his return. While traveling
abroad, he can be contacted on his mobile telephone number at 212-533-3739. In
addition, he can be contacted through his business office at 340-VS-2525 or
through me a
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
https".lloulloo1c.offlce.comhnalllsea,c:hlld/AAQkAGVkOGVICVWYzLTVIIMTldNGNIZl110Dgzl.TRhNjczM2E10TJkZQAOAJ80RNxlcs4FfllK6%28ADHgY... 112.
Respectfully,
httpa://outlook.afflca.c:omrmantaesrc:hlld/AAQkAGVkOGYxYWV21.lVkMTktNGNJZi1100gz.LTRIINjczM2E10TJlcZQAQAJ80RNxka4FFIIK6"2BADHgY-· 2/2
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
7, 2019, Mr. Epstein will travel from his vacation home in New York, New York to his
vacation home in Palm Beach, Florida, where he expects to stay until April 9, 2019.
On April 9, 2019, Mr. Epstein plains to return from his vacation home in Palm Beach,
Florida to his permanent residence in the U.S. Virgin Islands. He will email your
office upon his return to the U.S. Virgin Islands on April 9, 2019.
This is also to advise you that Mr. Epstein plans to travel on April 20, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 20, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 11AM local
time on April 30, 2019 and will email your office upon his return. While traveling
abroad, he can be contacted on his mobile telephone number at 212-533-3739. In
addition, he can be contacted through his business office at 340-775-2525 or
through me at
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
https:1/oullook.office.com/maiVsearch/id/AAQkAGVkOGYxYWYzLTVkMTktNGNIZi1iOOgzLTRhNjczM2E1OTJkZQAQAJBORNxks4FFhK6%2BADHgY .. . 2/2
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
7, 2019, Mr. Epstein will travel from his vacation home in New York, New York to his
vacation home in Palm Beach, Florida, where he expects to stay until April 9, 2019.
On April 9, 2019, Mr. Epstein plains to return from his vacation home in Palm Beach,
Florida to his permanent residence in the U.S. Virgin Islands. He will email your
office upon his return to the U.S. Virgin Islands on April 9, 2019. . .
This is also to advise you that Mr. Epstein plans to travel on April 20, 2019 by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
his vacation home in Paris, France. He expects to arrive at Le Bourget Airport in
Paris, France at approximately 7:30PM local time on April 20, 2019 and to remain at
his vacation home in Paris, France until April 30, 2019, when he plans to return by
private aircraft, N212JE, from his vacation home in Paris, France to his permanent
residence in the U.S. Virgin Islands. Mr. Epstein expects to arrive at Cyril E. King
International Airport in St Thomas, U.S. Virgin Islands at approximately 11AM local
time on April 30, 2019 and will email your office upon his return. While traveling
abroad, he can be contacted on his mobile telephone number at 212-533-3739. In
addition, he can be contacted through his business office at 340-775-2525 or
through me at
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
htlps:/fouttookofflce.comtmailhleardll!d/AAQkAGVkOGY>cVWYzL.TVacMTklNGNIZl110Dgzl.TRIINjcZM2E10TJkZQAOAJBORNxka4FfltK4%28ADHgV... 1/2
Respectfully,
........................................................................................................
The Information contained In this communleatlon Is confidential, may be attorney-client
privileged, and Is Intended only for the use of lhe addtessee. tt Is the property of
Da"en K. fndyke. Unauthorized use, disclosure or copying of lhls communication
or any pa,t thereof Is strictly prohibited and may be untawrul If you have received this
communication fn errcr, please notify us lmmedfately by return e-mail, and destroy lhls
communication and all caples thereof, lncludln9 all attachments.
....................................................."".....................................................
Copyright of Darren K. lndyke - @ 2019 Damm K. fndyke -All rights reserved•
hUpa://outloak.offlc&.comlmellfsearc:hlldlAAOkAGVltOGYx'WWVzl.TVlcMTktNGNJZi1100gzLTRhNJczM2£10TJkZQAQAJBORN~28A0H9Yu, 212
Shani Pinney
From: J <jeevacation@gmail.com>
Sent: Wednesday, April rn, 2019 11 :58 AM
To: Shani Pinney; Darren lndyke
Subject: Re:
i am not feeling well and might leave earlier than planned 1 can come in iomnl\v allernoon aroudn l 30 if ok
with you
From: J <jeevacation(wgrnail.corn>
Sent: Tuesday, April 9, 2019 3:46 PM
To: Shani Pinnev; Shani Pinney; Darren lndyke; Kevin Augustin
Subject:
?vls, S. Pinney
Territorial SClR Program Manager
'Virgin Islands Department of Justice
United States Virgin Islands
This is to ad vise you that l wiH travd on /\pri! 16, 2019 from my permanent residence in the U ,S. Virgin
lsiands to my vacation home in Ne\v ·York, New York, where l expect to stay until ,April 19, 20l 9, On /1,pril
19, 20 l 9, I p1an to travel on by private aircraf\ N212J E, from 1ny vacation horne in Ne\v York, New-
York to rny residence in Paris, France for business. I expect to arrive at Le Bourget ,Airport in
Paris, France at approximately 7:30PM local time on April 19, 2019 and to remain there until
April 30, 20 I 9. On April 30, 2019, I plan to travel by private aircraft, N212JE, from Paris, France
to my vacation home in Nev,r York, Nevv York, I expect to arrive at Teterboro Airport in
0
Teterboro, New Jersey at approximatcly 11 A_M local time on April 30, 2019 and to stay at rny
vacation home in Nev; York, Ncv,c York until May 3 1 2019, On l\fay 3, 2019, I plan to travel from
my vacation home in New'{ ork, New''{ ork to rny vacation home in Stan1cy, New !'vlcxico, \Vhere
I expect to stay until May 14, 2019. On Ivfay 14, 20 l 9, I plan to travel from rny vacation home in
Stanley 1 New Mexico to my vacation hornc in New 'fork~ New York, \vhere I expect to stay until
?vlay 16, 2019, 'vvben I plan to return from my vacation home in York, New York to my
permanent residence in the U.S. Virgin Islands. I vvill email your ofTice upon rny return on May
16, 2019. \Vhile traveling abroad, I can be contacted on my mobile telephone number at 2 [2-533-
3739.
- - ln addition,. I can be contacted through mv.,, business office at 340-775-2525
··- ·-·-·- or thromzh mv
.,,
~ ·-
attomey, Darren K, lndyke, at
. .,
If you need any fmiher information lease foel free to call Attorney lndyke at r on
his mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms, Pinney. ls lherc a good fanc
on tuesday the 16th to come to you if needed . thx,
Respectfully,
please note
The information contained in thJs comnmnication is
confidential, may be attorney-client privilege.cl, may
constitute inside information, and is intended only for
the use of the addre$see, It js the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly profobited
and may be unlawful, If you have received this
communication in error, please notify us immediately by
return c--rnail or by e-mrdl to jcevacation(i.1~gm1tiLcorn., and
destroy this communication and all copies tbereo(
including all attachments. copyright -all rights reserved
please note
The information contained in this commlmication is
confidential, may be aitomey-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
commu11icatio11 in error, please notify us irnmediately by
return e-mail or by e-mail to fa£.Y!l9J,ti9Jl@gmail.com, and
destroy this communication and all copjes thereot:
including all attachments, copyright *all rights reserved
Caro l Thomas•Jacobs
Good morning Attorney Jacobs - just following up on my question regarding the Sexual Offender Registry Boanl and
whether or not rt is active, Thank you.
Erika A. Kellerhals
Member
KeHerhals Ferguson Kroblin PLLC
Royal Palms Professional Building
9053 Estate Thomas Suite 101
St Thomas, VI 00802
Notice: Thls Ct,rnmw,ii:;ation may corllain privileged or other c;onfidential informalion, If you are not lhe intenaoo ni<;iplent, or Mlieve that you have received this
commuoication in error_ please <lo tlOt prinl, copy, ro-,1ra,1smit disseminate. or other...,ise use this infolT!lal1on, Also. please i1micale to 1h~ sender that you have
received this e-mail in error. and ctoMe the copy yoll roeeived, roan~ }'OU.
Thank you again for speaking wit h me last week. I had one last question thet I forgot to ask you, Is there an active Sex
Offender Registry Board - as provided for in the statute?
Erika A. Kellerhals
Member
Kellerhals Ferguson Kroblin PLLC
Royal Palms Professional Building
9053 Estate Thomas Suite 101
St. Thomas. VI 0080.2
Notice: This com1n1.inication may contain priVi!eged or other conl1dential lnformatiQn. If you a.re net tho intended rec!piont. or believe thal you have received this
communication in error, pfo.ise (lo not print, copy, re-transmit, <lissernina!e, Of other.vise use this lnfo011ation Also, pioase indicale to !he sender that you have
received th,s e•mall In error, anll delete the copy you recefved. ·niank you.
Good morning Carol. r just realized I have to be at airport at 3pm. Any chance we could talk at 2;30? Or tomorrow I am
free between 9:30 a11d 12?
Erika A. Kellerhals
Member
Thank you. Please let me know the best number to call you.
Erika A. Ker!erhals
Member
Nolke: This camrnunication may cont,iin privileged or othiu conlldenlial !nfofmat\on. lf you afe not ihe inten<l~d
recipient. or believe that you have received this communication iri error. pleasa <lo not prit11, C()py. re-transmit.
dissemlnate, 0 1 othen,vise owt!Jis information. Also, please indicate to the seMer tt!at your.av~ ieceived lh.is e-n1ail
ln orror; .ind delete the copy you received. Thani<. you,
Good morning CaroL ! hope this email finds you well and certainly hope you are
enjoying your day off. ts there a time we could speak this week regarding your letter
to Mr., Epstein of March 14, 2019?
Erika A. Kellerha!s
Member
Notice: This communication may contain prtvileged or other conlldential Information. If you are not the intended
recipient, or believe that you have received this communication In error, please do not print, copy, re-transmit.
disseminate, or otherwise use this lnfonnallon. Also, please Indicate to the sender that you have received this e-
mail In error, and delete the copy you received. Thank you.
P=riva=te:..:Ai=:.::rC:::.:m=ft=-------------------
Method of Travel: ....
Felony: __ Misdemeanor: _ _
Felony: _ _ Misdemeanor:
BY _ _ _ _ _ _ _ __
(MMJDD/VV)
Date: 41 Itf f
D
{You are required to notify the Sexual Registry Coordinator when you return to the Territory)
OR-5
Felony: _ _ Misdemeanor: _ __
VIDOJ/SOR-7
~O'h>
Upon Arrival in your Destination Please Report to:_··__! _r'7_/_',_-_________________
(,\li'l-1/DDI\"\")
Completed By:
(You are required to notify the Sexual Registry Coordinator when you return to the Territory)
SOR-5
Purpose of Travel: __
B___
us__in...,ess.......__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Driver's License#: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Felony:~ Misdemeanor: _ _
Felony: __ Misdemeanor: _ _
W10JISM•7
Felony: _ _ Misdemeanor:
BY __________
(MM/DD/VY)
Date: 4l If I'~
D
(You are required to notify the Sexual Registry Coordinator when you return to the Territory)
OR-5
Last Name: ._jE_p_s_te_in_ _ _ _ ___;I Fir5t Harne: ,_~_eff_.r_e_y_ _ _ _ _ _.....,I Middle Name: ...
IE_d_v_m_r_d______,
Aliasesm ,myl:
Citizernship:
Sex Offons.e(s) ofwhkh Procurring a person under the age of 18 for prostitution
Convicted:
Last Name: '-IE_p_s_te_il_,_ _ _ _ _ -'! First Name: •'-IJ_ef_fe_r_Y_ _ _ _ _ ____;I Middle Name: ....
IE_d_w_a_r_d_ _ ___,
-
AliaseS(ifanyL
Gt izern hip:
Criminal Record
Date(,) of Conviction: joG/30/08 I City and State or Jurisdiction of Conviction: ._IF_lo_r_id_a_ _ _ _ _ _ ___,
Sex Offense(s) of which Procuring a person under the age of 18 for prostitution
Convicted:
Other Epstein expects to arrive at Le Bour9et Airpoti in Paris, France at approxirnate!y 7:30PM
information, (Le, local time on April 20, 2019 and to remain at his vacation horne in Paris, France until April
itinerary; visa 30, 2019, when he plans to return by prlvate aircraft, N212.JE, from his vacation home in
information; Paris, France to his permanent residence in the U..S. Virgin Islands.
explain "other"
responses above)
Aliases{if Ml\'l:
Citizenship: US
Criminal Record
Date(s) of Corwk:tlon: lo6/30iOS I City and State or Jur1sdiction of Conviction: j,_iF_lo_r_id_a_ _ _ _ _ _ ___,
Sr.x Offense(s) of which Procuring a person under the age of 18 for prostitution
Convicted:
!us_________________________
Jurbdktion(s) of Current Registry; ,...._ Virgin islands _;
Other
Contact information in De~tination Country: 2'1?
1
~-533__________________________
' v ••3r9
'-·
nd 340-7. 75.'-2525·
,.:k a ' ..)
Other Epstein expects to arrive at Le Bourget Airport !n Paris, France at approximately 7:30PM
fnformatlon, (l,e, ocal time on April 20, 2019 and to remain at his vacation home in Paris, France unfil April
itinerary; visa 30, 2019, when he plans to return by private aircraft, N212.JE, from his vacation horne in
information; Paris, France to his permanent residence in the U.S. Virgin Islands.
explain "other"
responses above)
-_____,
Aliasesn1 a,1yi:
-==---..
Date of Birth: FBI IP (internal use only):
Citizenship; US
Travel Information
Purpose ofTrnveL !Business l3 Means of Travel:L,..F_ir_ ___j[:j..,=o111
Destination Country;
l•.
France
,_
_ I
_ _ _ _ _ _ _........, Address: fh2 Avenue Foch, Paris France
Critnina! Record
Date{s) of Conviction: ~ - - - - - ' Cit}" and State or Jurisdiction of Conviction: j._F_lo_r_id_a_ _ _ _ _ _ __,,.J
Sex Offons-e{s) of which Procuring a person under the age of 1B for prosmution
Convicted:
Other
Contact information in Destination Country: 1212.533.3739 and 340-775-:2525
Other Epstein expects to arrive a! Le Bourget Airport in Paris, France at approximately 7:30PM
information, (i.e. local lime on April 20, 2019 and to remain at his vacation home in Paris, France until April
itinerary; visa 30, 2019, when he plans to return by private aircraft, N212JE, from his vacation home in
information; Paris, France to his permanent residence in the U.S, Virgin Islands.
explain "other"
responses above)
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
25, 2019, Mr. Epstein will travel by private aircraft bearing U.S. Registration No.
N212JE for a day trip from his vacation home in Paris, France to Marrakech, Morocco
and return that same day from Marrakech, Morocco to his vacation home in Paris,
France. He expects to arrive at Menara Airport in Marrakech, Morocco at
approximately 12:00PM local time on April 25, 2019 and depart that same evening
and return to Le Bourget, Airport in Paris, France at approximately 12:35AM on April
26, 2019. He expects to stay at his vacation home in Paris, France until April 30, 2019.
On April 30, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his
vacation home in Paris, France to his vacation home in New York, New York.
He expects to arrive at Teterboro Airport in Teterboro, New Jersey at
approximately 11AM local time on April 30, 2019 and to stay at his vacation home
in New York, New York until May 3, 2019. On May 3, 2019, Mr. Epstein plans to
travel from his vacation home in New York, New York to his vacation home in
Stanley, New Mexico, where he expects to stay until May 14, 2019. On May 14,
2019, Mr. Epstein plans to travel from his vacation home in Stanley, New Mexico to
his vacation home in New York, New York, where he expects to stay until May 16,
2019. On May 16, 2019, Mr. Epstein plans to return from his vacation home in New
York, New York to his permanent residence in the U.S. Virgin Islands. He will email
your office upon his return on May 16, 2019.
While traveling internationally, Mr. Epstein can be contacted on his mobile telephone
at 212-533-3739. In addition, he can be contacted at his business office at 340-775-
2525 or through me at
https://outlook.office.com/maiVsearch/id/AAQkAGVkOGYxYWYzLTVkMTktNGNIZi1iODgzLTRhNjczM2E10TJkZQAQAIFRMOCz%268tFpMh8CiwTg... 1/2
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
DARREN K. INDYKE
https:l/outlook.office.com/mail/search/id/MQkAGVkOGYxYWYzlTVkMTktNGNIZi1i0DgzlTRhNjczM2E10TJkZQAOAIFRMOCz%2BBtFpMh8CiwTg. .. 2/2
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
25, 2019, Mr. Epstein will travel by private aircraft bearing U.S. Registration No.
N212JE for a day trip from his vacation home in Paris, France to Marrakech, Morocco
and return that same day from Marrakech, Morocco to his vacation home in Paris,
France. He expects to arrive at Menara Airport in Marrakech, Morocco at
approximately 12:00PM local time on April 25, 2019 and depart that same evening
and return to Le Bourget, Airport in Paris, France at approximately 12:35AM on April
26, 2019. He expects to stay at his vacation home in Paris, France until April 30, 2019.
On April 30, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his
vacation home in Paris, France to his vacation home in New York, New York.
He expects to arrive at Teterboro Airport in Teterboro, New Jersey at
approximately 11AM local time on April 30, 2019 and to stay at his vacation home
in New York, New York until May 3, 2019. On May 3, 2019, Mr. Epstein plans to
travel from his vacation home in New York, New York to his vacation home in
Stanley, New Mexico, where he expects to stay until May 14, 2019. On May 14,
2019, Mr. Epstein plans to travel from his vacation home in Stanley, New Mexico to
his vacation home in New York, New York, where he expects to stay until May 16,
2019. On May 16, 2019, Mr. Epstein plans to return from his vacation home in New
York, New York to his permanent residence in the U.S. Virgin Islands. He will email
your office upon his return on May 16, 2019.
While traveling internationally, Mr. Epstein can be contacted on his mobile telephone
at 212-533-3739. In addition, he can be contacted at his business office at 340-775-
2525 or through me at
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Res pectfuIly,
We represent Mr. Jeffrey Epstein, who is registered on the U.S. Virgin Islands Sexual Offender
Registry. For the reasons explained below, we are respectfully requesting that the U.S. Virgin Islands
Department of Justice f'USVIDOJ") reinstate the proven travel notification procedures that have
been in effect since Mr. Epstein's initial registration. Since initially registering with the Registry in
2009, Mr. Epstein has strictly followed the USVIDOJ's same travel notification procedures, which
fully comply with both U.S. Virgin Islands statutory law and the United States Sex Offender
Registration and Notification Act ("SORNA"). By letter to Mr. Epstein dated March 14, 2019, then
Acting Assistant 1\ttorney General Carol Thomas Jacobs acknowledged Mr. Epstein's well
documented history of frequent and extensive travel, but advised that the USVIDOJ would no longer
permit Mr. Epstein to follow these procedures, despite the fact that they have worked flawlessly for
the past ten (10) years.
The USVIDOrs Failure to Notify the Dominican Republic of Mr. Epstein's Travel
Mr. Epstein has a ten (10) year record of perfect compliance with his travel notification obligations to
the USVIDQJ. In many cases, Mr. Epstein has over-notified the USVIDOJ regarding his travel in
order to ensure his continuing compliance. To our knowledge, the only issue ever to occur with respect
to Mr. Epstein's travel is related to his recent travel to the Dominican Republic on February 19, 2019.
Mr. Epstein bears absolutely no responsibility for this issue as he gave timely notice to the USVIDOJ
of his intended travel to the Dominican Republic. It is our understanding that the issue arose solely
as a result of the USVIDOJ's inadvertent failure to notify the Dominican Republic of Mr. Epstein's
intended travel to that jurisdiction, as required by 14 V.LC. §1726(d). Because of the USVIDOJ's
failure, Mr. Epstein was detained for several hours by the Dominican Republic authorities and
eventually refused entry into the country. Unfortunately, we believe that this incident, caused solely
by the USVIDOJ, and not by Mr. Epstein, resulted in additional scrutiny regarding Mr. Epstein's travel
reporting, and that this in tum gave rise to the recent decision to change the travel reporting
procedures that have worked perfectly for the past ten (10) years. Attached as Appendix l, you will
find a detailed account of Mr. Epstein's extensive notification efforts relating to his trip to the
Dominican Republic and the response from the USVIDOJ.
I have included for your review, as Appendix 2, the correspondence between Attorney Hodge and
then-Attorney General Vincent Frazer in which then-Attorney General Frazer confirmed the twenty
four (24) hour statutory notice period applicable to Mr. Epstein's frequent travel outside the Virgin
Islands, as well as Mr. Epstein's right to provide travel notification to the USVIDOJ via email and by
facsimile in lieu of in person notification.
Specifically, we are requesting reinstatement of the following travel notification procedures confinned
by the USVIDOJ 1:
• Mr. Epstein will be allowed to notify the Department of Justice of his intention to travel
outside the Territory twenty-four (24) hours p110r to his departure;
• Notice must be given by Mr. Epstein himself, via in--person visit, by facsimile correspondence
which is signed by h.im, or by email with an electronic signature;
• Mr. Epstein will be allowed to continue to notify the department when he is staying in one of
his stateside homes. He must provide ... a current list of, and address for each of his stateside
homes;
• If the jurisdiction to which he travels requires his registration for the duration of time he is
there, he will comply with that registration requirement;
• When Mr. Epstein is staying at the home of an associate, he must notify the department of
the city and state or country in which he is temporarily staying and his period of stay in the
jurisdiction;
1 Th.is hst reflects the relevant reqwrements communicated by letters datedJulr 25, 2012:md August 14, 2012 from then-
• \Vhen Mr. Epstein is staying in a non-private lodging he, or his representative, may provide
the specifics of the name, city, and address of the establishment;
• Notice must be given of any modification from the travel itinerary, as originally advised after
leaving the territory. Such notice may be submitted by facsimile or email by Mr. Epstein or his
legal counsel; and
• Upon returning to the Virgin Islands, Mr. Epstein shall immediately notify the Department of
Justice by visit, facsimile, or email with electronic signature.
Attorney Jacobs letter of March 14, 2019 revoked the notification procedures previously confirmed
by the USVIDOJ and now requires the following:
• [1'Jr. Epstein is] required to appear in person at the USVIDOJ at least twenty-one (21) calendar
days prior to any travel outside the United States;
• Notification of any travel outside the U.S. Virgin Islands must be provided in person at the
USVIDOJ when [!\fr. Epstein] is in the territory;
• Notification by email can only serve as notification if [I\1r. Epstein is] already outside the
territory and planning on travelling to another destination or to notify of a change in the length
of [Mr. Epstein's] travels while [1vlr. Epstein is] outside the territory;
• If a reduction in the twenty-one (21) day notification is requested, [Jvfr. Epstein] must submit
infonnation in support of the request for approval at the discretion of the USVIDOJ.
The Prior Travel Notification Procedures Fully Comply with SO RNA and the USVI Statutes
As discussed in Attorney Hodge's letter of July 30, 2012, SORNA very dearly authorizes flexible
travel notification procedures in cases, such as Mr. Epstein's, where registrants travel frequently for
work or other legitimate purposes. As detailed in Attorney Hodge's letter of July 30, 2012:
The Federal SORNA guidelines have already recognized that there are cases where
flexibility in the application of SORNA's travel notification procedures is necessary.
For example, the SORNA guidelines themselves discuss the case of an individual who
is a t 1long haul trucker11 who regularly drives thousands of miles through 11 dozens of
jurisdictions in the course of his employment11 , as well as the cases of a home...
in1provement contractor and of a day laborer, who travel regularly to various locations
that may change on a daily basis -- see The National Guidelines for Sex Offender
Registration and Notification, pp. 39 and 43 -- or the case of an individual "who lives
in a northern border state and who commutes to Canada for work on a daily basist 1 ,.
- see Supplemental Guidelines for Sex Offender Registration and Notification, Federal
Register, Vol. 76, No. 7 Qanuary 11, 2011), p. 1638. These cases are analogous to any
number of possible situations in our Territory, including pilots, fisherman, boat
captains, boat workers, cruise ship workers, merchants and international businessman,
all of whom travel to and from the Territory on a frequent and regular basis in the
ordinary course of their employment or business. The burden on both the Department
of Justice and the worker of requiring such a worker to give 72-hours and in some
cases 21-day prior notice each time he leaves the Territory and to confirm every
location and address induded in his travel notification would be substantial. In
situations such as these, the SO RNA guidelines pennit the responsible jurisdictions to
reduce notice requirements and simply require the traveling registrant to provide a
most likely itinerary of "normal travel routes" and "general areas" of work. The
National Guidelines for Sex Offender Registration and Notification pp. 39 and 43.
Mr. Epstein's case is no different from any of these cases where SORNA expressly
permits this flexibility in the manner and content of travel notification.
Consider, for example, the case of a St. Thomas boat captain chartering trips to various
islands in the Caribbean. Requiring that boat captain to provide 72 hours prior travel
notice would prevent him from taking any charters unless requested of him more than
three days in advance. With visiting tourists on short stays frequently requesting
charters only a day or two in advance, such a requirement would substantially interfere
with the boat captain's ability to conduct his business. Moreover, requiring him to
provide specific addresses of his travels could also be problematic in that tourists
chartering his boat might not even make such determinations until the day of the actual
charter. Requiring the boat captain to be inflexible with his charter passengers would
therefore also seriously interfere with his business. The supplemental SORNA
guidelines have specifically stated in their own words that such requirements could be
"pointlessly burdensome" and "unworkable". See Supplemental Guidelines for Sex
Offender Registration and Notification, Federal Register, Vol. 76, No. 7 Qanuary 11,
2011), p. 1638. Consistent with the flexibility afforded by the SORNA Guidelines,
both Senator Russell and [then-Attorney General Frazer] acknowledged at that June
21, 2012 legislative hearing that the law must be flexible to enable those who must
travel frequently and on short notice to do so.
Tbe very same flexibility authorized by SORNA for frequent travel reporting is incorporated into
Virgin Islands law. In fact, Section 1724(b)(4) provides for a mandatory exception to the twenty one
(21) day in person notice otherwise required for international travel. Section 1724(b)(4) explicitly
states that "... a sex offender who provides reasonable and reliable proof satisfactory to the
Department of.Justice, that he travels frequently outside the United States for work or other legitimate
purposes, or a sex offender who travels outside the United States for emergency situations, shall notify
the Department ojjustite in writing at least 24 hours before traveling outside of the United States for
periods of more than 48 hours, and, in any such case, shall notify the Department of Justice in writing
upon the sex offender's return to this jurisdiction."
Therefore, in cases such as !\Ir. Epstein's, where he has provided reasonable and reliable proof to the
USVIDO.J that he travels outside the United States for work or other legitimate purposes, we believe
he is only required to notify the US\'IDOJ in writing (that is, by email) at least twentyfour (24) hours
before travelling outside the United States and to notify the l)SVIDOJ in writing upon his return. We
believe that the USVIDOJ is al.ready in possession of substantial proof of l\fr. Epstein's extensive and
frequent international, as well as his domestic, business travel. However, in the event you would like
us to resubmit any information, we would be happy to do so.
Further adopting the recommendations of federal SORNA guidelines, Virgin Islands law provides
equal flexibility with respect to reporting travel between the USVI and the United States. Email travel
reporting prior to departing the USVI for destinations in the United States fully complies with the
requirements of Section 1724(c), Section 1724(c) provides that "[b]efore moving from the United
States Virgin Islands to another jurisdiction within the United States, a person required to register shall
register his new address, temporary or permanent, with the Department of Justice before he leaves
the territory." By its very terms, Section 1724(c) specifically does not require in person notification.
Therefore, Attorney Jacobs' requirement to appear in person to notify the USVIDOJ of travel
between the USVI and the United States appears to exceed the requirements of Virgin Islands law.
Although Attorney Jacobs cited section 1724(b)(1) as the reasoning for revocation of the established
travel procedures, we do not believe that this section is applicable to Mr. Epstein's travels to the
United States. Among the many reasons that we believe that section 1724(b)(1) does not apply is the
fact that Mr. Epstein has already registered his temporary lodging with the USVIDOJ. By its very
language, section 1724(b)(1) appears only to apply .in the event there are changes to Mr. Epstein's
temporary lodging in the United States. Mr. Epstein maintains temporary lodging (vacation homes) in
Florida, New York, and New Mexico. All of the required information :regarding those temporary
lodgings has been on file with the USVIDOJ since Mr. Epstein initially registered in the USVI in 2009.
There have been no changes to Mr. Epstein's temporary lodging information since his initial
registration, and there certainly have been no changes to his temporary lodging information since his
last in person annual registration renewal earlier th.is year, as required by section 1724(d).
As a result of the incident in the Dominican Republic, we are conscious of the need to make sure
there are safeguards in place to ensure Mr. Epstein's compliance and also to ensure that proper
notification is given to jurisdictions that require it. We are respectfully requesting that going forward,
the USVIDOJ provide Mr. Epstein with an email copy of all notifications it is required to make to
jurisdictions outside the USVI pursuant to section 1726(d). By receiving an email copy of these
notifications, Mr. Epstein will be able to confirm that the USVIDOJ has received each of his travel
notices and, if necessary, take additional action to ensure that such notice has been received by the
USVIDOJ and forwarded to the appropriate jurisdictions outside the USVI.
Mr. Epstein's counsel, Darren Indyke, and] would appreciate the opportunity to discuss this matter
with you further. We will make ourselves available at your convenience.
Respectfully,
Erika A. Kellerhals
Encl
APPENDIXt
In accordance with the procedures authorized by Attorney General Frazer in August 2012, Mr.
Epstein gave proper email notice on February 16, 2019 to Ms. Shani Pinney, the Territorial Sexual
Offender Registry Program Manager, of his intention to travel for a day trip to the Dominican
Republic on February 19, 2019. Mr. Epstein's attorney, Darren Indyke, was copied on that email
notice, and received the email at the same time Mr. Epstein emailed it to Ms. Pinney. See Exhibit t.
That notice included all international travel information necessary in order for the Department of
Justice to give the Dominican Republic authorities the required advance notice of Mr. Epstein's arrival.
Mr. Epstein also emailed Ms. Pinney on February 18, 2019 regarding his obligation to annually renew
his registration on March 5, 2019 and advised that after leaving at noon on February 19, 2019, Mr.
Epstein anticipated being outside of the Territory until March 20, 2019. Mr. Epstein inquired in his
email as to whether he should renew his registration before he left the next day or after he returned
on March 20, 2019. Attorney Indyke was also copied on that email, and also received it when M.r.
Epstein emailed it to Ms. Pinney. See Exhibit 2.
Despite Mr. Epstein's timely and proper notice to the Department of Justice of his travel to the
Dominican Republic, the Dominican Republic did not receive advance notice of M.r. Epstein's travel.
As a result, upon Mr. Epstein's arrival in the Dominican Republic on Febrnary 19, 2019, he was
detained for several hours and ultimately denied entry. Having been refused entry, Mr. Epstein then
traveled to his vacation home in Palm Beach, Florida, as his February 16, 2019 email notice advised
he would do.
On February 21, 2019 at 9:57PM (EST), Attorney Indyke notified Ms. Pinney of a modification to
Mr. Epstein's travel plans. As authorized by the travel notification procedures in effect prior to your
March 14, 2019 letter, because Mr. Epstein was traveling and no longer in the Territory at that time,
Attorney Indyke provided the changes to Mr. Epstein's itinerary by email to Ms. Pinney at the same
email address that he had previously used to transmit his messages successfully. See Exhibit 3. All of
the required information, including the required information for international travel, was included in
that email.
Six (6) days after Mr. Epstein emailed his Febrnary 16, 2019 travel notice, and three (3) days after M.r.
Epstein had been detained and refused entry to the Dominican Republic, Mr. Epstein received a
response from Ms. Pinney. By email on February 22, 2019 at 9:11AM (EST), Ms. Pinney advised that:
I am only now responding because I have been out of the office. Please note that an
appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there ,vill be Investigators that
can assist in my absence.
Also, I have not received your travel details. As you are aware these details must be
provided prior to your departure. Please provide by the end of business day.
See Exhibit 4. Five (5) minutes later, at 9:16AM (EST), Mr. Epstein re-sent to Ms. Pinney the email
travel notice that he sent on February 16, 2019 and copied Attorney Indyke on the email he resent.
See Exhibit 5. Ms. Pinney responded by email at 9:43AM (EST) that she searched her emails and
could not find Mr. Epstein's original February 16, 2019 email travel notice. See Exhibit 6. However,
Ms. Pinney did receive Mr. Epstein's February 18, 2019 email and Mr. Epstein's 9:16AM (EST) email
on Febmary 22, 2019. See the email chains in Exhibits 4 & 6. Ms. Pinney also stated that:
In the future, cc SOR Investigator Augustin to assure that the travel details are
received. Agent Augustin has been cc'd in this email. Also, you are required to report
on March 11 ,h after your return to the USVI on March 9th to complete your yearly
registration.
See Exhibit 6.
In light of Ms. Pinney>s advice that she had not received Mr. Epstein's emails, Mr. Epstein inquired
as to whether she had received Attorney Indyke's February 21, 2019 email regarding the changes to
Mr. Epstein's travel itinerary. Mr. Epstein sent Ms. Pinney four (4) separate emails on February 22,
2019 asking for confirmation that Attorney lndyke's February 21, 2o-J 9 email had been received. Both
Attorney Indyke and Agent Augustin were copied on all of them. See Exhibits 7, 8, 9 & 10. Attorney
Indyke received each of these emails at the time they were sent to Ms. Pinney. Attorney Indyke also
sent emails to both Ms. Pinney and Agent Augustin on February 22, 2019, which included a copy of
the February 21, 2019 email Attorney Indyke sent to Ms. Pinney. See Exhibits 11 &, 12. Three (3)
days later, on February 25, 2019, Ms. Pinney emailed Mr. Epstein that she had not received any notices
from Attorney Indyke. See Exhibit 13. However, none of the emails sent by Attorney Indyke, or for
that matter by Mr. Epstein, during the February 16, 2019 to February 28, 2019 period were returned
as undelivered by the DOJ's email server, and Attorney Indyke and Ms. Pinney have communicated
successfully by email for years.
Exhibit
s. S. Pinney
Territorial Sexual Offender Registry Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you that I will travel by private aircraft, N212JE, on February 19, 2019 for a
day trip to Puerta Plata, Dominican Republic. I expect arrive at Gregorio Luperon
International Airport in Puerta Plata, Dominican Republic at approximately 1 :OOPM local time,
and to travel by private aircraft, N212JE, that same day to my vacation home in Palm Beach,
Florida. I expect to arrive at Palm Beach International Airport In Palm Beach, Florida at
approxfmately 6:45PM local time on February 19, 2019 and to stay at my vacation home in
Palm Beach, Florida until February 22. 2019. On February 22,. 2019, I plan to travel from my
vacation home in Palm Beach, Florida to my vacation home in New York, New York, where I
expect to stay until February 28, 2019. On February 28, 2019, I plan to travel by private
aircraft, N212JE, from my vacation home in New York, New York to my vacation home in
Paris, France. I expect to arrive at Le Bourget Airport in Paris, France at
approximately 7:30PM local time on February 28, 2019 and to stay at my vacation home in
Paris, France until March 9, 2019. On March 9, 2019, I plan to return by private aircraft,
N212JE, from my vacation home in Paris, France to my permanent residence in the U.S.
Virgin Islands. I expect to arrive at Cyril E. King International Airport in St. Thomas, U.S.
Virgin Islands on March 9, 2019 at approximately 1:OOPM local time. While traveling abroad,
I can be contacted on my mobile telephone number at 212-533-3739. In addition, I can be
contacted-siness office at 340-775-2525 or through my attorney, Darren K.
lndyke, at . I will email your office upon my return to the U.S. Virgin lslands on
March 9, .
If you need any further information, please also feel ~ o m e y , Darren K. lndyke
at ,r on his mobile telephone n u m b e r - -
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
plaasenote
The lnfwmallon contained in this communle81Ion Is
conlldanlial, may be attorney-client l)ltvile9ed. may
constitute Inside Information, and is Intended only for
the use ol tha acklressee. II la the property ol
JEE
t.Jnauthorltad use, cbclosure or copying of this
communk:&tlon or anv oart thereof it strlctlv orohlbltad
Exhibit 2
Ms Piney , i am on Island unlil tues at noon , and wll not return to the territory untl the 20th of march, my raglslrallon date is
mardl 5 • woudl you l]fefer I wait until my retum or would you pmer I come In tues momng. lhll,
please note
The informalfon contained In this communlcaUcn Is
conlldentlal, may be attorney-diem prMleged, may
constitute lnlSlde lnfotmalion, and Is Intended on!y for
the Ute of !he addressee, It is the property ol
JEE
Unaulhorlzed use, dtdoaure or copying ol lhls
communlcalion or any part thereof is strictt, pll)hl)ited
and may be unlawful. II you have received this
communication in erro,, please notlty us Immediately by
return a-mall or by e-maff to teeyacation@grnajtcorn, and
destroy thts oommunlcallon and all copin thereof,
including all attachments. eopyrlght ·all rights reserved
Exhibit 3
Ms. S. Pinney
Territorial Sexual Offender Registry Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. Mr. Epstein will stay at
his vacation home in Palm Beach, Florida until February 24, 2019. On February 24, 2019,
Mr. Epstein plans to to travel from his vacation home in Palm Beach, Florida to his vacation
home in New York, New York, where he expects to stay until February 28, 2019. On
February 28, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in New York, New York to his vacation home in Paris, France. He expects to arrive at
Le Bourget Airport in Paris, France at approximately 7:30PM local time on February 28, 2019
and to stay at his vacation home in Paris, France until March 9, 2019. On March 9, 2019,
Mr. Epstein plans to return by private aircraft, N212JE, from his vacation home in Paris,
France to his permanent residence in the U.S. Virgin Islands. He expects to arrive at Cyril E.
King International Airport in St. Thomas, U.S. Virgin Islands on March 9, 2019 at
••i
approximately 1:OOPM local time. While traveling abroad, he can be contacted on his mobile
telephone number at 212-533-3739. In addition, he can be contacted through his business
office at 340-775-2525 or through me at Mr. Epstein will email your office
upon his return to the U.S. Virgin Islands on March 9, 2019.
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
DARREN K. INDYKE
.....................................................................................................................................................
The Information contained in this communication Is confidential, may be attorney-client
privileged, and Is Intended only for the use of the addressee. It Is the property of
Darren K. lndyke. Unauthorized use, dlSclosure or copying of this communication
or any part thereof is strictly prohibited and may be unlawful. ff you have received this
communlcatlon In error, please notify us Immediately by return e-mail, and destroy 1hls
communication and all copies thereof, Including an attachments.
.........................................................................................................
Copyright of Darren K. lndyke - @ 2019 Darren K. lndyke - All rights reserved .
,...
Exhibit 4
Good Day.
I am only now responding because I have been out of the office. Please note that
an appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators that
can assist in my absence.
Also, I have not received your travel details. As you are aware these details must
be provided prior to your departure. Please provide by the end of business day.
From: J <jeevacation@gmail.com>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subject:
Ms Piney , I am on island unit! tues al noon , and will not return to 1he terrtto,y until the 20th of march, my registration date la
march S , woudl you prefer I wait until my retum o, WOCJld you prefer I come In tues momng. lhx,
please note
The inlomlation contalned In this communc411on is
conlldentlal, may be attomey-dient privileged, may
oonatllute Inside lnlormallon, and is intended only tor
lhe use 01 the addressee. It ls the property of
JEE
Unauthorized use, ciscfosure or copying of this
eommllnication or any part thereof is sb'k;tty prohibited
and mey be unlawful. If you have reoelved this
communication in enor, please notify us Immediately by
return e-mail or by e-maH to ieevacatjon@gmall.com. and
destroy this communication and al copies thereof,
Including an attachments. copyright -all rights reserwd
please note
The lnlormatlon contained In this communlc:atlon la
oonfidentlal, may be attomey-dient priYlleged, may
oonstilute inside illtormat!on. and Is I.mended only for
the use of the addre"". It Is the property of
JEE
Unlltllhortzed use, !l&dosure or copying ol thb
communication or any part lhereol Is strictly prOhiblted
and may be unlawful. If yov have received tills
communlcallon In error, please no1ify us Immediately by
retum e-mu or by e-mail to jeeyar:alion@gman,com. and
d861roy this communication and al copies thereot,
lnducllng a• attactvnents. copyright -all righls reseNed
Exhibit
pie
s. S. Pinney
Territorial Sexual Offender Registry Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you that I will travel by private aircraft, N212JE, on February 19, 2019 for
a day trip to Puerta Plata, Dominican Republic. I expect arrive at Gregorio Luperon
International Airport In Puerta Plata, Dominican Republic at approximately 1 :OOPM local
time, and to travel by private aircraft, N212JE, that same day to my vacation home in Palm
Beach, Florida. I expect to arrive at Palm Beach International Airport in Palm Beach,
Florida at approximately 6:45PM local time on February 19, 2019 and to stay at my
vacation home in Palm Beach, Florida until February 22. 2019. On February 22., 2019, I
plan to travel from my vacation home in Palm Beach, Florida to my vacation home in New
York, New York, where I expect to stay until February 28, 2019. On February 28, 2019, I
plan to travel by private aircraft. N212JE, from my vacation home in New York, New York to
my vacation home in Paris, France. I expect to arrive at Le Bourget Airport in Paris, France
at approximately 7:30PM local time on February 28, 2019 and to stay at my vacation home
in Paris, France until March 9, 2019. On March 9, 2019, I plan to return by private aircraft,
N212JE, from my vacation home in Paris, France to my permanent residence in the U.S.
Virgin Islands. I expect to arrive at Cyril E. King International Airport in St. Thomas, U.S.
Virgin Islands on March 9, 2019 at approximately 1:00PM local time. White traveling
abroad, I can be contacted on my mobile telephone number at 212-533-3739. In addition, I
can be contacted throllilh m business office at 340-775-2525 or through my attorney,
Darren K. lndyke, at I will email your office upon my return to the U.S.
Virgin Islands on Marc , .
Please confirm by reply email to me your receipt of this email. Thank you. Ms. Pinney.
Aespectfully,
please note
The Information contained In this communication is
conlldenllal, may be attomey-dlenl privileged, may
constitute Inside Information, and Is Intended only for
the use of the addressee. It Is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof ls striclly prohlblted
and may be unlaWh.11. If you have received this
communication In error, please notify us immediately by
return e-mail or by e-mail to !eevacalion@gmall.com. and
destroy this communloalion and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The lnfonnatlon contained In this communication Is
oonfldenllal, may be attomey•dlent prMleged, may
oonstltule inside lnlormation, and Is intended only for
lhe use of the addressee. II Is the property of
JEE
Unauthorized use, disclosure or copying of this
communicallon or any part thereof Is strictly prohibited
and may be unlawful. II you have received this
communication In error, please nolify us Immediately by
return e-mall or by e-mail lo ieevac:alion@gmail.cy;,m, and
deslroy this communication and all ooples thereof,
Including all attachments. copyright -alt rights reserved
please note
The information contained in lhts communication Is
confidential, may be attomey•cllent privileged, may
oonstilule Inside Information, and ls Intended only for
lhe use ol the addressee. It Is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof Is strictly prohibited
and may be unlawful. If you have received this
oommunlcallon in error, please notify us Immediately by
return e-mail or by e-mail lo leevocaUon@gmail.com, and
destroy this communication and all copies thereof,
Including all attachments. oopyrlghl -all rights reserved
Exhibit
From: J 1e11vacation~•gma1Lcom ,
Subjec t: Fwd: Aeglstta11on & Travel
Olli&: Febnlluy 22, 2019 at 9:49 AM
To: Darren lndyl<e
Thank you.
I searched my email and I did not receive lhis or any correspondence from you on
the date February 16, 2019 as indicated in your attachment. In the future, cc SOR
Investigator Augustin to assure that the travel details are received. Agent Augustin
has been cc'd In this email. Also, you are required to report on March 11th after
your return to the USVI on March 9th to complete your yearly registration.
From: J <jeeyacat;on@gmajt.com>
Sent; Friday, February 22, 2019 10:19 AM
To: Shani Pinney
-.......
Subject: Re: Registration & Travel
.,_ ,. ......".........
...
.....,......,.., .,._.....,..~
•·s. rw.y
rom- s.....1Otrll!Mr Rllol"'Y .. " ' -
1/llgin lalondl O o p , - o f -
- Slolot "111• lalldt
O.,Mo. PIMIY:
Vo,t,--,
..,,__,,,,,20.. .,., .. ...,_..,, .... """"11......
"'-1a - . - ...... -.i111;c . , 1lOOPM -lho, . . . . n ffl l l y ~ - •Jrcn~ N21UE.1Nlu. . ,.., .. . . , , . - - "'I'm - di. F1o<ldL , _ IO .....
--Ai,po,t.-P1111 8-.Flondaal..,,....,,_, _ _ _ 1ioo ...... .. , _ _ ,_,,u21111
0n,ebtullf 2Z., 2018, I P""10- -my•...iion-lo l'IIIIIIIHdt, H,,..,1o,_,_ ,_,, In_ -.1 - IIO Ulll'--IIYH, 2011. On hlw
201t. ljllaftlon ..l bJp,l,aalrmlt.N21lle. .... ,..,--i..Hew'lblll--lO..,,,....UOnhome ... P'n,,,.,_, ,_. ......... i..llo\llgelAl,fonln.Parlt.F-
-lftt-.
on F-..y M. ?Olt .. 10 "'7 • m, wmuon ...... In ""'11, , _ - Ml/II': 11, 2011. 0,, -9. 20\8.1 pion kl ....... by pm• -
--•In''"'-
-l<llnllllY 7:30PM - - NllaJE,
op,.,-,,y 1:00PM--. -
Fq - 10 "1'/ -nonl - In lie US. ~ii llla"'1o . 1 - 1 0 -
I oanbec.o,.ltm<lon ,,,, _ . . , . _ nuo,1'"01
t i C\'111 £. lnlolMUal\fl
l f t - n , I CMbo _ . . . . . . , "11.......,....,.
In II. - •• U.S , 'lllrgln ....!Ids on - I , 2(
al '!O:U ii:2SZ$"' ~'°""',_,.-..,. o...ntt 1"f)t,I. • · · - ..- ...,tilyoo, - -" " 1 -IOh U.S. ~ 1- ... - t. Z!lli,
I am only now responding because I have been out of the office. Please note that
an appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators
Also, I have not received your travel details. As you are aware these details must
be provided prior to your departure. Please provide by the end of business day.
From: J <Jeevacation@gmail.com>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subject:
Ms Piney , I am on Island until tues al noon , and will not return lo the territory until the 20th of march, my registration date Is
march 5 , woudl you prefer i wall until my return or would you prefer i come In tues mornng. thx,
please note
The Information contained in this communication Is
conlldenllal, may be attorney-client privileged, may
constitute Inside information, and Is Intended only for
the use of the addressee. It Is the property ot
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. II you have received this
communication In error, please notify us Immediately by
return e-mall or by e•mail to ieevacallon@gmall.cqm. and
destroy this communication and all copies thereof,
Including all attachments. oopyrlghl -all rights reserved
please nole
The information conlalned In this communication Is
confidential, may be attorney-client privileged, may
constitute Inside information, and Is Intended only for
the use of the addressee. II is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. II you have received lhls
communication In error, please notify us Immediately by
return e•mall or by e-mail to iuvacalion@gmelLcom. and
destroy this communication and all copies thereof,
Including all attachments. copyright -all rights reserved
please nole
The Information contained In this communication Is
confldential, may be attorney•cllent privileged, may
conslltule Inside inforrnallon, and Is Intended only lor
the use of the addressee. II is lhe property of
JEE
Unauthorized use, di&Closure or copying ol lhls
communication or any part thereof Is slrlctly prohibited
and may be unlawful. If you have received this
communication In error, please notify us Immediately by
return e-mail or bye-mall to jpeyac.Jll!lon@gmall.com, and
destroy this oommunicatlon and all copies thereof,
including all attachments. copyrighl -all rights reserved
Exhibit
please confirm that you have receive the emails I Just sent showing notification Before I left. and you should have additional travel
detalls from attny lnc:lyke • II not, please let me know
I am only now responding because I have been out of the office. Please note that
an appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators that
can assist in my absence.
Also, I have not received your travel details. As you are aware these details must
be provided prior to your departure. Please provide by the end of business day.
From: J <jeevacation@gmail.com>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subject:
Ms Piney , I am on Island until tues at noon , and will not return to lhe territory unlil lhe 20th of march, my registration dale Is
march 5 , woudl you prefer I wait until my return or would you prefer I come In tues mornng. thx,
please note
The Information contained In this communication Is
confidential, may be attorney-client privileged, may
constitute Inside Information, and Is Intended only for
the use o1 the addressee. It is the property ot
JEE
Unauthorized use, disclosure or copying of thls
communication or any part lhereo1 is strldly prohibited
and may be unlawful. If you have received lhls
communication In error, please notify us lmmedlately by
relum e-mail or by e-mail to ieevacaljon@gmail.com, and
destroy !his communication and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The Information contained In this communication Is
confidential, may be attomey-cllent privileged, may
constitute Inside lnfonnation, and Is Intended only for
the use of the addressee. It Is the property of
JEE
Unauthorized use, disclosure or copying ol this
communication or any part lhereof Is strlclly prohibited
and may be unlawful. If you have received lhis
1XJmmunication In error, please notify us lmmedfalely by
return e-mail or by e-mail to ieevacation@gmail.com, and
destroy this communication and all copies thereof,
Including all attachments. copyright •all rights reserved
Exhibit I
did you recleva attny lndykts new notice .? and may I have a numb&r on which you can be reached this afternoon.
On Frl, Feb 22, 2019 at 9:43 AM Shani Plooey <Shani Ptooev@vl,gop wrote:
Thank you.
I searched my email and I did not receive this or any correspondence from you
on the date February 16, 2019 as indicated in your attachment. In the future, cc
SOR Investigator Augustin to assure that the travel details are received. Agent
Augustin has been cc'd In this email. Also, you are required to report on March
11th after your return to the USVI on March 9th to complete your yearly
registration.
From: J <jeevacation@gmaU.com>
Sant: Friday, February 22, 201910:1 9 AM
To: Shani Pinney
-
Subject: Re: Registration & Travel
-s.-~~~--
.....:-.,.. ....20"•4:Jt,,.
, . ...,...,_,. C v.-,.._.~._...,,,.,.0-,.,.,.•
a. 8. PIMtr
~h-Dopa,111111'11(11""'1Jol
Ullilod - .. .,_,
'1111111 IO ..... M )OU11>oll ..at,,_ i,,.,..,... - Nlt2JE, ...,r111N11y 1t, 201tlor I f0,,111> ll> l'ultfa -
Pf.........,
Dodrkan R ~. I - ll1MI otO,....to
PI.-Pllla,Donnal•~ .. •Pll'W.-Yl:llOPM .,.i llrN,...,to_by _ _ ft,H211JE, f l l l l , - f t y t o o , r - - l n P D , - . - ·
8-l, l o l , _ ililportln Pllln 1-._ rtoriolo 11 ...
On"""-Jtt..201t,1_., _ _ "'1 _ _
1:45PM local-on F..._,. It, 201t end 11> """•,,,, _homltn Polm h,ci,, , - 1111111 F~
i,,....,-,,-.. "'1'--h-'l'o,t,Nr,,Yo1t,_..1_,i1oo1tyll0ll~2t. 2018. OnFo
f-l0-
. . 11111,,,10o,111A
21. 2019,
.,,.....--1n-.
my-•-
2019,I ..... IO_l ..,,pm1io8'nll,Hlll.lE,IIOmffil'.-,-ill_'rbttl, llow_ lo..., _ _ tn P-,1,.F._, 1-IO-oti..a..,ti~lnl'oril,F,...
1;3oPM loal - Oft F~ 28, 2019""" IO ""'W OI
'°'"1'1>4,,,,.,_,._ ,..,...to_ FtlNl0 - - 1, 20,t, On - t. 2019, I ..... lonluffl i1f ptMt• ..... N212JE,
11 C)oi F.. 1Cit'9 -Altpc,ttloSI. -0-1, U.S. ~ I - o n - t. :X
tMTST""' _
- - • Pw. F,..... IIIIM U.S 'llllp 1 -.
1
l:OOPll -llmL -1"""""9 - • _,...,.,_11ti!Z:lla:mJ, .., _ , l<aAINl-.......
ll~~o,illlou!llt" ' l ~ °"'""K,inlli,loe. .- - .,._,,-._, ,,,y-tc,'11IJ.S,Vi'g"'itllnds°"Maldlt, 201f.
I am only now responding because I have been out of the office. Please note
that an appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators
that can assist in my absence.
Also, I have not received your travel details. As you are aware these details
must be provided prior to your departure. Please provide by the end of
business day.
From: J <jeevacation@gmail.com>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subject:
Ms Piney , I em on Island until tues al noon , and will not return to the territory until the 20th of march, my registration date
Is march 5 , woudl you prefer I watt until my return or would you prefer I come In tues momng. thx,
please note
The information contained In this communication Is
confidential, may be attorney-client privileged, may
constitute Inside Information, and Is intended only for
the use of the addressee. It Is the property of
JEE
Unauthorized use, disclosure or copying of lhis
communication or any part thereof is strictly prohibited
and may be unlawful. II you have received this
communication In error, please nollfy us lmmedlately by
return e-mail or by e-mail to leevacalion@gmail.com, and
destroy this communication and all copies thereof,
Including all attachments. copyright -all rights reserved
please note
The Information contalnad In 1hls communication Is
conlldential, may be attorney-client privileged, may
constitute Inside Information, and Is lnlended only for
lhe use of the addressee. It Is lhe property of
JEE
Unaulhorlzed use, disclosure or copying of this
communication or any part thereof is stlictiy prohibited
and may be unlawful. II you have received this
communication In error, plesse notify us Immediately by
return e-mail or bye-mall to iee;vaca!lon@gmail.com, and
destroy this communication and all copies thereof,
Including all attachments. copyright -all rights reserved
please note
The lnformallon contained In this oommunlcatlon ls
confidential, may be attorney-client privlleged, may
constitute Inside Information, and Is Intended only for
the use of the addressee. II ls the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof Is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jQeV§9!tloo~mJll,~m, and
destroy lhls communication and all copies thereof,
including all attachments. copyright -all rights reserved
Exhlbh
please confirm receipt of thlls email. th1: s1ill no answer on phone at 340 n4 5666
.....................................................................................................................
The tnformation contained in this communication Is confidential, may be attorney-client
prMteged, and Is Intended only for the use of the addressee. It Is the property of
Darren K. lndyke. Unauthorized use, disclosure or copying of this communication
or any part thereof is strictly prohlblled and may be unlawful. If you have received this
communication In error, please notify us lmmedlately by return e-mail, and destroy this
communication and all copies thereof, Including all attachments.
........................................................................................................................................ ..............
Copyright of Darren K. lndyke • @ 2019 Darren K. lndyke - All rights reserved .
Ms. S. Pinney
Territorial Sexual Offender Registry Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. Mr. Epstein will stay at
his vacation home in Palm Beach, Florida until February 24, 2019. On February 24, 2019,
Mr. Epstein plans to to travel from his vacation home in Palm Beach, Florida to his vacation
home in New York, New York, where he expects to stay until February 28, 2019.
On February 28, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his
vacation home In New York, New York to hls vacation home in Paris, France. He expects
to arrive at Le Bourget Airport in Paris, France at approximately 7:30PM local time
on February 28, 2019 and to s1ay at his vacation home in Paris, France until March 9,
2019. On March 9, 2019, Mr. Epstein plans to return by private aircraft, N212JE, from his
vacation home in Paris, France to his permanent residence in the U.S. Virgin Islands. He
PYl'\Pl"tc: tn ;:irri11oe> ;:it r.11ril F Kinn lnt.,.rn::ltinn::11 Aimnrt in Rt Thnmi:1<: 11 R \lirnin lc:l~nri<i nn
...,,.,,.......,...,.,- •- - • •••- ...... -. -J ••• -• . .. ,.,.l:J ••~ ...... • ••-•·~-• •- • • ... ,....., • ., ••• - •• • ••-•••-...,, - •- • • n::1••~ •-•-••-"-' Y••
March 9, 2019 at approximately 1:00PM local time. While traveling abroad, he can be
contacted on his mobile telephone number at 212-533-3739. In addition, he can be
contacted through his business office at 340-US-2525 or through me a Mr.
Epstein will email your office upon his return to the U.S. Virgin Islands on March 9, 2019.
If you need any further information, please feel free to call me at ron my
mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
DARREN K INDYKE
. . . .. . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 • • • .. . .. . ............ ,. • •
please note
The Information contalned In 11n communication la
CQllfldemtal, may be attomey-dlent privileged, may
constitute Inside inlonnallon, end Is Intended only !or
the use of the addressee, HIs lhe prope,ty of
JE'E
Unauthorized use, dlsclowre Of c:cpylng of this
commutllcallon or any part thereof Is stric1ly prohlbiled
and may be unlawful. If you have received this
communication In error. please notify us immediately by
retum e-mail or by e-mail to 1eevaca1ion@gmat1.com. and
deslroy 1hls communleallon and al copies thereof,
including al attachments. copyright -all rights res8IVed
Exhlbll 1(
- - · -Forwaroed meesage - -
From: J <ieevacatjon@gmau £Q!!!:>-
oa1e: Mon, Feb 25, 2019 at
Subject: Re: ReglstraUon & Travel
To: Shani Pinney ~ X . ~ .
I searched my email and I did not receive this or any correspondence from you
on the date February 16, 2019 as indicated in your attachment. In the future, cc
SOR Investigator Augustin to assure that the travel details are received. Agent
Augustin has been cc'd in this email. Also, you are required to report on March
11th after your return to the USVI on March 9th to complete your yearly
registration.
From: J <jeevacatlon@gmail.com>
Sent: Friday, February 22, 2019 10:19 AM
To: Shani Pinney
-
SUbject: Re: Registration & Travel
0.:1&-11,,lt1t•utll'
...... ,.,..~llloS....,..0-.-....,... ~ ~ ~ , .,
a.S,PiMor
Wgll\- ~,.,~
U-9111111.....,_
1No is lo ..... l'OU lhlll ... nwley---. NZ12.ll!. Oft F4tin,a,y 11, 2011 lo,. -,-.lo
"'-1'111•. DomWa,,,rt.,d,k • - - 11 G-"'
,,_al~l:4-
Puo,1lflolt.-Alp\lblicd~1-Mlocollifflt,lfld"'"""""',.-.-11.N:112Jll!,N1 -<ltyloflf1_...,_iol'aim-. - luoedlO-
lold>-AApol1 ., ,.,. _ - - O f t f " " " ' ) ' 19, 201'.,.IOl'°l'M...,. _ _ ln P.... - . l'lorida-FffNOly 22. 2011
OnF'o1>1uo1y:U_ 201t. 1.,....,,.__,,,.._...._lnl'llm_, _ l o l l l f - - l n - ' l b l l l. -Yat1r.-.1_00...,""1~:ll. 20IL OnF111
Ott-••
201a1p11111o-1,Jprioa-HtlUE, _ . . , _ . . , _ l n N_ _ _ _ _ ,...., _ _ k _ f _, ...pocl .. _Oluac..,,.Mpor11nl'otis, f..,.
lo
_ . _ _ , 7:30PM- - Oft F.-,y U , 20lt ond !lo)' O l t n r - - lo Poria,F,- tffllil-t. 2011,
- -ln ""'°•-I0"'1.,..._1 __ ..... U.$.W,i;,t -
201', I ...... , . _ ..,.....,.wcnll.lQl2JE,
. 1-IO-OICJ'flll.~-Ai,po,tlnll,-_U.$. Vwp,1_..,_t,:lo
RtllllCdJlly.
p,rr. .......,.........................,...,.....
I am only now responding because I have been out of the office. Please note
that an appointment is not needed to fulflH your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators
that can assist in my absence.
Also, I have not received your travel details. As you are aware these details
must be provided prior to your departure. Please provide by the end of
business day.
From: J <jeevacation@gmail.com>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subject:
Ms Piney • I am on lalend until lues at noon , end wlll not ratum 10 lhe territory untll the 20th of march, my ragigtrallon
dale Is march 5 , woudt W'OIJ p,eter I wait until my return or would you prefer I come In tuas momng. thx,
please note
The Information oonlelned In lhls oommunlcallon Is
oonftdanlial, may be allomev-dlent privileged, may
constitute lnelda Information, and rs Intended only tor
the uae ol th& addresffe. Hla the property ot
JEE
Unauthorized use, dlscloeure Of copying of Ihle
communication or any part tl'lereol is strlcily prohibited
and may be unlawful. If you have n,celved this
communication In error, please notify us lrmieclalaly by
retum e-mell or by e-mal to leevaca11on@gmail.com, end
destroy lhls c:ommunlcallon arid all cop!es thereof,
Including all altachmenls. copyright -ell nghls reserved
please note
The lnlormallon conlained in this communication la
COflfldentlel, may be attomey-ctlent ptivileged, may
conetllute Inside Information. and Is intended only for
the use of the addl'a•sH. It Is lhe property of
JEE
Unailhorlzed use. dlsclo5ure Of copying of this
communication or any p111 lhereol ls $ll1CU)f prohlbMe<I
and may be unlawM ff you have received this
communication In en-or, please notify ue lmmedlately by
return e-maU or by e-mail to jeevaca1jon@gmaa.com. and
destroy fib communication end all oople9 lheraof,
Including all altactvnenlS. copyrlghC -all t1gh1s reserved
pleuenote
plaasanote
The Information contained In lh!s communication fs
conlldentlal, may be attorney•cfient privileged, may
conslilUte Inside Information, and is lntended only for
lhe use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or cop~ng ol lhis
communication or any part thereof Is strictly prohibited
and may be unlawful. If you have recelved lhls
communication In error, please notify us Immediately by
retum e-mail or by e-mail to ieevacallon@gmall.oom, and
destmy tilts communication and all copies !hereof,
including all attachments. copyrlghl •1111 rights reserved
please note
The Information contained ln this communication Is
oonflclenlial, may be attomey-crienl privileged, may
constitute instde Information, and Is intended only for
the use of the addressee. n rs the property of
JEE
Unauthorized use, disclosure or copying of this
c:ommuntcatlon or any part thereof is strictly prohibited
and may be unlawful. ti yoo have received this
communication in em:1r, please notify us immediately by
return e-mail or by e-maY to iee11m;ailon@gmail.com, and
deskoy this communication and an copfes thereof,
including an attachments. copyright -an rights reserved
Exhibit
From: Darrentndyk•-
Subject: Fwd: Mr. Jeffrey
Date : February 22, 2019 al 12:15 PM
To: shani.pinney 1~v• gov, SPlnney spi1111eyii, 101 ,,ig,l41
Cc: Darren Indy
Good day, Ms. Plnnney. Hope you are we11. Can you please conllrm recelpt of my emall below.
lhankyou.
DARREN K. INOYKE
..........................................................................................................
The Information contained in this communlcation is confidential, may be attomey•client
privileged, and Js intended only for the use of the addressee. II ls the property of
Darren K. lndyke. Unauthorized use, disclosure or copying of this communication
or any part thereof Is strictly prohibited and may be unlawful. If you have received this
communication In error, please notify us Immediately by retum e-mail, and destroy this
communication and all copies thereof, Including all attachments.
Copyright of Darren K. lndyke • © 2019 Darren K. lndyke - All rights reserved .
...............................................................'11 . . . . . . . . . . . . . . . . . . . . . . . . . . .t t ................................................... .
Ms. S . Pinney
Territorial Sexual Offender Registry Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. Mr. Epstein will stay at
his vacation home in Palm Beach, Florida until February 24, 2019. On February 24, 2019,
Mr. Epstein plans to to travel from his vacation home in Palm Beach, Florida to his vacation
home in New York, New York, where he expects to stay until February 28, 2019. On
February 28, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in New York, New York to his vacation home in Paris, France. He expects to arrive
at Le Bourget Airport In Paris, France at approximately 7:30PM local time on February 28,
2019 and to stay at his vacation home in Paris, France until March 9, 2019. On March 9,
2019, Mr. Epstein plans to return by private aircraft, N212JE, from his vacation home in
Paris, France to his permanent residence in the U.S. Virgin Islands. He expects to arrive at
Cyril E. King International Airport in St. Thomas, U.S. Virgin Islands on March 9, 2019 at
approximately 1 :00PM local time. While traveling abroad, he can be contacted on his
mobile telephone number at 212-533-3739. In addition, he can be contacted through his
business office at 340-775-2525 or through me at - - Mr. Epstein will email
•·-··•• - U: . , - , ., _ _ _ L..l- - -• •• .. - ,._ .t.l.. ... I I,-... ' ' -•• - : - t - 1 - - -A- - - ••-•-&.. n l"'I.J'\411'\
yuu1 Ulllt;~ uµv11 llll) 11:tlUIII lV lllt/ u.-:>. v11y111 l~ll:lllU~ Oii lVU;tH,;11 -::,, .c:v1::,.
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
Exhibit 1
At Ms. Shani Pinney's direction, I am forwarding a copy of the travel modification notice for
Mr. Jeffrey Epstein that l emailed to Ms. Pinney yesterday. Please kindly confirm receipt of
this notice. Thank you.
Respectfully,
............................................ ..............................................................
_
The informa11on contained In this communication Is confidential, may be attomey-cltent
privileged, and is intended only for the use of the addressee. HIs the property of
Darren K. lndyke. Unauthorized use, disclosure or oopylng of this communication
ot any part thereof Is strlcUy prohibited and may be unlawful. If you have received this
communication In error, please notify us Immediately by return e-mall, and destroy this
communication and all copies thereof, including an attachments.
....................................................................................................................
Copyright of Darren K. lnclyke - © 2019 Darren K. lndyke - All rights reserved .
Ms. S. Pinney
Territorral Sexual Offender Registry Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans. Mr. Epstein will stay at
his vacation home in Palm Beach, Florida until February 24, 2019. On February 24, 2019,
Mr. Epstein plans to to travel from his vacatron home in Palm Beach, Florida to his vacation
hnm,:, in Ni:>u1 Vnrlc l\li:>1A1 Ynrk wh,:,r,:,. hi:, ,:,vn,:,,-t~ tn ~t~\I until J:i:>hrw:m, ?A ?01 Q nn
··-···""' ..... - ... . ........, ' ........ ·-·••1 ·••t....,, ..... ..... -, .. ,... _._.. ..... ............-, ..... .... . ...,...,,,¥_•, _...,, _..., ..... -··
February 28, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in New York, New York to his vacation home in Paris, France. He expects to arrive
at Le Bourget Airport in Paris, France at approximately 7:30PM local time on February 28,
2019 and to stay at his vacation·homeiriPans;France un1u·March9, on March§, ····· 2onr
2019, Mr. Epstein plans to return by private aircraft, N212JE, from his vacation home in
Paris, France to his permanent residence in the U.S. Virgin Islands. He expects to arrive at
Cyril E. King International Airport in St. Thomas, U.S. Virgin Islands on March 9, 2019 at
approximately 1:OOPM local time. While traveling abroad, he can be contacted on his
mobile telephone number at 212-533-3739. In addition, he can be contacted through his
business office at 340-775-2525 or through me at Mr. Epstein will email
your office upon his return to the U.S. Virgin Islands on March 9, 2019.
Ptease confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
DARREN K. INDYKE
Exhibit 1~
From: J 1eevaca!icnf/i,9roai1.corn /;
Subject: Fwd: Registration & Travel
Date: Februa
· ry2_.
To: Darren Ind
--·-··Foiwarded messege - -- ·
Ffom: Shani Pfnnev <ShaQi,PiOtlll.YlflYl~
Oate: Mon, Feb 25, 2019 at!;!19 AM
~ : Re: Reglstrallon & T1avel
To: J ,qeevacation@gmall.com>
Good Morning,
On Fri, Feb 22, 2019 at 9:43 AM Shani Pinney <Shapl PjQQ8Y(!vf.qov> ffl018:
Thank you.
I searched my email and I did not receive this or any correspondence from you
on the date February 16, 2019 as indicated in your attachment. In the future, cc
SOR Investigator Augustin to assure that the travel details are received. Agent
Augustin has been cc'd in this email. Also, you are required to report on March
11th after your return to the USVI on March 9th to complete your yearly
registration.
From: J ~eevacatjon@gm@iLCQtn>
Sen1: Friday, February 22, 2019 10:19 AM
To: Shani Pinney
-
Subject: Re: Registration & Travel
P-
o.:-w,-,t.an,~u,,..
, . .. . . , , f t - . ~ . . , - ..0 . . . . ~ " ( I J ~ t t -
, . $,PiMoy
1 -Sbwll Oft'..-11<191111y Man111tt
~-dl~IOl.lu1fcol
Uniltd si.1.. V1o;ln • -
O..tMo,PIMey.
~-11-,,.
Puerll l'lela. llcwrM\ar,Rept,l,llc ol l1IOl'II - - . lfld IO-by p,t,ala N212Jl!. lhol- dl,ylo my .,.calc,n - ;n hlo!l lle.l<lt,Florida. 1 ~ lo -
l!eod> lmomo-11 Al'l'O'l ln p.,,, Florido ol _..,_t:45PM locol- on F-,. 1e, 201, , ..... Oi.11111 ..,.,...!loft_ In - Be- ,-...u,r.,._ U . ~I~,
On i r - , . n_.1019.I_IO _ _ ,,,, _ _ lnP•lt>l-, f'IMdalol'IO)'_t,_hNow'itfl<. _ _ _ ..,,,rel_ lO _IU\IIIFollftlt,yZl,2019. O,,fobli
t.,..,,
:ll>lt , lo _ b y pdoata aircna tq!UE, - fflf _ , , _ In NH '11n, NtwYOl1' to 01)'--•lnll'al!,, l'nra. 1 - I O - • al IA 8Gurv,r1 Al- 1/1 Ptltl, Fn,,.
a , ~ 1:30PM-l - on FttNMy te, 2019 and 10 UOy ti my...,.... ,_,, In f'w. ,,_ uNJ M- 9, 2019, 0. - t. ~11. I Iii"' IO IIIW1' I,)' pii,w oioulJl.,NZt:t.lE,
- ,-111 ""1&. F - IO my Pl,_,,.ftl ....- .. ~u.s. 'IIIIQIO ltlandt. r._i .. . -., f . King l• --UonalAltportln SI.-·u.s, Ill..~ - ... - ,.. a(
_ , . , ; ~ IJOOPM-- WW.IIIYIJill;-. l ~ o n " ' Y , _ ~ . . , m b o t a t ~. . , - . . ,, lctn .,_..,.._._,lhm,!Mln... -
11 "'._,..."¥-..,, DtnonK. - - - ~ p o n f f l l ' _ IO..., U,S " " ' " ' - . on Ma,rMI, 201',
I am only now responding because I have been out of the office. Please note
that an appointment is not needed to fulfill your registration obligation.
In the future, report in person to 0OJ to register and there will be Investigators
that can assist in my absence.
Also, I have not received your travel details. As you are aware these details
must be provided prior to your departure. Please provide by the end of
business day.
From: J <ieevacation~gmajtcom>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subject:
Ms Piney , i am on Island un111 tues al noon , and wlft not return lo the tsrritoiy wllil the 20lh of march, my registration date
IS march 5 , woudl YOll prefer I wait unlll my return or would you Jlfel&r I come ln tues momng. thll,
pteaae note
The lnlormatlon con18lned In thlt oommunicatfon Is
confldenllal, may be attorney-client privileged, may
conatilule Inside lnlorma11on, and Is Intended only for
lhe use of the addre8S8e. It Is the propeny of
JEE
Unaulhorlzed use, clsc!osure or copying of lhls
communication or any part lhereof Is strictly prohibited
and may be unlawful. II you have received this
communication In error, please notify us Immediately by
rllllllrn e•mall or by e-maJI IO leevaeatlon@gmail.com. and
dettroy 1h15 communlcalfon and al copies lhereol,
lnc:fuding all attachments. copyright -all rights reaerved
please note
The lnformaUon contained In 1his communication 11
confidential. may be attorney-dent privileged. may
constitute lnelde lnlonnatiol\ and la Intended ort, for
the use of the add:re&&ee. It 181he property of
JEE
Unaulhollnd use, c:lactosure or copying of this
communication or any pan thereof is alrict~ prohlblled
i nd may be unlawful. If you nave received this
communication In error, please notify ua lmmedlalely by
retum e-mail or by e-md to iffvacation@gmall,qom. and
dNtroy Ulla communlcalion and all copies thereof,
lncludlng all allachmanta. oopyrlght •all rlghls r&881Ved
please note
The Information contained in this commun;x:allon is
c:onlldenlial, may be attorney-dent prlvltaged, may
__ ........ &.:-. ....... · - - :...... , .• , ... - ...a t - ...... , ........................... .
please note
The Information contained in lhis communication Is
conlldentlal, may be attorney-client privileged, may
constitute Inside Information, and is Intended only for
lhe use of the addressee. It Is the property of
JEE
Unauthorized use, disclosure or copying of lhis
communication or any part thereof Is strictly prohibited
and may be unlawful. If you have received this
communicallon In error, please notify us lmmedialely by
return e-mail or by e-mail to l§mmcaiion@gmall.com. and
destroy this communication and all copies thereof,
Including all attachments. copyright -all rights reserved
APPENDIX2
Re: Request Pursuant to Bill 29-0239 for Reduction/Approval of Notice Procedures for
Travel Outside the Virgin Island by Jeffrey Epstein
Thank you for meeting with me and Attorney Darren lndyke on Friday, July 13, 2012, to
discuss implementation of the new travel notice procedures for registered sex offenders under
Bill 29-0239 (including the amendment thereto), an Act amending chapter 86 of title 14 of the
Virgin Islands Code, to expand the laws of the United States Virgin (slands regarding the
monitoring and tracking of sex. offenders within this jurisdiction. that has been passed by the
Legislature, and which we anticipate will be signed into law by the Governor in the near future.
As we discussed and has been well.documented with your Department over the past
several years, my client, Jeffrey Epstein. has business and other legitimate reasons that require
him to engage in frequent travel outside of the Virgin Islands and outside of the United States.
In connection with that travel, Mr. Epstein has an extensive history of what you and your office
have confinned has been fu)ly compliant notification to your Department regarding Mr.
Epstein's frequent travel during the period he has been required to register wider the existing
Virgin Islands law. As we also discussed, we reasonably anticipate that Mr. Epstein will
continue to have notice obligations to your Department in the future regarding his on-going,
frequent travel, and we wish to insure that Mr. Epstein continues to remain fully compliant under
the revised provisions ofBill 29-0239, as amended, while properly invoking the discretion of the
Office of the Attorney General, conferred in the language of this Bill, to reduce the notice
requirements in the Bill upon request of a registered offender who provides supporting
information.
Accordingly, we respectfully make this formal request on behalf of Mr. Epstein that the
Office of the Attorney General exercise discretion under Sections 6 and 9 of Bill 29-0239, as
amended, to both aJlow a shortened notic.e period for proposed travel, and modification of the
ATTORNEYS AT LAW
1340 TAARNEBERG, ST. THOMAS, VIRGIN ISLANDS
PHONE:
EMAIL:
information required in lieu of that otherwise required under those sections of the Bill.
In particular, we request that Mr. Epstein be permitted to continue his long-standing
practice for notice of his frequent travel outside of the Virgin Islands and outside of the
United States, which your Department has verified as fully acceptable, of providing
written travel notice to your Department by email or facsimile from Mr. Epstein or his
legal counsel immediately prior to Mr. Epstein's departure. As has also been Mr.
Epstein's Jong-standing practice verified by your Department as acceptable, we
respectfully request that the Office of the Attorney General confirm that provision of the
following information in that notice will satisfy the travel notice requirements: (1) Mr.
Epstein's date of departure, (2) the general geographic areas of his travel, and with
respect to travel to any of his vacation homes, a statement that he is traveling to his
vacation home, (3) the time period for his intended travel, and (4) his contact
information (consisting of a cell number where he can always be reached during the
period of his intended travel, and also a cell number where his legal counsel can always
be reached), in case of any need to contact Mr. Epstein while he is traveling. In
addition, we request that written notice by email or facsimile from Mr. Epstein or his
legal counsel be permitted for any changes in travel plans that have occurred after Mr.
Epstein has departed the Virgin Islands, so long as such notice is given prior to
departure to any changed locations. In any event, consistent with the long-standing
practice accepted by your Department, email or facsimile notice from Mr. Epstein or his
legal counsel of Mr. Epstein's return to the Virgin Islands would be given immediately
prior to Mr. Epstein's departure for his return travel to the Virgin Islands.
reduce notice and adjust the information required under the amended law, we
respectfully request that you inform us, so that the necessary information can be
promptly provided.
I also wish to confirm, as agreed during our meeting, that during any period that
may elapse between the signing into law by the Governor of Bill 29-0239, as amended,
and your Office's completion of review of this request under the Bill to exercise
discretion as described above, the continued compliance by Mr. Epstein with the above.
described travel notification practices he has followed to date will be deemed
compliance with the new law.
Again, I appreciate you taking the time to meet with us to discuss this,
particularly in view of the commibnent on the part of Mr. Epstein to comply with the
law. Please advise me if there is any additional information that may be required for a
favorable response to the foregoing request.
Sincerely,
?/~-..,.--
Maria Tankenson Hodge
o~-,,. hs
THE UNI.TED STA.TES VIRGIN ISLANDS
DBl"ABTMENT OP JUSTICE
,,. OFFICE OF THB ATTORNEY GBNBBAL
·J
, .,
,. .
."\~t&~'~tr'
VINCENT It FRAZER, ESQUIRE July 25, 2012
ATTORNEYGl!N'SRAL
Re: Implementation of Act No.7372. (Bill No. 29-0239); International travel Notice request
I am in receipt of your letter of July 16, 2012 requesting clarification of our implementation of the
new provisions of the local sex offender registration and notification law (1\ 14 VIC Chapter 86). I
understand that your letter was written on behalf of Mr. Jeffrey Epstein, a registrant on the Virgin
Islands Sex Offender Registry.
It is m.y understanding that Mr. Epstein's business activities require him to make frequent and
often unexpected trips out of the territory to United States destinations and to international
destinations. Your letter is accepted as a request pursuant to the new provisions of Act No. 7372, for
the Attorney General to waive the 21 day prior notice requirement to the Department of Justice for Mr.
Epstein, when travelling out of the Virgin Islands.
Based upon your representation and that of Attorney Darren Indyke, we will grant the waiver of
the (21) twenty one day notice requirement to the Department of Justice when Mr. Epstein is traveling
out of the Territory. This waiver is granted upon compliance with the following conditions:
1. Prior notice must be given to the Department of Justice no less than Seventy two (72)
hours before travel out of the Virgin Islands;
2. Notice must be given by Mr. Epstein himself, via in-person visit, by facsimile
correspondence which is signed by him; or by e-mail with an electronic signature;
3. If the jurisdiction to which he travels requires his registration for the dUiation of time he is
there, he will comply with that registration requirement;
04•08 KlioNPJllDiDBll!ffl G.A:on • OBRS BJ.J>o., 211i'D FLOOB. • ST, THOMAS, U.S. Vx:aour Jl!ILAN»& 00802 • (1340) 774•5666 • PAX: (840) 774•0710
0040 CA.&TLB CoAXLBY • Ds910N C111NT111:a B:r.no. • C11:ann:LU1BTB», ST. Cao1x, U.S. Vumn, lm:.A1n>s ooae.o • (040) no-0206 • FAX Co40) 110-0200
b. the dates he will be departing from the Virgin Islands and the date expected to return;
c. the dates he will be staying at any intermediary temporary iocati.on.
5. Notice mu.st be given of any modification from the travel itinerary, as originally advised
after leaving the territory. Such notice may be submitted by facsimile or e-mail by Mr.
Epstein or his legal coumel;
6. Upon returning to the Virgin Islands, Mr. Epstein shall immediately notified the
Department of Justice by visit, facsimile, or e-mail with electronic signature.
I do recograize that these conditions vary from the former conditions. However in light of the
discretion given to the Attorney General by Act No.7372, we are forced to take a closer look at the
waiver conditions.
Please let me know if your client has any questions about these conditions.
7Zyyo _.u...._rs.....,_.,_
1
VincentF.
Attorney General
Re: Jul_y 25, 2012 Letter Regarding Act No. 7372 Travel Notice Request
I received your letter of July 25, 2012 agreeing to grant the Attorney General's waiver,
pursuant to the provisions of Act No. 7372, of the 21-day prior notice requirement under that Act
with respect to Mr. Epstein's travels outside of the Virgin Islands, and I have shared it with my
client. We appreciate the consideration given to Mr. Epstein's frequent travel requirements.
However, we still have serious concerns regarding what we believe arc undue restrictions placed
on Mr. Epstein's travel and the conduct of his business and professional activities by certain of
the specific conditions imposed as part of this waiver, and we respectfully request that your
office reconsider those specific conditions.
Specifically, we believe that the waiver conditions requiring Mr. Epstein to provide 72
hours notice before traveling out of the Virgin Islands and requiring Mr. Epstein to provide a
specific address of temporary lodging locations when traveling within the United States will
have an unduly restrictive effect on his right to travel and conduct his legitimate business and
professional activities. As I understand it, both you and Senator Russell stated during the
hearing on the Act before the Rules and Judiciary Committee on June 21, 2012, that the travel
notification requirements of this Act were specifically not intended to be penal in nature. Both
you and Senator Russell acknowledged that this was meant to be a notice provision, nothing
more. However, as explained below, the restrictive effect of the 72-hour prior notice
requirement and the requirement that Mr. Epstein disclose the specific address of his temporary
lodging while in the United States would impede Mr. Epstein's right to travel and conduct
business and professional activities in a manner that would indeed, be penal in nature.
I want to discuss the legal justification for greater flexibility in notice. The Federal
SORNA guidelines have already recognized that there are cases where flexibility in the
application of SORNA's travel notification procedures is necessary. For example, the SORNA
guidelines themselves discuss the case of an individual who is a "long haul trucker" who
regularly drives thousands of miles through "dozens of jurisdictions in the course of his
employment", as well as the cases of a home-improvement contractor and of a day laborer, who
travel regularly to various locations that may change on a daily basis -- see The National
ATTORNEYS AT LAW
1340 TAARNEBERG, ST. THOMAS. VIRGIN ISLANDS
PHONE:
EMAIL:
Guidelines for Sex Offender Registration and Notification, pp. 39 and 43 -- or the case of an
individual ''who lives in a northern border state and who commutes to Canada for work on a
daily basis" -· see Supplemental Guidelines for Sex Offender Registration and Notification.
Federal Register, Vol. 76, No. 7 (January 11, 2011), p. 1638. These cases are analogous to any
number of possible situations in our Territory, including pilots, fisherman, boat captains, boat
workers, cruise ship workers, merchants and international businessman, all of whom travel to
and from the Territory on a frequent and regular basis in the ordinary course of their employment
or business. The burden on both the Department of Justice and the worker of requiring such a
worker to give 72-hours prior notice each time he leaves the Territory and to confirm every
location and address included in his travel notification would be substantial. In situations such as
these, the SORNA guidelines permit the responsible jurisdictions to reduce notice requirements
and simpJy require the traveling registrant to provide a most likely itinerary of "normal travel
routes" and "general areas" of work. The National Guidelines for Sex Offender Registration
and Notification. pp. 39 and 43. Mr. Epstein's case is no different from any of these cases where
SORNA expressly permits this flexibility in the manner and content of travel notification.
Consider> for example, the case of a St. Thomas boat captain chartering trips to various
islands in the Caribbean. Requiring that boat captain to provide 72 hours prior travel notice
would prevent him from taking any charters un]ess requested of him more than three days in
advance. With visiting tourists on short stays frequently requesting charters on1y a day or two in
advance, such a requirement would substantially interfere with the boat captain's ability to
conduct his business. Moreover, requiring him to provide specific addresses of his travels could
also be problematic in that tourists chartering his boat might not even make such determinations
until the day of the actual charter. Requiring the boat captain to be inflexible with his charter
passengers would therefore also seriously interfere with his business. The supplemental SORNA
guidelines have specifically stated in their own words that such requirements could be
"pointlessly burdensome" and "unworkable". See Supplemental Guidelines for Sex Offender
Registration and Notification. Federal Register, Vol. 76, No. 7 (January 11, 2011). p. 1638.
Consistent with the flexibility afforded by the SO RNA Guidelines, both Senator RusseH and you
acknowledged at that June 21, 2012 hearing that the law must be flexible to enable those who
must travel frequently and on short notice to do so.
In fact, when the travel notification amendment was revised for the Rules and Judiciary
Committee vote on June 25, 2012, the Attorney General discretion provision was inserted into
the law, rather than a specific 72-hour short notice exception to the 21-day notice requirement, to
provide your office with the flexibility to make decisions on a case-by-case basis. In the case of
frequent travelers, such as Mr. Epstein, as well as pilots, fisherman, boat captains, boat workers,
cruise ship workers, merchants and international businessman, who travel for business,
professional and other legitimate purposes several times a month, both on short notice and under
circumstances where travel plans frequently change on short notice, the new law provides your
office with the flexibility to grant a waiver that win not unduly restrict their travel and business
and professional activities, and that includes the right to allow notice prior to departure less than
72 hours in advance.
As you know, from the beginning of Mr. Epstein's registration in March 2010, he has a
demonstrated history of frequent travel and a flawless record of fully compliant travel
notification to your office. Even at times when the email servers at the Department of Justice
were not operating. Mr. Epstein's counsel took measures to ensure alternative notification by
providing telephonic and fax notification of the travel notice emails that were sent to the
Department of Justice. His record clearly demonstrates that he is unerringly diligent in ensuring
that the Virgin Islands is provided with timely notice of his travels outside of the Territory. and
he will remain so in the future under this new law.
Mr. Epstein has always previously provided the necessary travel notice, through his
counsel, immediately prior to Mr. Epstein's departure. He has done this because, in many
instances, , his travel dates and destinations are not known with certainty until a few hours prior
to departure, or they can and frequently do change on little or no notice for reasons that are not
within his control. For example, meeting schedules and locations for business or professional
trips evolved constantly over the past two years, and Mr. Epstein has had to remain flexible to
accommodate these changes. Moreover, W1expec:ted changes in weather patterns and mechanical
issues with the aircraft had also accelerated or delayed travel plans. Instead of providing a
constant flow of notices to the Department of Justice in anticipation of possible or changed
travel, Mr. Epstein has provided notice immediately prior to departure to ensure that the notice
he provided was as accurate as possible. It was and still is believed that this avoids unnecessary
administrative burden to the Department of Justice. which we understand would be required to
update its notices to other jurisdictions every time a new or changed notice is received from Mr.
Epstein.
In addition, to the extent that notification by Mr. Epstein of his entry into another
jwisdiction is even required by that jurisdiction, the notice is not required from :Mr. Epstein prior
to his arrival in that jurisdiction, and in some cases notice is not required until as much as several
days after arrival. Even in the State of Florida, the jurisdiction of Mr. Epstein's conviction
which triggered his registration requirement, Mr. Epstein is not required to provide any
minimum prior notice of his travel to Florida. In fact, he is permitted to provide email notice on
the day of his arrival. It is our understanding that notification immediately prior to Mr. Epstein's
departure from the Virgin Islands would still provide the Virgin Islands with ample time to
inform jurisdictions of Mr. Epstein's arrival, particularly when notification is done through
electronic means and is instantaneous. Moreover, in light of Mr. Epstein extensive record of
unerring diligence in providing notice of his travels and complying with his other registration
obligations, there are ample grounds to conclude that Mr. Epstein would continue to be fully
compliant in both the Virgin Islands and in all other jurisdictions to which the Virgin Islands
may have to give notice of Mr. Epstein's travels.
Requiring 72 hours notice of Mr. Epstein prior to his travel would severely restrict his
abHity to remain flexible to accommodate ever-evolving meeting schedules and locations and the
schedules of Mr. Epstein• s business and professional colleagues. For example, not infrequently,
Mr. Epstein is asked in the early morning to meet in a particular jurisdiction later in the day.
Because of the 72-hour notice requirement, in the future, Mr. Epstein would have to wait three
days before he could accommodate such a request for a meeting. As another example, assuming
Mr. Epstein gave the proper 72-hour notice of a trip to New York, but learned on the day of his
intended departure that the persons with whom he was to meet in New York later that day
desired to meet in a different location, Mr. Epstein would not be able to meet at the alternative
location because of the 72-hour notice requirement. In Mr. Epstein's business and professional
life, situations like this occur with frequency and regularity. and even a 72-hour notice
requirement would obvious]y have a significantly deleterious effect on his business and
professional activities.
For this reason, we respectfully request that Mr. Epstein be pennitted to provide notice
immediately prior to his departure when traveling outside of the Virgin Islands, provided that
Mr. Epstein will endeavor to provide 24-hours notice to the extent he has such advance
knowledge of his travel. We understand your requirement that notices come from Mr. Epstein,
himself. when he is in the Virgin Islands and providing notice of his travel outside of the
Territory, and Mr. Epstein will comply with that requirement.
Another waiver condition contained your the July 25, 2012 letter is that Mr. Epstein
provide your office with the address of his temporary lodging while traveling within the United
States. Mr. Epstein has and will continue to provide notice to the Department of Justice of the
addresses of temporary lodging that are his own homes. In fact, as the extensive volume of Mr.
Epstein's travel notification emails to the Department of Justice demonstrate, Mr. Epstein has
regularly stayed at his vacation homes when traveling and has so advised the Department of
Justice in his travel notifications each time he has done so. Inasmuch as the Department of
Justice already has a complete listing of the addresses of all of Mr. Epstein's vacation homes in
the registration information Mr. Epstein has provided and updates to the Department of Justice, it
was not thought necessary to include the specific addresses of Mr. Epstein's vacation homes in
each of the notices. To ensure compliance with the waiver conditions, Mr. Epstein will provide
the specific addresses of Mr. Epstein's vacation homes in the travel notices in the future.
However, frequently when Mr. Epstein travels to locations in the United States at which
he does not have a vacation home, he has stayed as a guest in the homes of thlrd parties,
including business and professional associates. Many times these invitations have been and are
extended to Mr. Epstein after arriving in these locations as plans change and meetings ex.tend
beyond scheduled times. Thus, origina1ly scheduled hotel reservations are cancelled and new
lodging arrangements have to be made (which would again require further notices to the
Department of Justice, which would presumably have to send updates to the jurisdictions to
which the original notices were previously given). Many of these hosts would be uncomfortable
with Mr. Epstein having to provide the addresses of their homes in the travel notifications to the
Department of Justice, particularly when the hosts are oftentimes prominent figures whose
addresses are not a matter of public knowledge and there is no guarantee that their addresses
would not be disclosed in response to FOIA or other Sunshine Law requests. Requiring Mr.
Epstein to provide these addresses would likely deter potential hosts from offering Mr. Epstein
lodging and thus again interfere with his ability to travel and maintain the necessary flexibility in
the conduct his business, professional and other legitimate activities.
It is for this reason that we respectfully request that the waiver condition requiring Mr.
Epstein to provide the addresses of his temporary lodging in hls notification of travel with.in the
United States be eliminated, provided that when Mr. Epstein stays at hls vacation homes while
traveling in the United States he will so advise the Department of Justice, and include in the
notice the specific address of his vacation home at which he is staying. In all other cases,
s
consistent with the Federal SORNA Guidelines which authorize jurisdictions to permit frequent
inter-jurisdictional travelers, such as long-haul truckers, day Jaborers, and international border
commuters, to provide a most likely itinerary of "normal travel routes" and "general areas" of
work, Mr. Epstein should be allowed to provide the general geographic area of his temporary
lodging and to provide a cell telephone number at which Mr. Epstein may be contacted at all
times while travelling.
We believe that the foregoing proposals are consistent with the Federal SORNA
Guidelines and consistent with the balance intended to be achieved in the travel notice
amendment as described by both Senator Russell and you at the Rules and Judiciary Committee
hearing on June 21. 2012. As has always been the case, Mr. Epstein would continue to provide
timely notification to the Department of Justice of his travel before departing the Virgin Islands,
so as to enable the Virgin Islands to electronically inform the necessary jurisdictions of this
travel. Notice of Mr. Epstein's general geographic location and a contact number to reach him at
all times would be provided, as well as his specific address when he stays at his vacation homes.
With this balance, the timing and the content of Mr. Epstein's travel notification would provide
your office the information it needs without impeding Mr. Epstein's right to travel and conduct
his business, professional and other legitimate activities, and would thereby avoid transforming
the Act's travel notice provisions into a punitive measure contrary to express legislative intent.
Once again, we appreciate the grant to Mr. Epstein by the Office of the Attorney General
of the travel notification waiver as described in your letter of July 25, 2012, and respectfully
request that the two waiver conditions described above imposed in that letter be modified as I
have proposed. If our request to modify the waiver conditions meets with the approval of your
please confirm that approval of the modifications as described above by signing this letter
below.
If you have any questions or require anything further for a favorable response to this
request, please do not hesitate to contact me.
Respectfully, -1__,;fl' __
After careful review of your letter giving additional information to support your client,
Jeffery Epstein's request for a shorter period for prior notice whenever he plans to leave the
Territory of the Virgin Islands. In light of the justification set out in your letter of July 30,
2012, I have decided to shorten the notice period and modify the other condition, as
follows:
1. Mr. Epstein will be allowed to notify the Department of Justice of his intention
to .travel out of the Territory twenty four (24) hours prior to his departure;
2. Mr. Epstein will be allowed to continue to notify the department when he is
staying in one of his stateside homes. He must provide us with a current list and addresses
of each of his stateside homes;
3. When Mr. Epstein is staying in the home of an associate, he must notify the
deparbnent of the city and state or country in which he is temporarily staying and his
period of stay in the jurisdiction;
4. When he is staying in a non-private lodging, he or his representative may
provide the specifics of the name, city and address of the establishment.
04•38 lCRC::UfJi'RllS'DSBNS GA.DE • GERS BLDO., 2Nl) Pr.oo:a • ST, Tuo.us, u.s. Vutoll!f ISLANDS 00802 • (340) 774•15688 • F'AX (040) 774•9710
8040 CAST.LB COA.KLllY • D:es10N CBNria::a Bl.Do. • CHJ1.1BTXANS't'JU>, ST. C:ao1x, U.S. Vm.onr Is:i....NDS ooe20 • (040) 770-02915 • FAX (1340} 770-0200
5. Pursuant to section 9 (4) (iii) of Act No. 7372, Mr. Epstein must provide a copy of
the following documents to the department.
a. all of his valid driver's licenses issued by any jurisdiction,
b. any and all government issued identification cards issued by any jurisdiction,
c. any passports issued to him.
I trust that the foregoing conditions will be workable for your client, in light of his
frequent trips out of the Territory on business. All other conditions stated in my letter of
July 25, 2012 are in full force and affect.
Vincent F. r r, E
Attorney General
Darren Indyke
Fri 4/26/201912:27 PM
To: Shani Pinney <Shani.Pinney@vi.gov>; Shani Pinney <Shani.Pinney@vi.gov>
Cc: Darren Indyke Augustin <Kevin.Augustin@doj.vi.gov>
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
29, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in Paris, France to his vacation home in New York, New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 1PM local
time on April 29, 2019 and to stay at his vacation home in New York, New York
until May 1, 2019. On May 1, 2019, Mr. Epstein plans to return from his vacation
home in New York, New York to his permanent residence in the U.S. Virgin Islands.
He will email your office upon his return on May 1, 2019.
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
DARREN K. INDYKE
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein must now depart Paris a day earlier than we advised you previously today.
On April 28, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his
vacation home in Paris, France to his vacation home in New York, New York.
He expects to arrive at Teterboro Airport in Teterboro, New Jersey at
approximately 6:30PM local time on April 28, 2019 and to stay at his vacation home
in New York, New York until May 1, 2019. On May 1, 2019, Mr. Epstein plans to
return from his vacation home in New York, New York to his permanent res idence
in the U.S. Virgin Islands. He will email your office upon his return on May 1, 2019.
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
DARREN K. INDYKE
https://outlook.office.com/maiJ/s&arch/id/AAQkAGVkOGYxYWYzLTVkMTktNGNIZi1iODgzLTRhNjczM2E1OTJkZQAQAK07dlLJ8npBpy2XvGofPbA%30 1/2
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. On April
29, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from his vacation
home in Paris, France to his vacation home in New York, New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 1PM local
t ime on April 29, 2019 and to stay at his vacation home in New York, New York
until May l, 2019. On May 1, 2019, Mr. Epstein plans to return from his vacation
home in New York, New York to his permanent residence in the U.S. Virgin Islands.
He will email your office upon his return on May 1, 2019.
If you need any further information, please feel free to call me at oron
my mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
DARREN K. INDYKE
Driver's License #:
Felony: _ _ Misdemeanor: _ _
WIOJJSOR-1
Upon Arrival in your Destination Please Report to: New '{ork. NY contact the monitoring unit upon arrival
(212) 323-71()1
r··.
"?
.>=::~. - -
! Yi
Completed By: ........ V~--•y~,,4;;_?.J/[) Date:.
(You are required to notify the Sexual Registry Coordinator when you return to the Territory)
\Ve reprcscnr ~tr, Jdfo:y Epstdn, who i~ rcgiso:Tcd on tbe U.5. Virgin lslands Scxunl Offender
Rcgistrr, FM the rea$ons expl.iiocd bdow, we are rc~pcctfolly requesting that 1hc U.S. Virgin ls!ands
Dt:partrn~nt of Justice ('USV ll)OJ',.) rcinsratc rhc pru\'cn tr::l\·d nutificatil)!l procedures lhat have
been in effect since .Mr. Ep~tein's inili:ii re~strntlon. Since lnitiallr registering with ch<:' Registry in
2009, .M.r. Ep:m:in has strictly l1.1Howcd the. l7SV!DOJ's snme mwd nocific:1don procedures, which
fully comply with br>d.1 U.S. Virgin Islnnds srntnt·(.iry hnv and the 'C'nii..-d Smtes Sex Offender
Re¢strn..ion !Ind Norificacion Act ('"SORl'\A"). By lett<:r l'V Mr. 1--:psrcin d:trcd :March 14. 2019, chc!l
Acting ,\ssisrant ,\ctome~ General C:1rnl 111umas Jawbs acknow1edgl!'d Mr, Fpsrcin·s wl'll
docum<..'nrcd hist-or.y of frequent and e.x.tcnsi,c trn\'d, but :1dviscd that t·he USVH)OJ would 110 longer
permit l\fr. Epstein r.o follow these procedures, de~pitc the fact that rhey ha\'C worked tla1.vkssly for
the p,t~t ten (10) yt.':tr'l.
Both :Mr. Epstein·$ Conner attomi."y, 1faria Hodp:c. and Mr. Epstein's 51':ltcside counsel, Darren Indyk~'.
previously provided S\1bSt.\11ti,~ documentation to the CSVIDOJ as re, \Ir. Epsrcin's frcqucm and
extensi\·c tr.we! for business and nther legitimate purpos.::s. Tn nearly all case~. i'\lr. Epstein h~s been
required ro trnvcl, both imerm1rion11.lly \\nd d<1mestic:11ly. <)n lirtlc nolict: mid co cbn11ge his travel plnm
freq~1cnrly on ec.1uall) lirtle notice. The c-nrnil mwel m>rific:1tlo.i1 authorized under Virgin ll-1:inds hw
has provitled the rnosr efficient 111\d \\'1.11k1blc method to keep rhc CS\'}DOJ irmamly informed of
Mr. Ep5rein•s frequenr and {:&tensive travel plans ;ind the change~ rc~,1larl)· reqt1ired t.o lK~ made to
th<)sc. plans, ,\ s n r.:·sult of this system of email mwd not·ifkation, the 'USVIDOJ has b~l:11 aware of
Mr. Epscdn's location every singk cfay 1Jf his lifo without exception i'nr rht! p:-t5l ren (10) rl!':i.ts. This
is confirmed br tlw l'SVIDOJ's own tiles \t:hich contain hundreds of l\lr. Epstein'~ email tnvei
not.ices and changc:s ro rhosc n{Jtkes rlrnt- htt.vc been provided to i\ls. Shani Pinney, the llSVJDOJ
Sexual Offender 'Registry Coordin:1rm. during rhat rl'11 (I()) year i:wriod.
The USVIDOJ's Failure to Notify the Dominican Republic of Mr. Epstein's Travel
Mr. Epstein has a ten (10) year record of perfect compliance with his travel notification obligations to
the USVIDOJ. In many cases, Mr. Epstein has over-notified the USVIDOJ regarding his travel in
order to ensure his continuing compliance. To our knowledge, the only issue ever to occur with respect
to Mr. Epstein's travel is related to his recent travel to the Dominican Republic on February 19, 2019.
Mr. Epstein bears absolutely no responsibility for this issue as he gave timely notice to the USVIDOJ
of his intended travel to the Dominican Republic. It is our understanding that the issue arose solely
as a result of the USVIDOJ's inadvertent failure to notify the Dominican Republic of Mr. Epstein's
intended travel to that jurisdiction, as required by 14 V.I.C. §1726(d). Because of the USVIDOJ's
failure, Mr. Epstein was detained for several hours by the Dominican Republic authorities and
eventually refused entry into the country. Unfortunately, we believe that this incident, caused solely
by the USVIDOJ, and not by Mr. Epstein, resulted in additional scrutiny regarding Mr. Epstein's travel
reporting, and that this in turn gave rise to the recent decision to change the travel reporting
procedures that have worked perfectly for the past ten (10) years. Attached as Appendix 1, you will
find a detailed account of Mr. Epstein's extensive notification efforts relating to his trip to the
Dominican Republic and the response from the USVIDOJ.
I have included for your review, as Appendix 2, the correspondence between Attorney Hodge and
then-Attorney General Vincent Frazer in which then-Attorney General Frazer confirmed the twenty-
four (24) hour statutory notice period applicable to Mr. Epstein's frequent travel outside the Virgin
Islands, as well as Mr. Epstein's right to provide travel notification to the USVIDOJ via email and by
facsimile in lieu of in person notification.
Specifically, we are requesting reinstatement of the following travel notification procedures confirmed
by the USVIDOJ':
• Mr. Epstein will be allowed to notify the Department of Justice of his intention to travel
outside the Territory twenty-four (24) hours prior to his departure;
• Notice must be given by Mr. Epstein himself, via in-person visit, by facsimile correspondence
which is signed by him, or by email with an electronic signature;
• Mr. Epstein will be allowed to continue to notify the department when he is staying in one of
his stateside homes. He must provide ... a current list of, and address for each of his stateside
homes;
• If the jurisdiction to which he travels requires his registration for the duration of time he is
there, he will comply with that registration requirement;
• When Mr. Epstein is staying at the home of an associate, he must notify the department of
the city and state or country in which he is temporarily staying and his period of stay in the
jurisdiction;
1
This list reflects the relevant requirements communicated by letters dated July 25, 2012 and August 14, 2012 from then-
Attorney General Vincent Prazer.
• When Mr. Epstein is staying in a non-private lodging he, or his representative, may provide
the specifics of the name, city, and address of the establishment;
• Notice must be given of any modification from the travel itinerary, as originally advised after
leaving the territory. Such notice may be submitted by facsimile or email by Mr. Epstein or his
legal counsel; and
• Upon returning to the Virgin Islands, Mr. Epstein shall immediately notify the Department of
Justice by visit, facsimile, or email with electronic signature.
Attorney Jacobs letter of March 14, 2019 revoked the notification procedures previously confirmed
by the USVIDOJ and now requires the following:
• [Mr. Epstein is] required to appear in person at the USVIDOJ at least twenty-one (21) calendar
days prior to any travel outside the United States;
• Notification of any travel outside the U.S. Virgin Islands must be provided in person at the
USVIDOJ when [Mr. Epstein] is in the territory;
• Notification by email can only serve as notification if [i\fr. Epstein is] already outside the
territory and planning on travelling to another destination or to notify of a change in the length
of [Mr. Epstein's] travels while [i\fr. Epstein is] outside the territory;
• If a reduction in the twenty-one (21) day notification is requested, [Mr. Epstein] must submit
information in support of the request for approval at the discretion of the USVIDOJ.
The Prior Travel Notification Procedures Fully Comply with SORNA and the USVI Statutes
As discussed in Attorney Hodge's letter of July 30, 2012, SO RNA very clearly authorizes flexible
travel notification procedures in cases, such as Mr. Epstein's, where registrants travel frequently for
work or other legitimate purposes. As detailed in Attorney Hodge's letter ofJuly 30, 2012:
The Federal SORNA guidelines have already recognized that there are cases where
flexibility in the application of SORNA's travel notification procedures is necessary.
For example, the SO RNA guidelines themselves discuss the case of an individual who
is a "long haul trucker" who regularly drives thousands of miles through "dozens of
jurisdictions in the course of his employment", as well as the cases of a home-
improvement contractor and of a day laborer, who travel regularly to various locations
that may change on a daily basis -- see The National Guidelines for Sex Offender
Registration and Notification pp. 39 and 43 -- or the case of an individual "who lives
in a northern border state and who commutes to Canada for work on a daily basis" -
- see Supplemental Guidelines for Sex Offender Registration and Notification, Federal
Register, Vol. 76, No. 7 (January 11, 2011), p. 1638. These cases are analogous to any
number of possible situations in our Territory, including pilots, fisherman, boat
captains, boat workers, cruise ship workers, merchants and international businessman,
all of whom travel to and from the Territory on a frequent and regular basis in the
ordinary course of their employment or business. The burden on both the Department
of Justice and the worker of requiring such a worker to give 72-hours and in some
cases 21-day prior notice each time he leaves the Territory and to confirm every
location and address included in his travel notification would be substantial. In
situations such as these, the SO RNA guidelines permit the responsible jurisdictions to
reduce notice requirements and simply require the traveling registrant to provide a
most likely itinerary of "normal travel routes" and "general areas" of work. The
National Guidelines for Sex Offender Registration and Notification pp. 39 and 43.
Mr. Epstein's case is no different from any of these cases where SO RNA expressly
permits this flexibility in the manner and content of travel notification.
Consider, for example, the case of a St. Thomas boat captain chartering trips to various
islands in the Caribbean. Requiring that boat captain to provide 72 hours prior travel
notice would prevent him from taking any charters unless requested of him more than
three days in advance. With visiting tourists on short stays frequently requesting
charters only a day or two in advance, such a requirement would substantially interfere
with the boat captain's ability to conduct his business. Moreover, requiring him to
provide specific addresses of his travels could also be problematic in that tourists
chartering his boat might not even make such determinations until the day of the actual
charter. Requiring the boat captain to be inflexible with his charter passengers would
therefore also seriously interfere with his business. The supplemental SORNA
guidelines have specifically stated in their own words that such requirements could be
"pointlessly burdensome" and "unworkable". See Supplemental Guidelines for Sex
Offender Registration and Notification Federal Register, Vol. 76, No. 7 Oanuary 11,
2011), p. 1638. Consistent with the flexibility afforded by the SORNA Guidelines,
both Senator Russell and [then-Attorney General Frazer] acknowledged at that June
21, 2012 legislative hearing that the law must be flexible to enable those who must
travel frequently and on short notice to do so.
The very same flexibility authorized by SORNA for frequent travel reporting is incorporated into
Virgin Islands law. In fact, Section 1724(6)(4) provides for a mandatory exception to the twenty-one
(21) day in person notice otherwise required for international travel. Section 1724(6)(4) explicitly
states that "... a sex offender who provides reasonable and reliable proof satisfactory to the
Department ofJustice, that he travels frequently outside the United States for work or other legitimate
purposes, or a sex offender who travels outside the United States for emergency situations, shall notify
the Departn1e11t q((Hstice in writing at least 24 hours before traveling outside of the United States for
periods of more than 48 hours, and, in any such case, shall notify the Department ofJustice in writing
upon the sex offender's return to this jurisdiction."
Therefore, in cases such as Mr. Epstein's, where he has provided reasonable and reliable proof to the
USVIDOJ that he travels outside the United States for work or other legitimate purposes, we believe
he is only required to notify the USVIDOJ in writing (that is, by email) at least twenty-four (24) hours
before travelling outside the United States and to notify the USVIDOJ in writing upon his return. We
believe that the USVIDOJ is already in possession of substantial proof of 1\-fr. Epstein's extensive and
frequent international, as well as his domestic, business travel. However, in the event you would like
us to resubmit any information, we would be happy to do so.
Funhcr adopting the rccommendatiorb of federal S()RN,:\ guidchiws, Virgin Islands law pro\'ides
equal flex.ibilityvirh rec:ipeu: to rcpon:ing tran:J b:'twecn the USVI :md the United Stal'cs, Email travel
reporting prior to dq:nrdng the LIS\'! for destinations in the United Stares fully complic, with the
r<·quirtnk'.nL of Section 1724(,;:), Sec:tiun J724(c) provides that "(b]efort moving from the Un.ittd
Stares Virgin Tsbnds to another jurisdiction within the L.'nircd Srntes, a person required to register shall
register his new addrefs, temporatr or pennanenr, with the Dcpartmenr of Justic<': before ht' kaves
th:- rerrirory:' By its very tenm, Section 1724(c) specifically docs not re,pin: in person nmiflc:irion.
'Therefore, Attorney J,cnh/ requirement to appc:1r in persnn to notit\ tfw L'S\'IDOJ of tuvd
bc:twccn d1t' tSVt and rhc Unii.t:d Srntcs appears to exceed the ttc;uirernents of Virgin Hands law,
Although Atton1t:y J;icobs cited ~ccrion l 724(b)(l) as the reasoning for revocat.ion of the esrnb!.ished
travel pro<:edurcs, Wti do not bclicv(· thar rhis section is applicable to \Ir. Epstein's trnvds to the
United Sut<s, i\ni<mg the nHnY rc:ts(>nS that \V(' bclicw that secriun 17240))(1) does not. itpply is the
fact th'.Ir \lr, Epsrdn has dready registered his rempornry lodging with the USVIDOJ. By its v1-rv
Lmgu;1ge, section 1724(b)(l) <tppcars only rn '.,pp!y in t:hc cvem rhere arc changes to l\lr. Ep-.rein's
t(·mponry lodging in the United States, Mr. J~psrdn rnainuins temporary lodging (vacation hin1<.:s) in
Florida, New '{ork, ;!nd Nv,,,, Mc.xico. All qf tht. requited information regarding those temporary
lodgings has been on fik with tlk USV!DOJ since \Ir. Epstein initidly registered .in the USVl in 2009.
There have hl"c:n W} ch:inges to i\l r, Epsrdn 's temporary lodging information since his initial
registration, and there ci.:rrainly have lxen no changes to his r(:mporary lodging infrirnuriun since his
last' in pcr~on annual registration renewal e,ir!icr this year, a~ required by section 1724(d),
i\s a result of dw incident in the Dominican Republic, we are conscious of the need to nuke sure
l'herc nre safcgu:mls in place to enrnn~ .\fr, F'.psttin 's compl.i;tncc and also n:i ensure that proper
notification is given ro jurisdiuinn~ rhat require it \\\:' are respecrfully re,pesting thar going frirwm:d,
the CSVIDC)J pnn'ide \Ir, 10:pstdn <.vidi an email COP)· of all notifiorions it is rt·quircd to make to
jurbdicrions uutsid(: the CSVl pursuant to section 172/S(d). By receiving an email copy of these
notifications, ;\Ir. L'.pnl'in will be ;rbk to confirm drnt the USVJDOJ ha~ received each o( his trnvd
notices w.1d, if nec(·~saq·, Like: additional anion to u1sure that such notice has been recein:d br the
USVIDOJ and forward~d to rhc :1ppropriatc iurischctions m1tsid(· the l.'SVL ,
J\.fr. Evtdn's coun,d, Dan:en lndykc, and l would apprechre the opporrunin to discuss this marter
,vith yon furtht:L \'(c will n1,1k(· ,,ursdves available ?( your convenience.
Rc,pectfol!y.
APPENDIX!
In accordance with the procedures authorized by Attorney General Frazer in August 2012, Mr.
Epstein gave proper email notice on February 16, 2019 to Ms. Shani Pinney, the Territorial Sexual
Offender Registry Program Manager, of his intention to travel for a day trip to the Dominican
Republic on February 19, 2019. Mr. Epstein's attorney, Darren Indyke, was copied on that email
notice, and received the email at the same time Mr. Epstein emailed it to Ms. Pinney. See Exhibit 1.
That notice included all international travel information necessary in order for the Department of
Justice to give the Dominican Republic authorities the required advance notice of Mr. Epstein's arrival.
Mr. Epstein also emailed Ms. Pinney on February 18, 2019 regarding his obligation to annually renew
his registration on March 5, 2019 and advised that after leaving at noon on February 19, 2019, Mr.
Epstein anticipated being outside of the Territory until March 20, 2019. Mr. Epstein inquired in his
email as to whether he should renew his registration before he left the next day or after he returned
on March 20, 2019. Attorney Indyke was also copied on that email, and also received it when Mr.
Epstein emailed it to Ms. Pinney. See Exhibit 2.
Despite Mr. Epstein's timely and proper notice to the Department of Justice of his travel to the
Dominican Republic, the Dominican Republic did not receive advance notice of Mr. Epstein's travel.
As a result, upon Mr. Epstein's arrival in the Dominican Republic on February 19, 2019, he was
detained for several hours and ultimately denied entry. Having been refused entry, Mr. Epstein then
traveled to his vacation home in Palm Beach, Florida, as his February 16, 2019 email notice advised
he would do.
On February 21, 2019 at 9:57PM (ESl), Attorney Indyke notified Ms. Pinney of a modification to
Mr. Epstein's travel plans. As authorized by the travel notification procedures in effect prior to your
March 14, 2019 letter, because Mr. Epstein was traveling and no longer in the Territory at that time,
Attorney Indyke provided the changes to Mr. Epstein's itinerary by email to Ms. Pinney at the same
email address that he had previously used to transmit his messages successfully. See Exhibit 3. All of
the required information, including the required information for international travel, was included in
that email.
Six (6) days after Mr. Epstein emailed his February 16, 2019 travel notice, and three (3) days after Mr.
Epstein had been detained and refused entry to the Dominican Republic, Mr. Epstein received a
response from Ms. Pinney. By email on February 22, 2019 at 9: 11 AM (ESl), Ms. Pinney advised that:
I am only now responding because I have been out of the office. Please note that an
appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators that
can assist in my absence.
Also, I have not received your travel details. As you are aware these details must be
provided prior to your departure. Please provide by the end of business day.
See Exhibit 4. Five (5) minutes later, at 9:16AM (ES1), Mr. Epstein re-sent to Ms. Pinney the email
travel notice that he sent on February 16, 2019 and copied Attorney Indyke on the email he re-sent.
See Exhibit 5. Ms. Pinney responded by email at 9:43Al\1 (ESl) that she searched her emails and
could not find Mr. Epstein's original February 16, 2019 email travel notice. See Exhibit 6. However,
Ms. Pinney did receive Mr. Epstein's February 18, 2019 email and Mr. Epstein's 9:16AM (EST) email
on February 22, 2019. See the email chains in Exhibits 4 & 6. Ms. Pinney also stated that:
In the future, cc SOR Investigator Augustin to assure that the travel details are
received. Agent Augustin has been cc'd in this email. Also, you are required to report
on March 11 th after your return to the USVI on March 9th to complete your yearly
registration.
See Exhibit 6.
In light of Ms. Pinney's advice that she had not received Mr. Epstein's emails, Mr. Epstein inquired
as to whether she had received Attorney Indyke's February 21, 2019 email regarding the changes to
Mr. Epstein's travel itinerary. Mr. Epstein sent Ms. Pinney four (4) separate emails on February 22,
2019 asking for confirmation that Attorney Indyke's February 21, 2019 email had been received. Both
Attorney I ndyke and Agent Augustin were copied on all of them. See Exhibits 7, 8, 9 & 10. Attorney
Indyke received each of these emails at the rime they were sent to Ms. Pinney. Attorney Indyke also
sent emails to both Ms. Pinney and Agent Augustin on February 22, 2019, which included a copy of
the February 21, 2019 email Attorney Indyke sent to Ms. Pinney. See Exhibits 11 & 12. Three (3)
days later, on February 25, 2019, Ms. Pinney emailed Mr. Epstein that she had not received any notices
from Attorney Indyke. See Exhibit 13. However, none of the emails sent by Attorney Indyke, or for
that matter by Mr. Epstein, during the February 16, 2019 to February 28, 2019 period were returned
as undelivered by the DOJ's email server, and Attorney Indyke and Ms. Pinney have communicated
successfully by email for years.
Exhibit 1
s. S. Pinney
Terrltorial Sexual Offender Registry Program Manager
Vlrgin Islands Department of Justice
United States Virgin Islands
This is to advise you th,9t ! will travel by private aircraft, N2l2JE, on February 19, 20i9 for a
day trip to Puerta Plata, Dominican Republic. ! expect arrive at Gregorio Luperon
!nternaHona! Airport in Puerta Plata, Dominican Repub!ic at approximately 1:O0PM local time,
and to travel by private aircraft, N212JE, that same day to my vacation home in Palm 8.each,
Florida. ! expect to arrive at Patm Beach lnten;at1ona! Airport in Palm .Beach, Florida at
approximately 6.:45PM local time on February 19, 2019 and to stay at my vacation home in
Palm Beach, Florida untH February 22. 2019, On February 22,. 2019, l plan to travEJI frorn my
vacation home :n Palm Beach, Florida to my vacation home in New York, New York, wi1ere I
expect to stay until February 28, 2019. On F~bruary 28. 2019. I plan to travel by private
aircraft, N212JE, from my vacation home ln New YorJ\, New York to my vacation home in
Paris, France. l expect to arrive at Le Bourget 1-\irport in Paris, France at
approximately 7:30PM local time on February 28, 2019 and to stay at my vacation home in
Paris, France until Marc!1 9, 2019. On i\1arcti :9. 2019, I plan to rewm by private aircraft,
N212JE, from my vacation home in Paris, France to rny permanent residence in the U,S,
Virgin Islands, I expect to arrive at Cyril E. i<:ing lnternationaf Airport in St. Thomas, U ,S.
Virgin Islands on Marct1 9, 2019 at approximately 1:00PM lccai time. While traveling abroad,
l can be contacted on my mobile to!ephone number at ?.12-533-3739. In addition, ! can be
contacted thrcn,.gh my business office a.t 340-775---2525 or through my attorney, Darren K.
lndyke, atlllllllllllll I w!I! email your oHlce 1Jpon my return 10 the U.S. Virgin Islands on
March 9, 20; 9.
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney:
Respectfully,
p!e~se note.
The lntorrnatiori conlaiM d in !his communicati(in ,s
confidential, may ba attorney•ciienl privtt.eged, may
cor.stitu!e iflS;de ir,ION11l11M, ,Htd is intended OO~f for
the use el the ad<lts~e, It ls tho props1ty of
JEE
lJl'l<!•;thor:zoct use, dls:clo~um or .::opyi.og .c·f fai:.
comniui;icalkm ar arw oarr ttwreof is ~!ric:Uv orohlhite,:J
Exhibit 2
Ms ?11,ey • i an1 on is,ar1d uni.;1 t1.os .at noon • and w ii! no! rotur n lo the territory until the 20tt, ol march,
march 5 , woudl you prefer i wa't,unt!I my rt!urn or would 1-i,u prefer 1-~ome in tue~ momng. thx:,
m, regls:ration data is
r,tea;;e ')()lo
The il!formatio11 contained in this comrnu11fca11on Is
confidential, may bP- a!tomey-cilcot privileged. moy
CO!iSli'.uto i11sido lnlomialion, and is intended or.ty for
the use ol !he addrasse~. ,t is the prQporty of
JEE
U,iaull,oriied use. dtsdvsu:e o. oopyir1g of \his
commuo!c.afon or any port lhe:eo! is stnd~; prohibited
and may be unlawfuL lf you have received this
cornmuriieation in orroi:; p!easo no\ify us Immediately by
;eturn e•m::iil or by e-rr.ail to j,u~vn;;ah,.l!'.&.!lJN!1LSil'.l!)'J, an-::!
dilslroy this C-Ommur.ica.tior: and a~ copies ~':ereol,
inc!tlding all attachmonts, copyr:ght •ali ri9Ns reserved
VI-JPM-000012455
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 130 of 196
Exhlblt3
Ms. S. Pinney
Territorial Sexual Offender Reg1str; Program Manager
Virgin lslands Department of Justice
United States Virgin is!ands
This is to advise you of a modification to Mr. Epstein's travel plans. Mr. Epstein will stay at
his vacation home in Palm Beach, Florida until February 24, 2019. On February 24, 2019,
Mr. Epstein plans to to travel from his vacation home in Palm 8 eact1, Florida to his vacation
home in New York, New York, where he expects to stay until February 28, 201 9. On
February 28, 2019, Mt Epstein plans to travel by private aircraft, N212JE, from his vacation
home in New Yori<, New York tc his vacation home in Paris, France. He expects to arrive at
Le Bourget Airport in Paris, France at approximately 7:30PM local time on February 28, 2019
and to stay at his vacation home in Paris , France until March 9, 2019. On March 9, 2019,
Mr. Epstein plans to return by private aircraft, N212JE, from his vacation home in Paris,
France to !lis permanent residence in the U.S. Virgin Islands. He expects ta arrive at Cyril E.
King International Airport rn St. Thomas, U,S. Virgin islands on March 9, 2019 at
approximately 1:OOPM local time. While traveling abroad, he can be contacted on his mobile
telephone number at 212:.,533-3739. In be contacted through his business
office at 340-775-2§65 or through me at - Mr. Epstein •y11i!I email your ottice
upon his return to the U.S. Virgin !s!ands on March 9. 2019.
Please confirm by reply email to me your receipt oi this emai!. Thank you, Ms. Pinney.
Aespectfully,
Exhiblt4
Good Day.
I am only now responding because I have been out of the office. Please note that
an appointment is not needed to fulfill your registration obligation.
In the future , report in person to DOJ to register and there will be Investigators that
can assist in my absence.
Also, I have not received your travel details. As you are aware these details must
be p rovided prior to your departu re. Please provide by the end of business day.
From: J <j~vacatign@grm,i!L@Jn>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
S ubjec1:
Ms Ploay • i am on itiland onlil tu~s at 1100n . an:.1 wil! not mtorn to the to<1rito1y 1.mti l th~ 20th ot match, my rcgislrntion date is
march 5 • woudl you prelo: I wait until my return 01 would yoo prtiler , come in :ues momng. th,:,
p'easo note
Th~ intormation cootainm:l ln ihis oommunicmfon is
conlldon\io!, may be al!om-0y--c!l-0t1t prMleged, may
constitute inside k1fo1matioo, and is intended ooly !or
tho uso of the addressee It ls the property oi
J.:-
-c
Un:a1Jthori2:od use, disclosote or COf>ying ol this
r:omm1,;nfcatlon or any pmt thereof is strittly prohibited
al1d may oo unlawfol. II you have received \his
comm1micalion in error, pteas-e notify u!. immediately by
return o-man or by e-mail to ~.7ill"9.~Qin?ll,c9m, und
destroy !his commur.i<'..atioo and an copies thereot,
inc!ud1119 all at1acnmo111s. rop}'fight •alt nghts tese,ved
pteasenote
Tile infotmalion contained in this communication is
confidential. rnay be attorney-client ptM!eged, may
eonstltwte inside information, and is intemfad tm!y 101
the use of !he ad<lreasee. ft is the pn:ipert}' o!
JEE
Unautt,onzed usa. disdosuce e< copying of this
commurucatic-n or any part the:eor is st<icll)" prohibited
and may be unlawful. If you have recotved lhh~
oommunical!OJ: in error, pleas,~ noiily us lmmedi atoly by
return e-mail or by e-rnwl to ~~41,gt1QQ@gm~rn. and
destroy this communlcalio-n and all cop:es :hereof,
including au attachments copyright --aU rights reserved
Exhibit 5
s. S. Pinney
Territo rial Sexual Offender Registry Program Manager
Virgin lsJands Department of Justice
United States Virgin Islands
Tl'lis is to advise you that I wit! travel by private aircraft, N212JE, on February 19, 2019 ior
a day trip to Puerta Plata, Dominican Republic. I expec1 arrive at Gregorio Luperon
International Airpori ln Puerta Plata , Dominican Republic al approximately 1 :0OPM loca!
time, and to travel by p rivate aircraft, N212JE 1 that same day to my vacation home in Palm
Beach, Florida. l expect to arrive at Palm Beach International Airport in Palm Beach,
Florida at approximately 6:45 PM local time on February 19. 20'19 and to stay at my
vacation home in Palm Beach, Florida until February 22. 2019. On February 22,. 2019, l
plan to travel horn my vacation home in Palm Beach, Florida to my vacation home in New
York, New York, v,;here I expect to stay until February 28, 2019. On February 28, 2019, I
plan to travel by private aircraft. N212JE, tram my vacation home in Ne•N York, New York to
my vacation home in Paris, France. I expect to arrive at Le Bourget Airport in Paris, France
at approximately 7:30PM loca! time on February 28, 2019 and to stay at my vacation home
in Paris, France unti! Maret, 9 . 2019. On March 9, 201 9, I plan to return by private aircraft,
N212JE, trom my vacation home Jn Paris, France to my perrnani?nt residence in the U.S.
Virgin Islands. I expect to arrive at Cyril E. King International Airport in St T homas, U.S.
Virgin Islands on tv1arch 9, 2019 at approximately 1:O0PM local time. While traveling
abroad, ! can be comacted on my mobile telephone number at .£ 1~533-3739. In addition, I
can be contacted thr~ ess office at 340-n5::2525 or through my attorney,
Darren K. lndyke, at - - - - I wH! email your office upon rny return to the U.S.
Virgin Islands on March 9, 2019.
Please confirm by reply email to me your receipt of this emall. Thank you, Ms. Pinney.
Hespectfuliy,
please note
The in!ormalhn contained in this comrnun.!ca!ion is
con!lden!ia!, may bo attmney-dient privileged, mHy
i::onstitute inside inimmation, and is intended <Jn1,., !or
the use cl !he addmssee, n 1:; the propert~· ol ,
,JEE
Unauthorized uso, disclo:wn, ,:ir capylng CT! triis
cGmmunk::ation or any part 1hemCJI is strictly pmhit,ited
and may be unlawl\JL II vou ha110 mce1ved 1his
.:omm>,mication in error, ,piuisa notify us immediakl\l b\l
relurn e--man or by e·--mail to )SJJ1:P9iMtz~r:)\P}p)::~(q;;nn{ and
de.slro~• this comrrn.mkalfon an,j all moles thereol,
including al! atlachments, cop~•rfght -all fights resmvfld
plea,w rick,
The infom1alion contained In this ~ommunica\ion is
conlidm1tial, rna/ be anorney-client privileged, may
conslilut,;,, inside Information, and is intended only for
trii;; urn oJ tbe addressee. I\ i.s 1i'1e pmµerty ol
JEE
Unauthorizod use, disd,,:;ure or copylng oJ this
communlcanon or any parl thereof is stric!l'.i pml1ildmJ
and may be i.inlawful. It you have mceived 1his
communication in ermr, plea:,e notify us immadiatai'.i' by
return •e.,n1n:i! Of by e~ma~i! to i_n~~\t~rnnqnff~qm~::lL(tw::::, and
dcslroy this cornmunicalkn and al! capies tt:cereul,
including :..iii tiltm::hments. c:opyright -ail right; n,;1sirve-d
please no:te
The inlcrmal.km ,xint,rined in this cornmu111ca!ion is
i::onfidentlal, may be attorney-ci!en1 privilego<l, rnay
constitule in,H:ie infnrmah:in, and is intended on\· br
the use, o1 the address1,m. I! is lhe property' cl
JEE
Unauthorl:wd use., dbdosure or copying ni this
communicaiion or anf part Hiemof is stric:tly prohibited
and may be unlawfuL Ii )'QIJ ha>;,;:, rGceived !his
cornmuriicmbn bi error, :p:teas·e n~,tify us .irn:mediat.e!y by
return eAmaH Ot by Hvrna.:11 t,o ,i:t•fa\:"fK~~Hlrr~@qrn~:d cntn, and
,:i,1stroy this communication ~nd ail copies lh~i~(;r~,
im:ludini1 all ilttachrr,ents copyrighl -a!I rights rnson10d
VI-JPM-000012460
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 135 of 196
Exhibits
Thank you.
l searched my email and I dld not receive this or any correspondence from you on
the date February 16, 20·19 as indicated in your attachment. In the future, cc SOR
Investigator Augustin to assure that the travel details are received. Agent Augustin
has been cc'd in this email. Also, you are requ ired to report on March 11th after
your return to the USVI on March 9th to complete your yearly registration.
From: J <;)e;evnqation@ gm~n. cgrn>
Sent: Friday, February 22, 2019 10:19 AM
To: Shani Pinney
Subject: Re: Registration & Travel
b ~ ~ t,~ ~S-U14'~*>Ac.1
$ ·-~ ~.
·:q ~~('§J~i<?---~$"~.;n:~.;m". ~::,.-:-:,,,,1\.-'~ ,<~' ~~ ~ ~~~.;.~~tt~,..
-s, S. P lnitll'/
Tr:,r6t~f3J ~CJ.tt;;):1 Offl!.m}nr ,lli?91~sr; ~t,x;v~m M:itt.lg~,
~li~t:n ~stat~'S: Oi.~M'i<?<'=t et ...
S.W,t;..~ S~llfJ~ V"~gb.t ~~1U,:,.
TH;;s fa 1<t 1.l.d\1t~ 1fJv. th.st l '1>4f tta•1ul t>y ttl-.~~ atttr~-,.f!:. wt..1 i Jt£, f;tbP'.>~:Y 19. 2J$P} ¾>t d dJ:t rr~ k~ r:1~~m ;')l;i!a. C~ffiic.t.") ~~td}~. f Wp$tl ;inh1t '" ~ ;'Jt-,it) :..\sp.:m)n ?/Ytii-rm:.t~~~t)l A
? u~t.3 f:'{l 1.;), ~ ,t.t¼~'\ ~;l':.tbl;t .;if :3-9;::h..~l:nnh~)f j·.O<!}.,M tGC'ai tlme, anrt {0: IM~·cu tJ~ r;,1.-,,1'1 i~h~~n, N.2~<2:.Jn) ft!~ ~mq dt.J t;) in)' v&~~ff$U h,,m-.~- tJ~P~lm ~C2)Cr'~ Fk~rid~- f {j)!~gf}! to :J;)Ni
Beac.h lttlam;3fit).1nj .ait ~'\J't h p~~n thmdt. Y:¢1:4~ -.3t '{7ppttid:n<1:tt!1 t ·4ti,?~ mt.ut ~me O,ts f~..m.,.t~y !$, t<hg 3~ h> J~}"•ij~ 1f:f ~(l,Y~ ~ ~nrrw tit P-J~ $f«t:lt, R~~i<fa µ~tmi:3?')' 22. l01<},
On ~ i'?:J:lN-3;,')' ~l ,. W H), er..,~t,:, tt',, ~.(flj i1<~~'.i\ ttl)' \m(';.'3{kl1 h ~ \ t~ ff~ <..;,t:,,:>,lj'o~ 'N~ '{~. k~ Yba-. v«t:,e:r,e t 1r1.y~:;t SJ milj ·w-:1.H f$u-.1.y 2!), 2{H9, on
ro, ~- :l pt~~·1 to !:,:s-.~1 t:.'l r.-fi'!Jw.~ ~/a¢<~ft l¢J(i:', ftmn ~, •+,a~~;-s M~m m fJu~ Y!1f,<\ 8 -t :w f<;:rt< m•1 '(¥"$)~\ ,<t#t:ts ·~ P.1,~. fr,31~zy,,, ·t<> dnJ:V,t m t~ '$et..<tij\H l ~?}:ic fJa~,
~;1~:'¢~ml.l~ij¼f i -i ePM k ·~a~ d.-nt urt f ti"t>N8ry 2$, ZOl9 M~ ~:'} fs?!sy ffW ~8cot~ - hemt, tn. P.atl:s,. t'twcn.\h-::H M3{:h 9, 2-9 1!3, On Miir<hS. :WH),. ,J f,1!11'\ ~i; 1~m ~.f ~!lv~fo uttunft. N?.'<Vf:)
~~4ti~tt1 ho:f,,; ,:. P..-ir.~, Fran:::~ 10 ~-n:r P'~(ma~~;u re.sfau.nr:~, fo m-1$ \J.&. V:r-a~~ ~~GtY.!'.s.. 111itmc:t fi3 ;,r.•i'fe at ~t:l €:. lttt'errmtb~~ /4m)?1 <rt St. Th~tt~l. tUt 'fit$ir. w~,-,d~~,n Mi!Jfet• rs, 2<
a;.tP-:~J.im;tttt.r 1~ <iPM ~ t ti-~& . \..l hd& tr.i:¥~Rl~ &~a~1, j ~ $S bi! ~m-) &~l>:!rl ~, m1 ~ 1 ' te!~~~ num~ $ . m::::'P;}.-£ilff, )tt ~d~~~.., l ! ~" ht! 1.~"J~t2,i-t,t,d ~~ush ~'f b:uSh1~!~l <l">ffilt.~
~! 3,9,7:tS:,.:S~ tr.t'o-.>g!'\ <?',~ i'd lt#n\ly,,. l}~mm K. ~"4~.>:t. ~• • · · ~4»1}rn,!,i:i 'fC'!$ ~"'<t'$ flVJ s1'iti.':m ~1' ~u t, V'i;J~ a~fa~)<h. ~m M~W », ,t.~t~.
011 f'ti, f'.~b 22, 2orn al 9:1 t AM Shani Pinney ~lMlPim,.;v§h:y;,r&> wrote:
Good Day,
I am only now responding because I have been out of the office. Please note that
an appointment is not needed to fulfill your registration obligation.
In the future, re-port in person to DOJ to register and there will be Investigators
A!so, ! have not received your travel details_ As you are aware these details must
be provided prior to your departure. Please provide by the end of business day.
From: J <)BLC'hlc0J,tiomW,;n12H.ccvn>
Sent: Monday, February 18, 2019 4:36 Pfv'!
To: Shani Pinney; Darren !ndyke
Subject:
Ms Piney , i am m, isiand until \t,% a, noon , Imd will nol ceh.im to !h<3 l&//it)'Y until the 2(Hh o1 marcn. my r,ag,~tration dak, is
m~rch 5 , wot.di ;l()~J pr:e::.tf~~t i watt untH my rowtr: or wvukf ynu p:efer i t~Cfna in tues morr:ng. th:;'<>
p!eaz"' not<?
The irsformalit:m contilinB,:i in thi, comrntinio,;iJ'on is
<:on.frjenHa!> rnay be attorrmy~dlant pfr,dog~~dl n1ay
(:ons!Hute inside intormafa)r\ ,1.nd ~s kdar:ded ~:;n1y- for
the i.,se of 1ile addm%ee. it is !h$ property d
JEE
Ur.w.Jimrf:rnd uw, dl1dowre or c0pyirig o! this
cr.HT1mt1nfcaU0n or ,~H1y- part th~3.':ru~f is stdeUy prohHited
ar;d n-::~y be urJawi:.J( H yo~ have re<:ei~lt~d this
cornmunicatiori in am:,r, p!.,,ise rso,ily u~ irnmedi$te\y by
return eHr}aH or by :e--ma.H to )?{:}'·}~~~-~3t0nW~::Jrt:q/~.~>~Hr~ ;1nd
destroy thts C(:rnm~nlcation and an ccph:s lhen:H)f;
inrJ~)dino aH aaachrn~:r;ts, copyright ~aH tights ri:::~served
rle.ise no!e
The lriiormation contained in this ccmmunkation ic;
,:onfitfrJntia!~ m-~1-~ t~e attJnlByAcHent pdvHeged~ rr:&-..>/
constit~)ttJ irsid~;; fnformit!on. and it; intended o~iy f(~t
~~ 1.Js~~ of H1e: addressef!, it is the: prcp6rly c_j
2
Unauthorized use, JisdostJre or copying ol !his
communka'Jon or arq part \.l,$teOf i:, ~\ricctly prohibited
and ff~ay b~ tu1!avlft~L H you t1rr-1e r€celvtd this
c-:m1.rt1!..mh:aUon in {Ftor p!o.ase notify ~)s frn:'fHldiat~]y- by
1
please note
Toe infounatjon contain~;;ct in this comrnunicaHon is
wnfidentl$l, may be attomsiy-dient privibged, may
consmute inside ir,brmation, and is \n!sinded on!y for
th;: ~se of the address.eo. it ls th:$ propert'/ rd
JEE
Unauthmiwd use, db:;l!Jsure or copyln;J of !his
cornr:n:..w:ieatlon or any ptrt thereoi i~ ~trictiy prohibited
a:nf{ rnny< tH:: unia'>. .iflH. H yo~,.; havs rece~vctJd lhls
C!.)i""rH~ounk~.atk)n b ~n{Jr< pk.•asa s:r,tify t.S 1·r1~rn~ciat:dy by-
n~tt.nn .. ff~dj! or bV e~rn~n to i~':t-~t~.~·i~)t GN::1f!@Ll;stt< ?tld
d.:,stroy this communk;,Jion and a.Ii cop:e, i.hereol.
1nr.:luding all attachments. ,;;opyngh\ •ni! righis reserved
Exhibit 7
From: J Jeavacation~'grnail.com
Subject: Re: Registration & Travel
Data: February 22, 2019 at 9:26 AM
To: Shani Pinney Shani.?inn~y·~vi gov, Darren lndyke
p!eese confirm that ymJ have receive Wit' 1;1rnails I jtJ(>i. .sent showing rotiiicalion Bdcm I If.lit and you show!rl have additional travel
details irom at:ny lndyte . ii nm, pleastl let me krn1w
On Ft1; Feb 22, ::z-019 .at 9:l1 Afv1 Shani Pinney ·<§tJtt. FJnt/tiJ.fr.{ q·qy:> wrote;
Good Day,
I am only now responding because I .have been out of the office. Please note that
an appointment is not needed to fulfil! your registration obligation,
In the future, report in person to DOJ to register and there will be Investigators that
can assist in my absence.
Also, I have not received your travel details. As you are mvare these details must
be provided prior to your departure, Please provide by the end of business day,
pieaM no!e
The inlormation con\aintd in this commlmi,:ation b
r;onfaieritiai, may be attorney-client privil,09eJ, rnay
conslitule inside infnrmation, and is Intended onlv for
tM use 01 the addressee, It is the proporty of ,
,JEE
Unaulhor\wd use, disclosure or t:opy!119 oi this
,::,ommunioaticn or ai1)l part thereol is slrictly prohibited
an,j may be wnlawlul. !f you hav,,, received !his
ce:wnrrrunlcaH0n in e:rror{ ple.?;;se us knrnl2d!ately :oy
rnlllm e-mail or by e-mail tc Elli1ili:i'1Lli?ff'.\LJ!Tfr10/U, and
destroy this cnmrrit;:rfrcation :.~rn:i tcpH.3S
irn::1wdin9 «11 atmchmrnnts. copyright •,illl rigr,ts reserved
pltlase nole
TIKl in!tmnal!un co11!ain,~d in 1his communication b
con!identia!, may be at\orney•client priviieged, may
cons@utc1 ,nside informa1bn, nnd is i11w11ded cnly br
tt::"rwse or tile wJdressee, I\ is the property- ol
Jt:,:;
Un;iuthoriwd use, O!sdos•Jre or cop:;ing c,! this
wmmunication or any pert 1h•~reof ;s strktli/ prohibited
and f1',a:y be unlawlwL I! you h;;we mceivtid this
Gom.m,mication in error, please notify us immediately by
return e-mail or by B•mail lo p·,NRC,60,1'.)qrrqiL<:nrn, and
dewoy !his cornmunicatlon and di copios lhersof,
inckdirig all atiacllrn,,,?n1s, copyright •a.II rights r%MVNi
E:xhlblt 8
Clid you rccieve aitny lndyk~ new n<rtica .? and may I have a number on which ycu can be reached th.s afternoon.
I searched my email and I did not receive this or any correspondence from you
on the date February 16, 2019 as indicated in your attachment. In the ·future, cc
SOR Investigator Augustin to assure that the travel details are received. Agent
Augu stin has been cc'd in this email. Also, you are required to report on March
11th after your return to the USVI on March 9th to complete your yearly
registration.
From: J <j~~vs1catior)@grn.ru1.&om>
Sent : Friday, February 22, 2019 10:19 AM
To ; Shani Pinney
Subject: Re: Regist-ration & Travel
~If 'Cdt,1'8 t 4,,;;¢J$.}S",;:i-.r"M
~ ~.i.'t
$."<+'o ,~,...,,r ,$.~4,.:.\!:.(t.$.W1', ~.rc~ d,'(/jf Q "4). ~.-''!. ~ ~~ "
s.SP~1
T~,nv..-i~ $\>~ O!'..e:"ld$-r R.g~lWf P(CIJt.i-,, ~fM.ag4,
,,,$1, 1,1o,,,-, Oep,,11m1n1 lJI ;.w,w
Vri1¢C &1re-11 \41:jr, fo!.md3
1lt1' "to o:O'(l1,u,p.J itl~l I w-;l t:r~-<~ '!>t~'Watt \f~~;;iU, Nl1Z,t. <,:n f ~t,N;~'Y t!t ?Q1f,~ 3day !ri;t kl P::~f".» P~ , . Ocn,~c:an tl~c..bk I wpe-ci :i;,-;i,. al ~ti~l.l;µ,~ r,,1c,..,.-,~~:.
?\,,.,n PIP ( > : ; ~ ~CS'.I.Jtu ~! i.i9ptG-4~:•11 ~toc;w .-ndk) : ..-~ ty p:,tdt: .mc:tlM ,.211~~~S,)("',8 'J.."ljlG-~ .,~~.~~inP-l'«', 3o:.t.._,f'~ 1t,ooetti:> ~
BeJOI tmtma~-- P~'ff 8'1:£"\. F'# t i a:1 af~:JW't'Qtwi 4'.AS?J.! F~..MtY l9~ ,o,i &.-d to &!4'( .al er, v,aau:-.r, llOlftt fn: P--Jtm tk,YJ\. fb&S) Wi.tll f ~ J 4'1.. 2019
CM !IL?.,1rr 22..., 2C>f) lct.,1:1 t> :rA'-itt1r<.>-nmy\'J~o,:i ~ i , . - , P~-3~,._•l\. Flaitt.'u !tf tft'fV-.)t.¥~" ~..c <n Nr,,,. 'Vat'\, ~ -N Y~...tl!to f <tJcpe-es~,w,yu~li !=:tt:~ M. at1S. On~*
:wio. f Pttn U) {:"~'1e! '01 ;,t¼t",1t'.S .vnt>'Sn, t42t2J:f t-cm m-, ~iit::i~ ~ ~,~ Ne:-?, 'fee~ N•:::-w Ytt). i~ fTI'/ ~ <"'..1fM h~ (tlj ~tl.':,i., (,(;jf\Ci!I, f i:tfti'IU ff) t .. l¼iJ!gtll Nn>e-\in (..:,,~
-~r~••l1'::::tlutr 7~~.M tOf;.il t.il"l'l-~ 4:n f'~uflly 101·9 w.O &:, tr«t -1:t mi ~~UM Jtcmm nt ? ,iih$>FtM~ {S1)!11 M.a,eh S), l019. 0:"? Uarch I), :,(Jt!l_ f p:31~ lJ,) tl'h!M tf)' ~"94..t '°'(l(:,.It U2t2.xi,
¥W:,41t:Ull c,~ :
x': Pari:,,, Fi.JI'.(.'!$ W ltl\' pc,h,~!W~ ,es«i:c.,na, }ti lh•J v .... ~'i(9f'l lstl..,.Jl j e,:~d b U,OJf! ~; t(._~ ~n~na:JJ:1.;, Ai,-;»1 t:, .$1. lhcMH US \/-.rftc,. Jst,1:ndl Ht ,._~ Q. 2t
3.;)~rc~rr.:.,at...11:QC:pct.t ?:3"'..e. ¼"'t.11-1: 1,, ~s ~:¼I.ff.. J e..'\!\ t:• oen~.t<S Cl'!~; Ntce ~l)t',OI"... " " ~ oit 7.t?•».?·)13:t r. ~•.«- 1 G.1:1 cic"1.~ed e,~tl' PY .-..SM<i;i.
t)l li_~U~f~!~« lhtw~ r;-v a~'$,, Oavt'l"I K, fn(r~ 411 - ._~ o'""-il '1¢c.r-dt.t --~ ~co!~"f\ " lh~ \1$ \.1 :t"' W11"W~~ M,s(CJ• ~. t-3tt
a '/(>•I fl<Jr.cl i;n f fW~Qr' 1.flf¢1"'-U~. p<lllim MM~foef fo:~ (.Q ():ld:l nt)' ~th~y, C-.4Mt"A ~ . <~:fitt
I am only now responding because I have been out of the office. Please note
that an appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators
that can assist in my absence.
Also. I have not received your travel d etails. As you are aware these details
must be provided prior to your departure. Please provide by the end of
VI-JPM-0000 12465
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 140 of 196
business day.
From: J <!@>:acatwo@ornalcorn>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren !ndyke
Subject:
Ms Pirnw , i am t1ri is!,md until tues at noori , and wi!! not rnlum to !he terri/o,y 1.mrn !r:,e Wtr, of rnarc\ my regi,tmtiori d;;it0
:s march 5 \:V(HJtH you prefer f v1;;d tr.t]i rny r{:turn or ~vot~k1 you prefer f c0me ~n iLces mornt~g. thx<
1
please note
The inforn~attm <X!t1ia~n~d h1 this. r-orrimunkalion ts
~;onfa:lent~td> rnay te attorneyAcFont pri:.;ltJgtd< rr~ny
,:onstb.lle indde inf,::irrnaiion, and h, intended ody f:ir
the use o! Uw addwssae. it is the propmiy of
JEE
Ur:auth-:)rl::r~Jct use: dlsck1tlfff or (~opying :)f this
communication or any pari l!',srnof ls s!rid!y prohibited
ar1d may be w,!awiuL Ii you have re,:eived this
cornmunicaiion in error, please notify us !rnmediale!y by
return O•·rnaH nr by ehrnaU lt~ fJ~\:~.h~~~~~hn~a~llillJl .:::(1St and
d:sstroy ir'iis cornrrHJnicanc:1 and aH copies ther~of~
iridudirsg a!i att1chmer,t$. ccpyri<Jtit •a!! rlgrits r,}sorvod
pteaza rH)tfl'
The inlc:)rrnafo;;n cantah:e~j in this (:ofnr-nt.:t~ic~t~on is
ctinfidenfaii, may be a.ttom,w·di,.mt privliaged, may
rnmnute in,ide infomution. and is iriterid<'!d crily for
tha use of ~ho t.1ddre.ssee. His th~ proo{nt>t ~,f
JEE ...
Unauthorized uzei (frsc\o~UfB or c-wpylng c-f !his
comrnimication or any part U1emof is strkt!y pmhioitM
and may be iJnlawful. !f you ivive recdv,.,,d this
:;~1;~~~~!::~~ ~/~;'.~~~fi!~~;:1 ~,,~~!~',~,:,i::~r::~,~i~~;;, ~~,j
destroy this ~::::-on1rrn.mlratlnn and an coph~s. tht:reo(
inclu,jing au aHachrnents ;:,opydgnt •ai! righ!s reserved
plsas.e :1{)le
The information contained iri this communication is
conl]df;r:Ual. ITlUY be >;1!t(}}!1€y•tJlenl µth.tH~g8d~ may·
cons!Jtuts in,;;Ue iriforrnatinn, ad is int<1nded only for
tr;_:,:'"e cf the a,Mmsses, Ith the pm;:mtty cl
,kc
Unauthorized uze~ disGlos~Jrt-~· 0r copying of this
corn:::w:ie:afo:H1 or .ar:y part ther:eof is strictly prohltdBd
arid rna.;,' oe un,awLL l! you haw" rsceiwd this
coromuuleafa:m in €rror: pleast noUfy us irnmediate!v by
fettiffi fr-maJ! Of uy· -8:rff~au to i}:H:/?~~:jtk:~~: {Kq:::,)~~-C:::~:nl and
dotiroy lhls communication and al! copies thereof,
fa-'1ckH1!ng aH attachments. c.opyf~ght ~an r(ghts reser.;~;d
Exhibit 9
rr·
Subject: Mr. JMfrey t pslej;;
Da t·e: j::.~l.-)r:Jart 2·t,. 2C 1.§ a:t S·5?':(f1 ~}d ~5:r
TO! ·Jm~.!21.,QiJill~;), < T}'o•
t:\~r 11•r :Zl>Ji [ "'' . s ;:,< ,l)l'H~f "sWhilitlt.i;"u!:ioLJ!.ls&t"
Ce : DtH'~r; u,~:;u~ . ·---·-· __________
Ms. S, Pinney
Territorial Sex.ua! Offender Registry Program Manager
Virgin Islands Department of Justice
United States Vitg!n Islands
This ls to advise you of a modification to Mr. Epstein 's trave! plans. Mr. Epstein wii! stay at
his vacation home in Palm Beach, F!odda until February 24, 20'19. On February 24, 2019,
Mr. Epstein plans to to travei from his vacailon l1or11e in Palm Beach. Florida to his vacation
home in Now York. New York. where he expects to stay unti! February 28, .2019.
On February 28, 2019, Mr. Epstein plans to travel by private aircraft N212JE, frorn his
vacation home in New York, f\Jew York to his vacation home fn Paris, France. He expects
to arrive at Le Bourget Airport in Paris, France at approximately 7:30PM !oca1 time
on February 28, 2019 and to stay at his vacation home 1n Pads, France until Ma(ch 9,
2019. On March 9, 2019, Mr, Epstein plans to return by private a'ircratt, N212JE from his
vacation home in Paris, France to his permanent res1.dence in the U.S. Virgin ls!ands, He
'-"Y'1"1'-"1"t~ !r~ ~rri,1.-:, C1t (:\fdl S:: k'inrt lntPr'<1:=tfinl"l~11 !'.\ir nnn i ri !;t ThtlmJ:i~ I I \JlMiri 1~1::in rl<: nn
...,, f , ..,.,,.,_,...,,;. ..., • "V ..... , / • • ·• · - • - ; ~') -• •<• ) •~ < • •<,--• ( )i,,.'\!o,.l < , J • ) - t >•)r--- ~•-·· ••i ..... .. , , , ..., , , , .......... ! -•-• •ot::,<A< <,., , . ..... . ..... 14' Vl t
Mtirch 9, 2019 at approxirnate!y 1:00PM local tirne, While traveling abroad , tie can be
contacted on hls rnobile telephone number at 2·12.533.3739_ In addition
contacted through his busit1ess office at M_(l-775-2525 or through me at Mr.
Epstein 'NiH email your ofiice upon !,is return to the U.S, Virgin Islands on March 9, 2019.
P!ease confirm by reply email to rne your receipt of tf1is ernaiL. n iank you. Ms. Pinney.
Respectfully,
p1eru;ent1te
The !ofoima!ion cont.lined ir. !ms cc.,':lm:.i11lcati(m is
confider.Ha!, may he attomey-cil~t1r. privileged, may
COf\Sti!.iJte inside ir1io:mari;;n, and ,., lnt(mded orily for
the :.1.sa d the adt:fr~ssii!e. It is lhe ::ircpeny ot
JZE.
Unaullloril'.ed use. dis<:losure or copyln[1 of this
commun!cat!o11 or any pan thernol is strictly prohibited
ond fila-y b-e uri!awful. tf yoll have receiW)el this
comrnunicalkm in cm:ir. please n:ilily u;; immediately by
rotun1 g,maH or Cf./ e~mail to i*Y?{H.ft.~1~nt1tiLc<>ti1. and
d..sir:>y lhfo o:Jnitm.1nicafo'1 al)d a.Ii <io~eil tt;er¢of,
inc:t,ctfng all altachmer,ts_ copyright •al! : ights re101ved
Exhibit 10
J @
$,J·;i.;;::;; F;ld:~gi~~~llo.~ .&,T;a~et
~:"):H':'1• ·P C ~ -~••,,:~• :,:~.:>">:•;-:::. •; . , , •·~
On Mon, Fet> 25, 20Hl at 9:00 AM Slla111 Pir,cey ~nan, P!n;aj!ltW'~ IM'olo:
Good Morning,
From: J <jeevaca«on@gm~itoom>
Sent~ Friday, February 22, 2019 12.:03 PM
To: Shani Pinney; Kevin Augustin; Darren lndyke
Subject: Re: Registration & Travel
did you rocievo attny lndtr1es new notice .'? and may I have a manber on which .,-cu can tJa reached this aflernoo;,.
011 Fil. Feb 22. 2019 3\ 9:43 AM Shani Pinm,11 .;.:;\hai:,J½;r,t-,~~:rltl>7f> wmte:
Thank you.
I searched my email and ! did not receive this or any correspondence from you
on the date February 16, 2019 as indicated in your attachment. In the future, cc
SOR Investigator Augustin to assure that the travel details are received. Agent
Augustin has been cc'd in this email. Also, you are required to report on March
11th after your return to the USVI on March 9th to complete your yearly
registration.
From: J ~ v.acmtlon@gr:uarLcom>
Sent: Friday, February 22, 2019 10:19 AM
To: Shani Pinney
Subject~Re: Registration & Travel
•. s. f'W,ey
Tc:m!!I:"~; S{_.i;•tlr;?<~:·, m
¼'"9" tJ.i~ Ol::'RC"~-=·.e,.;~ J"1.t.:.111r,
\Ir.* G'l.~S V'..-;r,t'! !do1M.~
lM 4 lG a~u l'-~ .. , , I w,;: vaN'J cy O'>in.!e !o·a.~.. !'t11US. (;S'S f'tv-<-i:.atr 1S. 2-~;i f~ c.a1 lr\t) r,: ?".x;.-..i ~tU.. ~ ~.., j.i_C/A.~:.. : ~u~:.t _,f O(e;:,..¼ L:>~O:t • r . ~ >
P::~r~ ?'..a.b. .2t ~~)..-m.l;N°; , -c,o~~t t.t):$'"> .. !; t:.-v-:: ~.,. ¢~q atcr.a...'-. N2:~e, !r.3? Uf"'..A <-~1 ;r,. ~ , <1~t~~ s~ Pa;.m thee-~. fl~•- ! tt"SW..d !::> ~rr~
;,-i,nrr:al>ooi! -~ ~ Pia~ l;i·•6'.n, ~da it d~!'eAAM'l.:;;:;s:y tkl6?M ti:::q :me ~,tb(,JlJY 1P' ~Hi 0~ ta ,ui;r ,u (r;t ;.,,,)(;41~n mJnttt :it./:~ Set:.!':: F-1.;f~ '.l,o\.1'.-()ty 1;. ~~'{::
C~Flt~t...-u:.,'12.. ~..)fli:., l~~ ic ?:,i•,e,lt1omrry1/JS1'Y.,;()(l.he:':':itJ :rsr~m:8+ach, ,!<:t!<i~~ 1acM)OO ~:(':.!'.t!W ~ t.. ~ Y:xtc'. ~~: ~..1.~ :'(;. 'U,;Y'/~ ;:i'OQ.Q.y~. ~~<J ~rd;
lO !l.: l>.ic:! mll.¥fflfl,/ ~ a:ta: ~-.1.:s.~ f.Q:1?~..
~;i,:t'Qt..~.¥!.~ 1 -~~ ·-.t1 G,:~ V! ...-v, 1:-&• .W~~ ¥.,
m1 y;~}Otlt~ ;." l'iilNl"ttl1'.. ,,.~-\.·(1,11,. tu m 1 ~ ,,-:"!W-h P&.~--s.
x: \.";;l'f :-:-.--; oca"".J.C-l i, P«-S:. Ft>:"='12 ~..; ~., S. 2019.
I ~~.11!':!~ ~ ;..• eat:~ ~fr'lfSa;:.,.,JliU'
ttltft., 9. ~ ':9. i t:> re•\P.' ~,~10 ~ ta:S\. N?.1( ,.L.
VXl to!\ t'--,'A',~ !J\ p ~ , ~ t.e ey ~S,.~t,;:':~ n~-s ~• io ::."'¢ l.:.$ ¼~n lit;l"C:... 1 C,,.1)0('! k *';\"('; l'J~ C"r."' 1 E.. !-..,1'19 ,~..:a;:;.;.-~ Afl')Or. ;:-; $ ! fOr.:tf~ V s . ".:~(1 :311;):'IC\ en MiJ~ 3 .
•• • ••• ,. •• ,r • • ,...,.....,~ • ••••.-• • , , ... ., , ..,. , , • .,_ , .,,..,.., , ••••"' • • • ••••• • ..................>, ..,, • • ,,.,,., ... . .., •• ,_, .. .,.., ,...,,. ..,.....,. ,,.,.,,..,• • " ~•.- .... . ....... .... ....... ..,..._., .,., ... , ; (~, .
VI-JPM-000012469
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 144 of 196
:¥.··N
~-V+>nM:mt ' v:_,,...,_,. >l)\.o.h n ,_ ~•,...<!:~ . ?. M Y : ~:"!~ :.c,'l««•~ W • . .. y :~:v.>1:•-.l'!ut : ..,,~-:,._~~ »> .t •s ..,::.J,;h,,., ,))· •·• ~1~1-~ ~•, .- , ~ : v~ l-.W•~«t,:::;'(, ~! 'Cl't lW.J' ~ ,xt ,A.."l<:,:<::-; w~t:
«~ ..??~2.3~ f~ t.'l~~¢ ~ .-, mt-.;>:·?m~~ n.:a:"ffl~~ ,( b ~~il. Y-:fr.ff t;if:-c¢ i.$.'t:1 nr-1 t<-1J.K.1' to (rw I.;.$ V~·!tin !$~-:~:,s Mwv.'! 9., 7-Jt;:J..
Ori Frt Fob 22, 2019 at 9!1'1 AM Shani ?innsy <;Shad P iiww~',l•/;,J:¼'t.> W(otO:
Good Day.
! am only now responding because I have been out of the office. Please note
that an appointment is not needed to fulfill your registration obligation.
In the future, report in person to DOJ to register and there will be Investigators
that can assist in my absence.
Also, I have not received your travel details, As you are aware these details
must be provided prior to your departure. Please provide by the end of
business day,
From: J <!filiY..@C@t:IOJp-@dmai!,¢001>
Sent: Monday, February 18, 2019 4:36 PM
To: Shani Pinney; Darren lndyke
Subje ct:
,>,,ts Pl ne<,: • i /.lffi on !sl,md until tues at 00011 , -iilHd wm n()t mt1.m, to iho terrilo.ry on!il !ht! 2-;>:h of march, my regi,,trafo:m
date is march 6 . wcudl 1c,1pr~uir i wl!.it until my return or wow!d you ptefs: i come in lues nmrn19, th~.
pleaso note
The ltllcrmatkm <:,:witairied irJ this cornmunk:ation is
confidential, may be atlorney•ctlt><,t pfrAleged, may
cor:stiture insk!e ;nformatior., am! is intend:id only /or
the use ol the audrosse<.;. It is the properly ot
JEE
UMuthcrite<l @i¾, disdosure or copying nt !his
communication any :,art tr1erenl is strictly µ,ohib!le!'.!
and may bo !ltilnwiuL 1/ yow have received this
c;ommur,kalion in err()(, pl&ase notify us irnmediat~ly by
return e•ma:1 er llY a,mal! to iM.?J.\1!.l!ili'c1!1l!i-i!'.fill!Areffi, and
<ros:troy !his commur,icalion and nli i..'Opii;a mer11vt,
t:Kiudl,-9 ali at;achmentS- copyrigN -a:1 riQhts rsserwld
pl8aS~ t:~to
The fnklrmalion ccntainoo ifl lhls ccmmunicaticm iS
corifidentiat may I¼, a!tom~y,cliMt pri.vHeged. may
const1t;,ite inside informatfon. end is intended only lor
the use of lno addressoe. It ls the property or
JEE
Unauthor!zed ws.e, ditdosurs1 er copying of lhs
communfa:alicn or any p a11 rh~roof is s!rictiy prot.ibited
.and ma,; ::ie urnawtul. II you 1\avUi received iJ;ls
comm1m,catic;1 ir, ,.mer, ·pleai;., notify us imtn<~dlat.aly t.;y
r eturn e•maii or by-0-rnall to 4J;!,.W~&ti~,:l@r,p,,ii! g,:in. a11:1
destroy !hia .:omir,unicatklrt ;1nd ail ·,:o;iies thereof,
inc1';ding al! a!l1whm()!'1ts, copyright --al! ;ights raserved
please note
The i-?liormafon contabsd in !his c,;;mmunic.ation ls
confident,a), may be atlorqey-den\ pri11i/e;pd, may
constitu\e ins\de inforrnmion, .and is intended anly tor
1he ui,e of !he addr05sae, It is th•3 prnperty of
,JEE
Unaulhoriz(ld use, drndoswre or copying ol this
communlcatian or any part therei:}f iS Wictiy prchibited
,md may be unUwbl. H you rncei'>'ed !his
cernmunica\bn in error, pleas(l nofly vs imrnedia1ety by
n:rtun1 e-mail or by .e--maH to 1~:HJ\f,;c~_,:::~1t~;i:~t~(t~rr~<H.tc{n~ ar:d
destroy 1h}s cnrnmuni·cation and an coph:.m thereat
induding ail ai!ad,01'-'Jnh, cop:1rlght a,1 righls reserved
0
note
The idorrna1ion oJn\alned in thb c-mrunu11ic.atim1 is
coniiderl!ial, may be at\orn,,y-,;::lient r:idviteqd, may
con~,tiltlte inside inform,&tlon, and is \nt.imded onl~· for
!hi] use of the addressee, nis 1h0 properly or
JEE
Unauthorized us,l, dkadm:,Jre or CDp'.)'ing o/ tr.ls
cnrnmunlr.:alion or aoy part th,imol l.i; strictly prohib+xt
and rnay be unlawful. I! '.,'OU have rec;;li>Jed this
cnrrimunicBUon ·::n encr, pleas:a notlfv u·s ifnrnedlatr.::!v bv
rehnn o"n1aH or by e"rnaif to ht¾:Vfl.{~~:~~·lk;n(JirrrmiLps-~~) a·nd
destrny lhis communkatlon ,md all copies ·thereof.
including all attachmenis. ,:;,::,pyrigh!. -a!I righ!s res&cvad
VI-JPM-0000124 71
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 146 of 196
Exhibit 11
Good day, Ms. Pionney. Hope you are we!!. Can you pf~as::l confirm receipt oi my orr1011below.
Tnankyou .
Ms. S, Pinney
Territorial Sexual Offender Registry Program Manager
Virgin Islands Department o f Justice
United States Virgin Islands
This is to advise yoi..1 of a modification to Mr. Epstein's iravel plans. Mr. Epstein will stay at
his vacat10n home in Palm Beach , Florida until February 24, 2019. On February 24, 2019,
~>1lr. Epslein plans to to travel from his vacation home in Palm Beach, Florida to his vacation
home in New York, New York, where he expects 10 stay until February 28, 2019. On
February 28. 2019, Mr. Epstein plans io travel by private aircraft. N212JE, from his vacation
home in New York , New York to his vacat1on home in Paris, France. He expects to arrive
at Le Bourget Airport in Paris, France at approximately 7:30PM !ocal time on FebiUary 28,
2019 and to stay at his vacation home in Paris, France untii March 9. 2019 . On March 9.
2019, Mr. Epstein plans to return by private aircraft N212JE, from his vacation home in
Paris, France to his permanent residence in the U.S. Virgin Islands. He expects to arrive at
Cyril E. Kt"g International Airport in St. T homas, U.S. V!tgin ,siands on March$ . 2019 at
app1oxirnately 1:OOPM loca: time. While traveling abroad, he can be contacted on tlis
mobile telephone number at .?1;2-533-3739 . In addition, he can be contacted through his
business office at ~Q:775-2525 or thrcugh me at Mr. Epstein will email
• • ~ " ... ,~~- . . . t I /"t
,., _,.., $ ,,.l_ • ..,..,f,.,. "' ~- J.A ... . , _,,.
(.,.,' _ ,. , .. :,.,,.,, .. t, ,.. ,..."".c"°'
,1,i,._._. \ /! . - .•. ~._ r,,.
Please confam by repiy emai! to me yoiJr receipt of this emaiL Thank you, Ms, Pinney.
Respectfully,
Exhibit 12
At Ms. Shani Pinney's direction, I am forv,,arding a copy o1 the travel modification notice for
Mr. Jeffrey Epstein that I emailed to tvis. Pinney yesterday. Please kindly confirm receipt oi
this notice. Thank you.
Respectfully.
Ms. S. Pinney
Territorial Sexual Offender Registry Program I'v1anager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a modification to Mr. Epstein's travel plans, ~-.,1r. Epstein wlll stay at
his vacation home in Palm Beach, F1orida until February 24, 2019. On February 24. 2019,
Mr. Epstein plans to to travel from his vacation home in Pa!rn Beach, Florida to his vacation
h"mo in 1\l,:,w Vn r lt l\i P1111 Ynrk whA(o h,:,. AYnPrt;:: t 0 ~t:i " 1mt il l=ohmi:in, ?R ?()1 O ()n
V I-JPM-000012474
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 149 of 196
, . ....,, ...... c•• • • - • · ,....,. , ,. < • V •• •->••, •Ci<V I..., C•~ ,._,,.•-1 -•••'•' V..,; • - - • J --~ _..,. ,..,, -•C
February 28, 2019. Mr. Epstein plans to travel by priva!e aircraft, N212JE, from his vacation
home in New York, New York to his vacation home in Paris, France. He expects to arrive
at le Bourget Airport in ParJs, France at approximately 7:30PM local tirne on February 28.
2019 and to stay at his vacation home in Paris, France until i-,,arch 9, 2019. On i1,,1arch 9,
2019, Mr. Epstein plans to return by private aircraft N21 2JE, from his vacation home in
Paris, France lo his permanent residence in the U.S. Virgin Islands. He expects to arrive at
Cyril E. King International Airport in St Thomas, U.S. Virgin ls1ands on March 9, 2019 at
approximately 1 :OOPM local time. While traveling abroad, he can be contacted on his
mobile telephone number at 212-533-37~9,. In addition he can be contacted through his
business ottice at 340-775-2525 or through rne at Mr. Epstein will emai!
y()ur otflce upon his return to the U.S. Virgin Islands on March 9, 2019,
If you need any turther in- ormation lease feel free to call me at r on my
mobile telephone numbe
Please confirm by reply email to me your receipt of this emaiL Thank you, Ms. Pinney.
Respectfully,
Ex.hibit 13
Good Morning,
On Ftl, Fe:n 22, 2019 at 9;-l3 AM Shani Pinney ,~fili~mi. Pinn.l['J @vi.rm..
V> •Nroto:
T hank you.
I searched my email and I did not receive this or any correspondence from you
on the date February 16, 2019 as ind icated i.n your attachment. In the future, cc
SOR lnv,e stigator Augustin to assure that 'th e trave.l details are received. Agent
Augustin has been cc'd in this email. Also, you are required to report on March
11th after your return to '!he USVI on March 9th to complete your yearly
registration .
From : J <jeevacatioo@gmafl.CQm>
Sent: Friday, February 22, 2019 10:19 AM
To: Shani Pinney
-
Subject: Re : Registration & Travel
~r~~20 1,.-t~tN
:t ~ "Mc.t,.~•Ht~J11• ..,_,..~#'>l~""'•~_....A~t,t:;'C'¢':~•
t. S.?)M~~
T~l"W~ Si.W~h' OJ~'!~ R~or1 M-1~!
V~"':- WM.CS ~ l'trrJJrt :,.f ru;:set
Ul'i!l?t SIil•• V, g;, h;.ooo•
1~>& le'tl,!,,\M,V..-tf\,11 i 'lid ;-.a~ lri Pfr(Jr.¢ ~l$~N1UJE' ¥--0 Ft:!,!t.,a,"'f 19.. lfti!l 1::,t ~ d~(tf.tptc. r..,....... P'~..M. Ot~W\,U.~ Rt'pvbl';. I c-.pcc.& _..,,. itG!t:t;t:t'U(.'4)1>'!),' •m•ma~u A
"'"t,;a $'»,ta. OC'«'W..M R<-r,\.'.bt:C: lltl)";)f~S,,.) c<:W,.\ ,;,x:.:;1 \Jmf:•, Ait'ld !nt'lld O'f p.,..a~ ~=,¢,~!t, tt2 IZ~. -....~ S.:-00 th'{ lO tr-y './ifC::.-lk'n ~mt ID P;1)n) u~~t,.">,. f lon:J~ ( t ~<tel tu ,am'!{
a u~~J• t~te~:,~,a! .lutpQ'(t ;t4Jm Eh1;1c!1. Ft~e ~l ~p~uH,-tn;ttafy ff·4S?~t k~u: irne o n Ft5?Jru,lj.,.f 10, ,01'0 91ml ~t:i t1;1:t :,· tt'l'llC:a~i<)() h~tuu ti, P,1llN 8\t~n:it, f.~.i oodf F11b,\;tsy tt. t!"tH~
OnFtJ~':fv~r 2:.,, 2019. 1 i.lM fo t,w.•tt) l1orn 'rttJ{ \'1'~ti,~'\ ~to ilt Pa!m&tJOt, f"~kJlS tttmJ"~e-~tWff ~ t t t N&w-Yo-:, n~w Yort<. f nn•~::1ia Jt~')' ~r>ta f tt>l.v3tV:Zf. 11)1~ (Mff,~,
l~f9", ~--!"l
tc, k,1111Y b'y pn,,.f~ ~~fl.. N2i~E, falltt u~ "°~.
11.iUI r.c.~ h t.i-tw Yth\ . N.-n '\l'o,!i( l!) t""t/ ~.1ti<>l'1 ~-O:,t.)) Ut Pi,ti,;, ~,Ut'\(.l:t. 'J 1:x,p«.t !O ll't$11I a;l 1.1$ ~ J A. ~ l in .. ft'd.....•
(»;;~ate!y7.30PIA~lt.m~ c~,~~u,"Y2-l (.Ol:1~ 3'IJf tll~ ;ra:;~ r ot'f"C .nPW~f~~ -.mu ;YJ;a',9, 'lfH9 C)\M4~ ·:J. 2Si9. J tUJl'-tUR!:.t'rtrf~d: ,am:r.in. NZUJ:f_
v,c,a\,,~ tr.,r.q-'" Pa!'ls. Ft;.~ lo Mt -tllitlt«ml $Jdf::Y.A IN u.s ;,eyn 11~, t <U~ lo~..tn a:I Cynl E. tnt\U'l"IM'l~ A:i'";:io,1 in St, Thom;r, . ltS. \A..'l",;ft ta.line,- en ~rm 9 :(
.a~~~?r."'J 't.C('A)f: t ~ l t:sne "''~'°
•~:rs *~:Qd, I un oonta:--ed er my mot,la tcte~ r.w~ •t ~Z-J~ rn .o:c!c:a 9.!\, t u n bt <'Cf":la,."'tta ttoogft m-., l;,,1-n«i1
3~ ;u"•U~·.ll:ll Qi t:tlm&;f1~ ~- 1.1111c,rt,y, l)Mr&" K :t"IC)'«-1', w:l n'!:IJJ1l),~r IJ"ff,:~ upon m, ~ h.ml J:) n·n us -.'::1"9.r. tit'Ji'l¢; i:m MJ:;h 9, ro,,g.,
I am only now responding because I t1ave been out of the office. Please note
that an appointment is not needed to fulfill your registration obligation.
In the future. report in person to DOJ to register and there will be Investigators
that can assist in my absence.
Also, I have not received your travel details. As you are aware these details
must be provided prior to your departure, Please provide by the end of
business day.
From: J <1eevac@.tl0n@gmail.cgrri>
Sent: Monday, February 18, 2019 4 :36 PM
To: Shani Pinney; Darren !ndyke
Subject:
Ms Piney • f am on isiland unlil luei; at noon • and will not retum to lhe territory unbl the 20th ol march, my r-0gfsJration date
is march S , wcni<ll yov pr"ler i wait until my rerurn or w,iuld Yl,'lu prefe.r i c,mno in tues mornng. th:.i,
ph:iase note
foe inlcmmillon ~nla!rwd in !his cornrnonicat1on is
conlklantla!. may bo a!tcrney-clienl p:ivii~(W-d, may
cons:itu!'(i ins!do; information, and 1s intended only for
lho use <ii thiil ilddre$..~e&. It is tha property of
J ES
Una1J!horited use, i:!iscfosure or oop,11ng of 1hls
Of any pad \t!Ofl1!0( is ,Strictly prohlbll>::ii
Md may be unlawJu!. II you have re.ceived this
tommunlootion in twm, plllase not'!fy m; iin111odinte:ly by
mti1m e-mail or by e, mail t1:1 !~ 'Wi'l\io/\!NtrritV Jl.oom, and
d-~iroy this communication a.nd cl! ,ocpies there-cf,
ird udii1g all a1!achmen1s. copyiigh! •all rfgh!s rosi!l,ved
please not-0
Tl'!e in-formation conlaitiied b !his co1rm1ur1,¼;alion is
evnfloont!al, may be a!1oriwy-ctkmt privi!&go<l. may
constitute losilfu informimort, ,md is intonded only for
the use of the addressea. !tis the prop,irty of
JEE
Unaolhmized uso, di:sr.Jcsure or wpying of this
t:ornmunic.at!on or an,v p.1rt !h&reof is strictly p1onlbi1,:xi
and may be oolawrul. If you have r~.eived !h!:s
communicatii?il in error, p1e:;isa nc!ily v& immediately by
return e•maH or by e-mail to !~NYll~lion@mm•JL.'6l!lh .ind
destroy !his communication and au «--oples !heruof,
lm,fuoing all atta<:hments, copyright -all rlghts rnisorvod
p!f!a$e note
The inlorma:1ion t-Ontained fo this communication is
cooEdeniial, may be atbmey-dieo! prilli!eged, may
_ _.,_.....: .... c. ... ..... :..; ,,. :,...rN,.,,,,_ ,.,c"'"_ ,...,_,..:t : ..,. : ....a,.,_,4_..:i, .... .. , ,., ll .,.,
ph:,as,1 nots
The inlormatic,0 corrl;iined in this ,,ximmvnicalion is
confo:iential.~ mriy be aiton1oy--clisnt pr.iv!!eged) nH7({
rnnsUut1:1 inside information, ilnd h inten,111d only for
the use GI the addressee. It is the propmtv of
JEE ,
Unauthmiwd use, disckisurn m cony>19 of I.his
rn1mmunicasion or any part there.of i,; WicW, pmhibit!ld
anij rnay btt t.m:iav:itfu!. H you have- tT!Coivccl th!s
cormnunication in €,nm. plea~~ n.oMy us immediately ty
n~turn e--i-rH:1~l (V by e--maH 10 .~ff:'i12~lh)('/~F~~Vn~;Jp(:n\. and
de:;;tmy this communication and all copios thomol,
ir,ciurling all attad-1menb, copyright ,a! rights re;:,er1e<l
VI-JPM-0000124 78
CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER
Case 1:22-cv-10904-JSR Document 194-27 Filed 06/20/23 Page 153 of 196
. I
AP;l>~NDIX2
Re: Request Pursuant to Bill 29-0239 for Reduction/Approval of Notice Procedures for
Travel Outside the Virgin Island by Jeffrey Epstein
Dear Attorney General Frazer:
Thank you for meeting with me and Attorney Darren Indyke on Friday, July 13, 2012, to
discuss implementation of the new travel notice procedures for registered sex offenders under
Bill 29-0239 (including the amendment thereto), an Act amending chapter 86 of title 14 of the
Virgin Islands Code, to expand the laws of the United States Virgin Islands regarding the
monitoring and tracking of sex offenders within this jurisdiction. that has been passed by the
Legislature, and which we anticipate will be signed into law by the Governor in the near firtwe.
As we discussed and has been welJ-documented with your Department over the past
several years, my client. Jeffrey Epstein, bas business and other legitimate reasons that require
him to engage in frequent travel outside of the Virgin Islands and outside of the United States.
In connection with that travel, Mr. Epstein has an extensive history of what you and your office
have confirmed has been fully compliant notification to your Department regarding Mr.
Epstein's frequent travel during the period he has been required to register under the existing
Virgin Islands law. As we also discussed, we reasonably anticipate that Mr. Epstein will
continue to have notice obligations to your Department in the future regarding his on-going,
frequent travel, and we wish to insure that Mr. Epstein continues to remain fully compliant under
the revised provisions of BiU 29-023 9, as amended, while properly invoking the discretion of the
Office of the Attorney General, conferred in the language of this Bill, to reduce the notice
requirements in the Bill upon request of a registered offender who provides supporting
infonnation.
Accordingly, we respectfully make this fonnal request on behalf of Mr. Epstein that the
Office of the Attorney General exercise discretion under Sections 6 and 9 ofBill 29-0239, as
amended, to both allow a shortened notice period for proposed travel, and modification of the
ATTORNEYS AT LAW
1340 TAARNEBERG, ST. THOMAS, VIRGIN ISLANDS
PHONE: FAX:
EMAIL:
information required in lieu of that otherwise required under those sections of the Bill.
In particular, we request that Mr. Epstein be permitted to continue his long-standing
practice for notice of his frequent travel outside of the Virgin Islands and outside of the
United States, which your Department has verified as fully acceptable, of providing
written travel notice to your Department by email or facsimile from Mr. Epstein or his
legal counsel immediately prior to Mr. Epstein's departure. As has also been Mr.
Epstein's long-standing practice verified by your Department as acceptable, we
respectfully request that the Office of the Attorney General confirm that provision of the
following information in that notice will satisfy the travel notice requirements: (1) Mr.
Epstein's date of departure, (2) the general geographic areas of his travel, and with
respect to travel to any of his vacation homes, a statement that he is traveling to his
vacation home, (3) the time period for his intended travel, and (4) his contact
information (consisting of a cell number where he can always be reached during the
period of his intended travel, and also a cell number where his legal counsel can always
be reached), in case of any need to contact Mr. Epstein while he is traveling. In
addition, we request that written notice by email or facsimile from Mr. Epstein or his
legal counsel be permitted for any changes in travel plans that have occurred after Mr.
Epstein has departed the Virgin Islands, so long as such notice is given prior to
departure to any changed locations. In any event, consistent with the long-standing
practice accepted by your Department, email or facsimile notice from Mr. Epstein or his
legal counsel of Mr. Epstein's return to the Virgin Islands would be given immediately
prior to Mr. Epstein's departure for his return travel to the Virgin Islands.
reduce notice and adjust the information required under the amended law, we
respectfully request that you inform us, so that the necessary information can be
promptly provided.
I also wish to confirm, as agreed during our meeting, that during any period that
may elapse between the signing into law by the Governor of Bill 29-0239, as amended,
and your Office's completion of review of this request under the Bill to exercise
discretion as described above, the continued compliance by Mr. Epstein with the above-
described travel notification practices he has followed to date will be deemed
compliance with the new law.
Again, I appreciate you taking the time to meet with us to discuss this,
particularly in view of the commitment on the part of Mr. Epstein to comply with the
law. Please advise me if there is any additional information that may be required for a
favorable response to the foregoing request.
Sincerely,
Re: Implementation of Act No.7372, (Bill No. 29-0239); Intemational travel Notice request
I am in receipt of your letter of July 16, 2012 requesting clarification of our implementation of the
new provisions of the
local sex offender registration and notification law (T: 14 VIC Chapter 86). I
understand that your letter was written on behalf of Mr. Jeffrey Epstein, a registrant on the Virgin
Islands Sex Offender Registry.
It is my understanding that Mr. Epstein's business activities require him to make frequent and
often unexpected trips out of the territory to United States destinations and to international
destinations. Your letter is accepted as a request pursuant to the new provisions of Act No. 7372, for
the Attorney General to waive the 21 day prior notice requirement to the Department of Justice for Mr.
Epstein, when travelling out of the Virgin Islands.
Based upon your representation and that of Attorney Darren Indyke, we will grant the waiver of
the (21) twenty one day notice requirement to the Department of Justice when Mr. Epstein is traveling
out of the Territory. This waiver is granted upon compliance with the following conditions:
1. Prior notice must be given to the Department of Justice no less than Seventy two (72)
hours before travel out of the Virgin Islands;
2. Notice must be given by Mr. Epstein himself, via in-person visit, by facsimile
correspondence which is signed by him; or by e-mail with an electronic signature;
3. If the jurisdiction to which he travels requires his registration for the duration of time he is
there, he will comply with that registration requirement;
04..33 KliONPRINDSBNS GADE • GERS BLDG,, 2ND FLOOR• ST. THOMAS, U.S. Vx:aolN ISLAlO>S 00802 • (340) 774.-5(;166 • FAX (040) 774-9710
6040 CASTLB COAKLEY • DBSION CnNTBR BLDG, • CHlUSTIANSTBD, ST, CROIX, U.S. VxaOJN ISLANDS 00820 • (1340) 773-0291!1 • FAX (1340) 770•132130
b. the dates he will be departing from the Virgin Islands and the date expected to return;
c. the dates he will be staying at any intermediary temporary location.
5. Notice must be given of any modification from the travel itinerary, as originally advised
after leaving the territory. Such notice may be submitted by facsimile or e-mail by Mr.
Epstein or his legal counsel;
6. Upon returning to the Virgin Islands, Mr. Epstein shall immediately notified the
Department of Justice by visit, facsimile, or e-mail with electronic signature.
I do recognize that these conditions vary from the former conditions. However in light of the
discretion given to the Attorney General by Act No.7372, we are forced to take a closer look at the
waiver conditions.
]Zf?i=,
Please let me know if your client has any questions about these conditions.
Vincent F. r, q.
Attorney General
Re: July 2S, 2012 Letter Regarding Act No. 7372 Travel Notice Request
I received your letter of July 25, 2012 agreeing to grant the Attorney GeneraJ's waiver,
pursuant to the provisions of Act No. 7372, of the 2l•day prior notice requirement under that Act
with respect to Mr. Epstein's travels outside of the Virgin·Islands, and I have shared it with my
client. We appreciate the consideration given to Mr. Epstein's frequent travel requirements.
However, we still have serious concerns regarding what we believe are undue restrictions placed
on Mr. Epstein's travel and the conduct of his business and professional activities by certain of
the specific conditions imposed as part of this waiver, and we respectfully request that your
office reconsider those specific conditions.
Specifically, we believe that the waiver conditions requiring Mr. Epstein to provide 72
hours notice before traveling out of the Virgin Islands and requiring Mr. Epstein to provide a
specific address of temporary lodging locations when traveling within the United States will
have an unduly restrictive effect on his right to travel and conduct his legitimate business and
professional activities. As 1 understand it, both you and Senator Russell stated during the
hearing on the Act before the Rules and Judiciary Committee on June 21, 2012, that the travel
notification requirements of this Act were specifically not intended to be penal in nature. Both
you and Senator Russell acknowledged that this was meant to be a notice provision, nothing
more. However, as explained below, the restrictive effect of the 72-hour prior notice
requirement and the requirement that Mr. Epstein disclose the specific address of his temporary
lodging while in the United States would impede Mr. Epstein's right to travel and conduct
business and professional activities in a manner that would indeed, be penal in nature.
I want to discuss the legal justification for greater flexibility in notice. The Federal
SORNA guidelines have already recognized that there are cases where flexibility in the
application of SORN A's travel notification procedures is necessary. For example, the SORNA
guidelines themselves discuss the case of an individual who is a "long haul trucker" who
regularly drives thousands of miles through "dozens of jurisdictions in the course of his
employment", as well as the cases of a home-improvement contractor and of a day laborer, who
travel regularly to various locations that may change on a daily basis -- see The National
ATTORNEYS AT LAW
1340TMR MAS, VIRGIN ISLANDS
PHONE:
EMAIL:
Guidelines for Sex Offender Registration and Notification, pp. 39 and 43 -- or the case of an
individual "who lives in a northern border state and who commutes to Canada for work on a
daily basis" -- see Supplemental Guidelines for Sex Offender Registration and Notification.
Federal Register, Vol. 76, No. 7 (January 11, 2011), p. 1638. These cases are analogous to any
number of possible situations in our Territory, including pilots, fisherman, boat captains, boat
workers, cruise ship workers, merchants and international businessman, all of whom travel to
and from the Territory on a frequent and regular basis in the ordinary course of their employment
or business. The burden on both the Department of Justice and the worker of requiring such a
worker to give 72-hours prior notice each time he leaves the Territory and to confirm every
location and address included in his travel notification would be substantial. In situations such as
these, the SORNA guidelines permit the responsible jurisdictions to reduce notice requirements
and simp]y require the traveling registrant to provide a most likely itinerary of "normal travel
routes" and "general areas" of work. The National Guidelines for Sex Offender Registration
and Notification, pp. 39 and 43. Mr. Epstein's case is no different from any of these cases where
SORNA expressly permits this :flexibility in the manner and content of travel notification.
Consider, for example, the case of a St. Thomas boat captain chartering trips to various
islands in the Caribbean. Requiring that boat captain to provide 72 hours prior travel notice
would prevent him from taking any charters unless requested of him more than three days in
advance. With visiting tourists on short stays frequently requesting charters only a day or two in
advance, such a requirement would substantially interfere with the boat captain's ability to
conduct his business. Moreover, requiring him to provide specific addresses of his travels could
also be problematic in that tourists chartering his boat might not even make such determinations
until the day of the actual charter. Requiring the boat captain to be inflexible with his charter
passengers would therefore also seriously interfere with his business. The supplemental SORNA
guidelines have specifically stated in their own words that such requirements could be
"pointlessly burdensome" and "unworkable". See Supplemental Guidelines for Sex Offender
Registration and Notification. Federal Register, Vol. 76, No. 7 (January 11, 2011), p. 1638.
Consistent with the flexibility afforded by the SORNA Guidelines, both Senator Russell and you
acknowledged at that June 21, 2012 hearing that the law must be flexible to enable those who
must travel frequently and on short notice to do so.
In fact, when the travel notification amendment was revised for the Rules and Judiciary
Committee vote on June 25, 2012, the Attorney General discretion provision was inserted into
the law, rather than a specific 72-hour short notice exception to the 21-day notice requirement, to
provide your office with the flexibility to make decisions on a case-by-case basis. In the case of
frequent travelers, such as Mr. Epstein, as well as pilots, fisherman, boat captains, boat workers,
cruise ship workers, merchants and international businessman, who travel for business,
professional and other legitimate purposes several times a month, both on short notice and under
circumstances where travel plans frequently change on short notice, the new law provides your
office with the flexibility to grant a waiver that will not unduly restrict their travel and business
and professional activities, and that includes the right to alJow notice prior to departure less than
72 hours in advance.
As you know, from the beginning of Mr. Epstein's registration in March 2010, he has a
demonstrated history of frequent travel and a :flawless record of fully compliant travel
notification to your office. Even at times when the email servers at the Department of Justice
were not operating, Mr. Epstein's counsel took measures to ensure alternative notification by
providing telephonic and fax notification of the travel notice emails that were sent to the
Department of Justice. His record clearly demonstrates that he is unerringly diligent in ensuring
that the Virgin Islands is provided with timely notice of his travels outside of the Territory, and
he will remain so in the future under this new law.
Mr. Epstein has always previously provided the necessary travel notice, through his
counsel, immediately prior to Mr. Epstein's departure. He has done this because, in many
instances, , his travel dates and destinations are not known with certainty until a few hours prior
to departure, or they can and frequently do change on little or no notice for reasons that are not
within his control. For example, meeting schedules and locations for business or professional
trips evolved constantly over the past two years, and Mr. Epstein has had to remain flexible to
accommodate these changes. Moreover, unexpected changes in weather patterns and mechanical
issues with the aircraft had also accelerated or delayed travel plans. Instead of providing a
constant flow of notices to the Department of Justice in anticipation of possible or changed
travel, Mr. Epstein has provided notice immediately prior to departure to ensure that the notice
he provided was as accurate as possible. It was and still is believed that this avoids unnecessary
administrative burden to the Department of Justice, which we understand would be required to
update its notices to other jurisdictions every time a new or changed notice is received from Mr.
Epstein.
In addition, to the extent that notification by Mr. Epstein of his entry into another
jurisdiction is even required by that jurisdiction, the notice is not required from Mr. Epstein prior
to his arrival in that jurisdiction, and in some cases notice is not required until as much as several
days after arrival. Even in the State of Florida, the jurisdiction of Mr. Epstein's conviction
which triggered his registration requirement, Mr. Epstein is not required to provide any
minimum prior notice of his travel to Florida. In fact, he is permitted to provide email notice on
the day of his arrival. It is our understanding that notification immediately prior to Mr. Epstein's
departure from the Virgin Islands would still provide the Virgin Islands with ample time to
inform jurisdictions of Mr. Epstein's arrival, particularly when notification is done through
electronic means and is instantaneous. Moreover, in light of Mr. Epstein extensive record of
unerring diligence in providing notice of his travels and complying with his other registration
obligations, there are ample grounds to conclude that Mr. Epstein would continue to be fully
compliant in both the Virgin Islands and in all other jurisdictions to which the Virgin Islands
may have to give notice of Mr. Epstein's travels.
Requiring 72 hours notice of Mr. Epstein prior to his travel would severely restrict his
ability to remain flexible to accommodate ever-evolving meeting schedules and locations and the
schedules of Mr. Epstein's business and professional colleagues. For example, not infrequently,
Mr. Epstein is asked in the early morning to meet in a particular jurisdiction later in the day.
Because of the 72-hour notice requirement, in the future, Mr. Epstein would have to wait three
days before he could accommodate such a request for a meeting. As another example, assuming
Mr. Epstein gave the proper 72-hour notice of a trip to New York, but learned on the day of his
intended departure that the persons with whom he was to meet in New York later that day
desired to meet in a different location, Mr. Epstein would not be able to meet at the alternative
location because of the 72-hour notice requirement. In Mr. Epstein's business and professional
life, situations like this occur with frequency and regularity, and even a 72-hour notice
requirement would obviously have a significantly deleterious effect on his business and
professional activities.
For this reason, we respectfully request that Mr. Epstein be permitted to provide notice
immediately prior to his departure when traveling outside of the Virgin Islands, provided that
Mr. Epstein will endeavor to provide 24-hours notice to the extent he has such advance
knowledge of his travel. We understand your requirement that notices come from Mr. Epstein,
himself, when he is in the Virgin Islands and providing notice of his travel outside of the
Territory, and Mr. Epstein will comply with that requirement.
Another waiver condition contained your the July 25, 2012 letter is that Mr. Epstein
provide your office with the address of his temporary lodging while traveling within the United
States. Mr. Epstein has and will continue to provide notice to the Department of Justice of the
addresses of temporary lodging that are his own homes. In fact, as the ex.tensive volume of Mr.
Epstein's travel notification emails to the Department of Justice demonstrate, Mr. Epstein has
regularly stayed at his vacation homes when traveling and has so advised the Department of
Justice in his travel notifications each time he has done so. Inasmuch as the Department of
Justice already has a complete listing of the addresses of all of Mr. Epstein's vacation homes in
the registration information Mr. Epstein has provided and updates to the Department of Justice, it
was not thought necessary to include the specific addresses of Mr. Epstein's vacation homes in
each of the notices. To ensure compliance with the waiver conditions, Mr. Epstein will provide
the specific addresses of Mr. Epstein's vacation homes in the travel notices in the future.
However, frequently when Mr. Epstein travels to locations in the United States at which
he does not have a vacation home, he has stayed as a guest in the homes of third parties,
including business and professional associates. Many times these invitations have been and are
extended to Mr. Epstein after arriving in these locations as plans change and meetings extend
beyond scheduled times. Thus, originally scheduled hotel reservations are cancelled and new
lodging arrangements have to be made (which would again require further notices to the
Department of Justice, which would presumably have to send updates to the jurisdictions to
which the original notices were previously given). Many of these hosts would be uncomfortable
with Mr. Epstein having to provide the addresses of their homes in the travel notifications to the
Department of Justice, particularly when the hosts are oftentimes prominent figures whose
addresses are not a matter of public knowledge and there is no guarantee that their addresses
would not be disclosed in response to FOIA or other Sunshine Law requests. Requiring Mr.
Epstein to provide these addresses would likely deter potential hosts from offering Mr. Epstein
lodging and thus again interfere with his ability to travel and maintain the necessary flexibility in
the conduct his business, professional and other legitimate activities.
It is for this reason that we respectfully request that the waiver condition requiring Mr.
Epstein to provide the addresses of his temporary lodging in his notification of travel within the
United States be eliminated, provided that when Mr. Epstein stays at his vacation homes while
traveling in the United States he will so advise the Department of Justice, and include in the
notice the specific address of his vacation home at which he is staying. In all other cases,
consistent with the Federal SORNA Guidelines which authorize jurisdictions to pennit frequent
inter-jurisdictional travelers, such as long-haul truckers, day laborers, and international border
commuters, to provide a most likely itinerary of "normal travel routes" and "general areas" of
work, Mr. Epstein should be allowed to provide the general geographic area of his temporary
lodging and to provide a cell telephone number at which Mr. Epstein may be contacted at all
times while travelling.
We believe that the foregoing proposals are consistent with the Federal SORNA
Guidelines and consistent with the balance intended to be achieved in the travel notice
amendment as described by both Senator Russell and you at the Rules and Judiciary Committee
hearing on June 21, 2012. As has always been the case, Mr. Epstein would continue to provide
timely notification to the Department of Justice of his travel before departing the Virgin Islands,
so as to enable the Virgin Islands to electronically infonn the necessary jurisdictions of this
travel. Notice of Mr. Epstein's general geographic location and a contact number to reach him at
all times would be provided, as well as his specific address when he stays at his vacation homes.
With this balance, the timing and the content of Mr. Epstein's travel notification would provide
your office the information it needs without impeding Mr. Epstein's right to travel and conduct
his business, professional and other legitimate activities, and would thereby avoid transforming
the Act's travel notice provisions into a punitive measure contrary to express legislative intent.
Once again, we appreciate the grant to Mr. Epstein by the Office of the Attorney General
of the travel notification waiver as described in your letter of July 25, 2012, and respectfully
request that the two waiver conditions described above imposed in that letter be modified as I
have proposed. If our request to modify the waiver conditions meets with the approval of your
office, please confirm that approval of the modifications as described above by signing this letter
below.
If you have any questions or require anything further for a favorable response to this
request, please do not hesitate to contact me.
Respectfully, -J~ _
Maria Tankenson Hodge
After careful review of your letter giving additional information to support your client,
Jeffery Epstein's request for a shorter period for prior notice whenever he plans to leave the
Territory of the Virgin Islands. In light of the justification set out in your letter of July 30,
2012, I have decided to shorten the notice period and modify the other condition, as
follows:
1. Mr. Epstein will be allowed to notify the Department of Justice of his intention
to .travel out of the Territory twenty four (24) hours prior to his departure;
2. Mr. Epstein will be allowed to continue to notify the department when he is
staying in one of his stateside homes. He must provide us with a current list and addresses
of each of his stateside homes;
3. When Mr. Epstein is staying in the home of an associate, he must notify the
department of the city and state or country in which he is temporarily staying and his
period of stay in the jurisdiction;
4. When he is staying in a non-private lodging, he or his representative may
provide the specifics of the name, city and address of the establishment.
04•38 KRONP1UNl,)s:8NS GADE • GERS BLDO., 2ND FLOOll • ST. THOM.AS, U.S. VmoIN ISLANDS 00802 • (340) 774-5886 • FA."< (040) '7'74•0710
0040 C.U.TI.B CoAKLBY • DBSION CENTER Bx.no. • CHBISTL\.NSTJ.m, ST. CHOIX, U.S. VinorN ISLANDS 00820 • (340) 7713·0205 • FAX (040) 7:r:3•3230
5. Pursuant to section 9 (4) (iii) of Act No. 7372, Mr. Epstein must provide a copy of
the following documents to the department.
a. all of his valid driver's licenses issued by any jurisdiction,
b. any and all government issued identification cards issued by any jurisdiction,
c. any passports issued to him.
I trust that the foregoing conditions will be workable for your client, in light of his
frequent trips out of the Territory on business. AU other conditions stated in my letter of
July 251 2012 are in full force and affect.
!li:trt:J:::r
Attorney General
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you that I will travel on May 18, 2019 from my permanent residence in the
U.S. Virgin Islands to my vacation home in Palm Beach, Florida, where I expect to stay until
May 21, 2019. On May 21, 2019, I plan to travel from my vacation home in Palm Beach,
Florida to my vacation home in New York, New York, where I expect to stay until May 24,
2019. On May 24, 2019, I plan to travel from my vacation home in New York, New York to
my vacation home in Stanley, New Mexico, where I expect to stay until May 29, 2019. On
May 29, 2019, I plan to travel from my vacation home in Stanley, New Mexico to my vacation
home in New York, New York, where I expect to stay until June 3, 2019. On June 3, 2019,
I plan to return from my vacation home in New York, New York to my permanent residence in
the U.S. Virgin Islands .
, I then plan to travel on June 10, 2019 from my permanent residence in the U.S. Virg in
Islands to my vacation home in New York, New York, where I expect to stay until June 14,
2019. On June 14, 2019, I plan to travel by private aircraft, N212JE, from my vacation home in
New York, New York to my residence in Paris, France for business. I expect to arrive at le
Bourget Airport in Paris, France at approximately 7:30PM local time on June 14, 2019 and to
remain at my residence in Paris, France until June 20, 2019. On June 20, 2019, I plan to retu rn
by private aircraft, N212JE, from Paris, France to my permanent residence in t he U.S. Virgin
Islands. I expect to arrive at Cyril E. King International Airport in St. Thomas, U.S. Virgin
Islands at approximately 11AM on June 20, 2019 and will email your office upon my return on
June 20, 2019. While traveling abroad, I can be contacted on my mobile telephone number
at 212-533-3739. In addition, I can be contacted throug h my business office at 340-775-
2525 or through my attorney, Darren K. Indyke, at
Please advise if I need to come to your office in person to provide the above details. If so, is
there a good time on Wednesday, May 15, 2019, for me to come see you?
https://outlook.office.com/maiVsearchf!d/AAQkAGVkOGYxYWYzlTVkMTktNGNIZi1 iODgzlTRhNjczM2E 1OTJkZQAQAEvN%288Tua%2BRlkn5bRFLK... 1/2
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@.gmail.com. and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
212Je. Gulfstream
On Wed, May 15, 2019 at 11:27 AM Shani Pinney < Shani.Pinney_@vi.gov> wrote:
Good Morning,
I am preparing the paperwork for your travel and I need the aircraft you will travel on from here to the
mainland and when traveling from state to state.
From: J <jeevacation@gmail.com>
Sent: Monday, May 13, 2019 11:16 AM
To: Shani Pinney; Kevin Augustin; Darren lndyke
Subject: Fwd: Privileged and Confidential
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you that I will travel on May 18, 2019 from my permanent residence in the
U.S. Virgin Islands to my vacation home in Palm Beach, Florida, where I expect to stay until
May 21, 2019. On May 21, 2019, I plan to travel from my vacation home in Palm Beach,
Florida to my vacation home in New York, New York, where I expect to stay until May 24,
2019. On May 24, 2019, I plan to travel from my vacation home in New York, New York to
my vacation home in Stanley, New Mexico, where I expect to stay until May 29, 2019. On
May 29, 2019, I plan to travel from my vacation home in Stanley, New Mexico to my
vacation home in New York, New York, where I expect to stay until June 3, 2019. On June
3, 2019, I plan to return from my vacation home in New York, New York to my permanent
residence in the U.S. Virgin Islands .
, I then plan to travel on June 10, 2019 from my permanent residence in the U.S. Virgin
Islands to my vacation home in New York, New York, where I expect to stay until June 14,
2019. On June 14, 2019, I plan to travel by private aircraft, N212JE, from my vacation home
in New York, New York to my residence in Paris, France for business. I expect to arrive at
Le Bourget Airport in Paris, France at approximately 7:30PM local time on June 14, 2019 and
to remain at my residence in Paris, France until June 20, 2019. On June 20, 2019, I plan to
If you need any further information, please feel free to call Attorney Indyke at -
- or on his mobile telephone number
Please advise if I need to come to your office in person to provide the above details. If so,
is there a good time on Wednesday, May 15, 2019, for me to come see you?
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfu fly,
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@.gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
I am preparing the paperwork for your travel and I need the aircraft you will travel on from here to the
mainland and when traveling from state to state.
From: J <Jeevacatlon@gmail,com>
Sent: Monday, May 13, 2019 11:16 AM
To: Shani Pinney; Kevin Augustin; Darren lndylce
SubJed:: Fwd: Privileged and Confidential
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you that I will travel on May 18, 2019 from my permanent residence in the
U.S. Virgin Islands to my vacation home in Palm Beach, Florida, where I expect to stay until
May 21, 2019. On May 21, 2019, I plan to travel from my vacation home in Palm Beach,
Florida to my vacation home in New York, New York, where I expect to stay until May 24,
2019. On May 24, 2019, I plan to travel from my vacation home in New York, New York to
my vacation home in Stanley, New Mexico, where I expect to stay until May 29, 2019. On
May 29, 2019, I plan to travel from my vacation home in Stanley, New Mexico to my
vacation home in New York, New York, where I expect to stay until June 3, 2019. On June
3, 2019, I plan to return from my vacation home in New York, New York to my permanent
residence in the U.S. Virgin Islands .
, I then plan to travel on June 10, 2019 from my permanent residence in the U.S. Virgin
· Islands to my vacation home in New York, New York, where I expect to stay until June 14,
2019. On June 14, 2019, I plan to travel by private aircraft, N212JE, from my vacation home
in New York, New York to my residence in Paris, France for business. I expect to arrive at
Le Bourget Airport in Paris, France at approximately 7:30PM local time on June 14, 2019 and
to remain at my residence in Paris, France until June 20, 2019. On June 20, 2019, I plan to
https:l/outlook.offloo.comlmalllsearc:Mcl/AAQkAGVkOGYxYWYzlTVkMTk!NGNIZl1IODgzllRhNJczM2E10TJkZQAQAEvN%288Tua%2BRlkn5bRFU<... 113
: return by private aircraft, N212JE, from Paris, f ranee to my permanent residence in the US.
: Virgin Islands. I expect to arrive at Cyril E. King International Airport in St Thomas, U.S.
Virgin Islands at approximately 11AM on June 20, 2019 and will email your office upon my
· retum on June 20, 2019. While traveling abroad, I can be contacted on my mobile
: telephone number at 212-533-3739. In addition.- I can be contacted through my business
office at 340-VS-2525 or through my attorney, Darren K. lndyke, at
. If you need any further information, please feet free to call Attomey Indyke a t -
.82.31 or on his mobile telephone numbe
Please advise if I need to come to your office in person to provide the above details. If so,
is there a good time on Wednesday, May 15, 20191 for me to come see you?
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
please note
The information contained In this communication is
confidential, may be attomey•dient privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jaevacation@.gmajl,com. and
destroy this communication and afl copies thereof,
including all attachments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may be attomey-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
I am preparing the paperwork for your travel and I need the aircraft you will travel on from here to the
mainland and when traveling from state to state.
From: J <jeeyacatjon@11mall.mm>
Sent: Monday, May 13, 2019 11:16 AM
To: Shani Pinney; Kevin Augustin; Darren lndyke
Subject: Fwd: Privileged and Confidential
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you that J will travel on May 18, 2019 from my permanent resid~nce in the
U.S. Virgin Islands to my vacation home in Palm Beach, Florida, where I expect to stay until
May 21, 2019. On May 21, 2019, I plan to travel from my vacation home in Palm Beach,
Florida to my vacation home in New York, New York, where I expect to stay until May 24,
2019. On May 24, 2019, I plan to travel from my vacation home in New York, New York to
my vacation home in Stanley, New Mexico, where I expect to stay until May 29, 2019. On
May 29, 2019, I plan to travel from my vacation home in Stanley, New Mexico to my
vacation home in New York, New York, where I expect to stay until June 3, 2019. On June
3, 2019, I plan to return from my vacation home in New York, New York to my permanent
residence in the U.S. Virgin Islands .
, I then plan to travel on June 10. 2019 from my permanent residence in the U.S. Virgin
· Islands to my vacation home in New York. New York, where I expect to stay until June 14,
2019. On June 14, 2019, I plan to travel by private aircraft, N212JE, from my vacation home
in New York. New York to my residence in Paris, France for business. I expect to arrive at
Le Bourget Airport in Paris, France at approximately 7:30PM local time on June 14, 2019 and
to remain at my residence in Paris, France until June 20, 2019. On June 20, 2019, I plan to
https://ou1loolu:1fflce.comlma!lfsearc:MdlAAQkAGVkOGYxVWVzl.1VkMTidNGNlZi110Dgzl.TRhNjczM2E10TJkZQAOAEvN%288Tua%2BRlkn5bRA.K... 113
: return by private aircraft, N212JE, from Paris, France to my permanent residence in the U.S.
: Virgin Islands. I expect to arrive at Cyril E. King International Airport in St Thomas, U.S.
Virgin Islands at approximately 11AM on June 20, 2019 and will email your office upon my
· retum on June 20, 2019. While traveling abroad, I can be contacted on my mobile
, telephone number at 212-533-3739. In addition, I can be contacted through my business
office at 340-VS-2525 or through my attorney, Darren K. Indyke, at
: If you need any further information, please feel free Attorney Indyke at -
- o r on his mobile telephone number
Please advfse if I need to come to your office in person to provide the above details. If so,
is there a good time on Wednesday, May 15, 2019, for me to come see you?
Please confirm by reply email to me your receipt of this email. Thank you, Ms. Pinney.
Respectfully,
please note
The information contained In this communication is
confidential, may be attomey•cUent privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeeyacatjon@,gmail,cgm. and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights rese,ved
please note
The information contained in this communication is
confidentiaJ, may be attomey-dient privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
hllps://oullootc.offlc:e.ccmlmolfleean:Md/AACMGVkOGYxVWYzLTVIIMTictNGN121110DgzllRIINjczM2E10TJkZQAQAE\IN%288Tua%2BRlknSbRFU(.... 213
Carol Thomas-Jacobs
Er ika and I would like to meet with you. What does your schedule look like next week?
Clive Rivers
Good day,
There ls no specific informat ion that I am seeking at this time. Please submit reasonable and reli able
proof as required by stanrte, tf the travel notifications are helpful in your submission -0f the required
proof, you may submit.
Regards,
Good day Attorney George. I am following up on my email of June 7th. We are in the process of
compiling the information you requested in your correspondence. However, before we finalize, I wanted
to Inquire as to whether there was any specific information you are looking for that constitutes
"reasonable and reliable proof' that Mr. Epstein travels frequently outside the U.S. Neither the VI Code,
nor the SORNA guidelines define "reasonable and reliable proof" and in an attempt to get this matter
resolved as soon as possible, we want to ensure you have a!I of the information you need to make a
determination.
I also need your guidance as to whether you would like us to compile af! of the
notifications of travel that have been sent to Shani Pinney since 2012 or if you are able
to obtain those documents from within your ow11 ~gency.
Erika A. Ke!lerha!s
Member
Ke!lerhals Ferguson l<rob!in PLLC
Thank you for your correspondence Attorney George. We wrn pull togetherthe
information you requested and provide it ASAP.
Erika A. Kel!erhals
Member
KeHerha!s Ferguson Krob!in PLLC
Best regards,
Erika A KeHerhals
Member
Kelle(hals Ferguson Kroblin PLLC
Royal Palms Professional Building
9053 Estate Thomas Suite 101
St Thomas, V! 00802
Notice: This communication rnay contain privileged or other confk!ential infonnation. If you are
not th!'! lnt(lnded recipient, or believe !hat you havi.1 rn(;eived !his communication in error. please
do not print, copy. re-trans1riit, disseminate, or otheiwise use this lnfomiation. Also. please
inditata to lhe sender that you have received this e-mail !n error, and de!ete lhe oopy you
received. Thank you,
Good day Attorney Kellerhals, are you still representing Mr. Epstein in
, this matter or should l send my correspondence to Atto rney Rivers.
Please advise, Thank you.
Erika A. Ke!!erha!s
Member
St Thomas VI 00802
On May 1, 2019_
, at 9:56 AM, Erika Ke!lerha!s
wrote:
Erika A. Kel!erhals
Member
Mr. Epstein will remain at 22 Avenue Foch in Paris, France until July 14, 2019. On July
14, 2019, Mr. Epstein plans to travel by private aircraft. N212JE, from 22 Avenue
Foch in Paris, France to 9 East 71st Street, New York, New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 11AM local
time on July 14, 2019 and to stay at 9 East 71st Street, New York, New York until
July 20, 2019. On July 20, 2019, Mr. Epstein plans to travel from New York, New
York to 358 El Brillo Way in Palm Beach, Florida, where he expects to stay untit July
21, 2019. On July 21, 2019, Mr. Epstein plans to return from Palm Beach, Florida to
his permanent residence in the U.S. Virgin Islands. He will email your office upon
his return on July 21, 2019.
This is also to advise you that on July 24, 2019, Mr. Epstein plans to travel by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
22 Avenue Foch in Paris, France. He expects to arrive at Le Bourget Airport in Paris,
France at approximately 7:30PM local time on July 24, 2019 and to remain at 22
Avenue Foch in Paris, France until August, 3, 2019. On August 3, 2019, Mr. Epstein
plans to return by private aircraft, N212JE, from Paris, France to his permanent
residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King
International Airport in St Thomas, U.S. Virgin Islands at appro><imately 12:00PM
local time on August 3, 2019 and will email your office upon his return on August 3,
2019.
hllps:/loutfoakofflc:e.com/ma!l/8ean:Md/AAQkAGVkOGYxVWYzl.TVkMTktNGNIZi1100gzJ.TRhN~10TJkZQAQAEux4%2FJBZE9FnHOCxZG%2... 112
While traveling internationally, Mr. Epstein can be contacted on his mobile telephone
at 212-533-3739. In addition he can be contacted at his business office at 340-VS-
2525. or through me at
lf you need any further information, please also feel free to call me at -
- . , r on my mobile telephone number
Please confirm by reply emaH to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
............................." ..................................................................... .
The Information contained In !his communlcatton Is confldentlaJ, may be attomey-clfent
privileged, and Is Intended only for the use of 1he addressee. It Is the property of
Darren K. lndylce. Unauthorized uae, dlsdosure or copying of this communlcalfon
or any part thefeof Is strictly prohibited and may be unlawful. If you have received this
cunmunlcatlon tn em>r, please notify us Immediately by return e-malt, and destroy this
conununtcatlon and all copies !hereof, indudlng all attachmefds.
..........................................................................................................
Copyright of Damm K. fndyke-0 2019 Darren K. lndyke - AII rights reee,ved .
hltps:/loutlook.offloe.cam/mafflseen:hAAQkAGVkOGYxYWYzl.1VkMTktNGNIZl1100gzLTRhNjczM2E10TJlcZQAOAEulc4%2FJSZE9FflHOQcZG%2... 212
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
Mr. Epstein will remain at 22 Avenue Foch in Paris, France until July 14, 2019. On July
14, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from 22 Avenue
Foch in Paris, France to 9 East 71st Street, New York, New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 11AM local
t ime on July 14, 2019 and to stay at 9 East 71st Street, New York, New York until
July 20, 2019. On July 20, 2019, Mr. Epstein plans to travel from New York, New
York to 358 El Brillo Way in Palm Beach, Florida, where he expects to stay until July
21, 2019. On July 21, 2019, Mr. Epstein plans to return from Palm Beach, Florida to
his permanent residence in the U.S. Virgin Islands. He will email your office upon
his return on July 21, 2019.
This is also to advise you that on July 24, 2019, Mr. Epstein plans to travel by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
22 Avenue Foch in Paris, France. He expects to arrive at Le Bourget Airport in Paris,
France at approximately 7:30PM local time on July 24, 2019 and to remain at 22
Avenue Foch in Paris, France until August, 3, 2019. On August 3, 2019, Mr. Epstein
plans to return by private aircraft, N212JE, from Paris, France to his permanent
residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King
International Airport in St. Thomas, U.S. Virgin Islands at approximately 12:00PM
local time on August 3, 2019 and will email your office upon his return on August 3,
2019.
\ /"''"/o"""'·°""'·""""''"'.....,,"AAQkAGVkOGY,YWY,LTVl<MTktNGNJZ11l0Dg,t.TRhNjO,M2E10T.JkZQAQAEW<4%2FJBZE9FoHOC><2G%2 .. : 1n
While traveling internationally, Mr. Epstein can be contacted on his mobile telephone
at 212-533 -3739. In addition, he can be contacted at his business office at 340-775-
2525 or through me at
If you need any further information, please also feel free to call me at
. , r on my mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
Mr. Epstein will remain at 22 Avenue Foch in Paris, France until July 14, 2019. On July
14, 2019, Mr. Epstein plans to travel by private aircraft, N212JE, from 22 Avenue
Foch in Paris, France to 9 East 71st Street, New York, New York. He expects to
arrive at Teterboro Airport in Teterboro, New Jersey at approximately 11AM local
time on July 14, 2019 and to stay at 9 East 71st Street, New York, New York until
July 20, 2019. On July 20, 2019, Mr. Epstein plans to travel from New York, New
York to 358 El Brillo Way in Palm Beach, Florida, where he expects to stay until July
21, 2019. On July 21, 2019, Mr. Epstein plans to return from Palm Beach, Florida to
his permanent residence in the U.S. Virgin Islands. He will email your office upon
his return on July 21, 2019.
This is also to advise you that on July 24, 2019, Mr. Epstein plans to travel by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin lslands to
22 Avenue Foch in Paris, France. He expects to arrive at Le Bourget Airport in Paris,
France at approximately 7:30PM local time on July 24, 2019 and to remain at 22
Avenue Foch in Paris, France until August, 3, 2019. On August 3, 2019, Mr. Epstein
plans to return by private aircraft, N212JE, from Paris, France to his permanent
residence in the U.S. Virgin Islands. He expects to arrive at Cyril E. King
International Airport in St Thomas, U.S. Virgin Islands at approximately 12:00PM
local time on August 3, 2019 and will email your office upon his return on August 3,
2019.
hllps://outtook,offlce.com/m8llf8earchlldlAAQJcAGVltOGYxYWVzLTVkMTk!NGNIZl110DgzLTRhN.1CzM?£10TJlcZQAQAEux4%2FJ8ZE9FnH~... 112
While traveling internationally, Mr. Epstein can be contacted on his mobiJe telephone
at 212-S33-3739. In addition, he can be contacted at his business office at 340-775-
25.2S or through me a
...!!z2!! need any further information, please also feel free to call me a t -
lllllllor on my mobile telephone numbe
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
...........................................................................................................
The lnl'onnatlon contained In this c:ommunlcation la confldentiet. may be attomey-c!Jent
privileged. and Is intended only for the use of the addressee. It Is lhe property of
Darren K. lndyke. Unauthorized use. dlsclosure or copying of this communlcallon
or any part thereof Is strictly l)IOhibited end may be unlawful. If you have received this
c:ommunlcallon In en'OI', please notify us Immediately by retum e-mail, and destroy lhls
...........................................................................................,-........-............
communication and all copies thereof. Including au attachments.
Copyright of Darren K. lndyke •O 2019 Dal1'8n K. tndyke -AD rlghea reserved•
tltlps:l/outlook.offlce.ccm/ma!llaeeR:hfld/AAQkAGVkOGYxVWYzl.TVkMTidNGNIZl1I00gzl.TRhNjczM2£10TJJcZQAQAEUl!A%2FJBZE9FnHOCxZG%2••• 212
Felony: _ _ Misdemeanor: _ __
VIDOJ/SOR-7
Upon Arrival in yom Destination Please Report to: New York. N''{ contact the monitorim~ unit upon arrival
(212) 323-7101
(\
\ ! /\ /'?
..
Completed By: .................. \/ f ~ . - __·____ Date:
(You are required to notify the Sexual Registry Coordinator when you return to the Territory}
SOR-5
QS/21/19-05/24/19: 9 E 71
st
St, New York, NY
Q.5/24/19-05/29/19: 49 Zora Ranch, RD, Stanley'"-,-'-NC'-'M"-------
st
Q~i_/29/19-06/03/19: 9 E 71 St, New York, NY
Driver's License #:
Felony: - ~ - ~v'Hsdemeanor: · - - -
Felony; . Misdemeanor: ~ - -
VJDOJ/SOR-7
Felony: Misdemeanor: _ __
Upon Arrival in your Destination Please Repcni to.: ___ Palm Beach, FL Stockade Sheriffs Ofiice upon arrival
( 561) 688-4990 (1nore than 3 davst New York, NY
contact the monitoring unit upon arrival f 212) 323-710 l;
Stanley. NM Torrance County Sheriffs Office upon arrival
(505) 705-4034 (nmre than 5 davs)
Completed By . P~·
Yexual Registry Coordinator
Date:
{You are required to notify the Sexual Registry Coordinator when you return to the Territory)
SOR-5
NSwTC
1
Olte Submltted:~7(12201 g
sex camm
NATIONAl. OFFENDER TAAGETING
Citizenship: us
Criminal Record
Date(s) of Conviction: ~/30/2008 j City and State or Jurisdiction of Conviction: 1-IF_lo_ri_da_ _ _ _ _ _ ----1
Other Mr. Epstein plans lo travel by private aircraft, N212JE, from 22 Avenue Foch in Paris,
Information, (i.e. 'Crance for a day (rip to Nice, France and then I.ravel lhat same day to 9 East 71 st Street,
Itinerary· visa lNew York, New Yolic. He expecls to arrive at Nice Cote d • Azur Airport in Nice, France
lnforma;lon· lat approximately 12PM local time on July 6, 2019, and after departing Nice, France later
explain "other" ~hat same dale arrive at Teterboro Airport In Teterboro, New Jersey at approximately 9:
responses above) ~OPM local time on July 6, 2019.
NSS<IHAiSC
NATIONAi. sex OFFENDER TARGETING CENTER
One SubmCtted:107022019
. . -----------------------1
Contact Information In Destination Country: 1212-533-3739
Other Mr. Epstein plans to travel by private aircraft, N212JE, from 22 Avenue Foch In Paris,
Information, (i.e. France for a day trip to Nice, France and then travel that same day to 9 East 71st Street,
Itinerary; visa !New York, New York. He expects to arrive at Nice Coted' Azur Airport in Nice, France
Information· lat approximately 12PM local time on July 6, 2019, and afte, departing Nice, Franca later
explain ~oth,er" lthat same date arrive al Teterboro Airport In Teterboro, New Jersey et approximately 9:
responses above) 30PM local time on July 6, 2019.
J
Notification of lnterru1tioru1i Travel of Sex Offender
Subject information
Date of Birth:
1111111117 FB! # (internal use only): j
>----------'
Gtizenship:
Travel information
Date R<mnnirlg to US: joJ/06/2018 Arrival Lociltion,: ·eterboro Airport b Teterboro, New Jersey
Date(s) of Conviction: iOB/2.0!2003 j City ;:md State or Jurisdiction of Conviction: ln::.ruJ_______ __c
Other
Ms. S. Pinney
Territorial SOR Program Manager
Virgin Islands Department of Justice
United States Virgin Islands
This is to advise you of a further modification to Mr. Epstein's travel plans. Mr.
Epstein will depart Paris, France on the same day as scheduled, but his day trip to
Nice, France has been canceled. Mr. Epstein will remain at 22 Avenue Foch in Paris,
France until July 6, 2019. On July 6, 2019, Mr. Epstein plans to travel by private
aircraft, N212JE, from 22 Avenue Foch in Paris, France to 9 East 71st Street, New
York, New York. He expects to arrive at Teterboro Airport in Teterboro, New Jersey
at approximately 6:30PM local time on July 6, 2019. Mr. Epstein will also depart
New York, New York a day earlier than previously advised. Mr. Epstein expects to
stay at 9 East 71st Street, New York, New York until July 8, 2019, when he plans to
return from New York, New York to his permanent residence in the U.S. Virgin
Islands. Mr. Epstein will email your office upon his return on July 8, 2019.
This is also to advise you that Mr. Epstein's trip to Palm Beach, Florida will be a day
earlier t han previously advised. On July 12, 2019, Mr. Epst ein plans to travel by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
358 El Brillo Way in Palm Beach, Florida, where he expect s to stay until July 16,
2019. Mr. Epstein's remainin g plans are unchanged. On July 16, 2019, Mr. Epstein
plans to travel by private ai rcraft, N212JE, from Palm Beach, Florida to 22 Avenue
Foch in Paris, France. He expects to arrive at Le Bourget Airport in Paris, France at
approximately 7:30PM local time on July 16, 2019 and to remain at 22 Avenue Foch
in Paris, France until July 29, 2019. On July 29, 2019, Mr. Epstein plans to return by
private aircraft, N212JE, from Paris, France to 9 East 71st Street, New York, New
York. He expects to arrive at Teterboro Airport in Teterboro, New Jersey at
approximately 11:30AM local time on July 29, 2019 and to stay at 9 East 71st Street,
New York, New York until July 30, 2019, when he plans to return from New York,
New York to his permanent residence in the U.S. Virgin Islands. Mr. Epstein will
email your office upon his return on July 30, 2019.
This is also to advise you that on August 3, 2019, Mr. Epstein plans to travel by
private aircraft, N212JE, from his permanent residence in the U.S. Virgin Islands to
358 El Brillo Way in Palm Beach, Florida, where expects to stay until August 6, 2019.
On August 6, 2019, Mr. Epstein plans to travel by private aircraft, N120JE, from Palm
Beach, Florida to 49 Zorro Ranch Road in Stanley, New Mexico, where expects to stay
until August 21, 2019, when he plans to return to his permanent residence in the U.S.
Virgin Islands. Mr. Epstein will email your office upon his return on August 21, 2019.
While traveling internationally, Mr. Epstein can be contacted on his mobile telephone
at 212-533-3739. In addition, he can be contacted at his business office at 340-775-
25.2.5. or through me a
If you need any further information, please also feel free to call me a t -
_ , r on my mobile telephone number
Please confirm by reply email to me your receipt of this email. Thank you, Ms.
Pinney.
Respectfully,
DARREN K. INDYKE
DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
1. I am employed as the Territorial Sex Offender Registry Program Manager with the United States Virgin Islands
Department of Justice ("VIDOJ"), designated by the Attorney General to register all sex offenders currently
residing in the District of St. Thomas, St. John and Water Island.
2. As the Territorial Sex Offender Registry Program Manager, I am the custodian of the records for the Virgin
Islands Sexual Offender Registry ("V.1. Sexual Offender Registry") which among other duties requires me to
receive and record information which has been provided to the Department of Justice by sex offenders, law
enforcement agencies and other sex offender registries concerning sex offenders who are required to register
under the laws of this Territory.
3. On July 15, 2019, at the request of Brad Bolen, of the United States Marshals Service, I conducted a diligent
search of the Sex Offender Registry filing system including a search of all data electronically entered and stored
in the V.I. Sexual Offender Registry Database and a manual search of pending files.
4. As a result of this search there were records indicating that JEFFREY EPSTEIN is registered in the U.S. Virgin
Islands as a sexual offender and is required to provide in person notification of any travel outside of the U.S.
Virgin Islands.
5. JEFFREY EPSTEIN notified VIDOJ on March 9, 2019 of intended travel to Paris, France from March 19, 2019
until March 29, 2019.
6. On March 30, 2019 email notification was received advising of modification to travel plans and JEFFREY
EPSTEIN instead departed from Paris, France and returned to the U.S. on April 2, 2019.
7. JEFFREY EPSTEIN informed VIDOJ on April 11, 2019 of intended travel to Paris, France from April 4, 2019 until
April 30, 2019.
8. On April 23, 2019 email notification was received advising of a day trip for JEFFREY EPSTEIN to Marrakech,
Morocco on April 25, 2019.
Page 2
9, Emai! notification was received on April 26, 2019 advising of modification to travel plans and JEFFREY EPSTEIN
instead departed from Paris, France and returned to the U.S. on April 29, 2019.
10. JEFFREY EPSTEIN informed V!DOJ on June 13, 2019 of intended travel to Paris, France from June 14, 2019 until
June 20, 2019.
11. Our records do not reflect that JEFFREY EPSTEIN returned to the lLS, on June 20, 2019.
12. On July 2, 2019 email notification was received advising of a day trip for JEFFREY EPSTEIN to Nice, France on
July 6, 2019.
13. Later on July 3, 2019 ernail notification was received advising that the day trip for JEFFREY EPSTEIN to Nice,
France on July 6, 2019 was cancelled.
14. Ernail notification received on July 3, 2019 also advised of modification to travel plans and JEFFREY EPSTEIN
instead departed frorn Paris, France and returned to the U.S. on Juiy 6, 2019,
sj£ni APim~f~J , ,.
Territorial Sex Offender Registry Prograrn fVlanager
Virgin Islands Department of Justice, Office of the Attorney
Genera!