Guide to Understanding Epstein's 'List': The 40 Documents, One by One

Epstein's list isn't really a list. At least, not a list of clients, or those who traveled to his island. Although there are some enumerations of names, in most cases people are mentioned in the documents in heterogeneous contexts. Along with people who committed sexual acts with some of the victims, there are others who appear only tangentially, because they are questioned about them or because they are victims, or employees. In the vast majority of cases, there are no indications of reprehensible conduct, even if the mere appearance of a name has proven toxic to its reputation, amid the disinformation that circulates unchecked on social networks, where numerous fake lists have also appeared.

The names appear in more than 900 pages on which Loretta Preska, the judge who has taken charge of the case of the defamation lawsuit filed in 2015 by one of the victims, Virginia Giuffre, against Epstein's former lover and partner, Ghislaine Maxwell, was lifted the secrecy on Wednesday. It is a first batch of documents that will be followed by others. Jeffrey Epstein committed suicide in August 2019 in his cell in a high-security Manhattan prison while awaiting trial for his sex crimes.

What we do have with the declassification of the papers is a list of documents. There are 40 of varied content. Here's a guide.

Document 1: "I Need Time to Process"

The first of the documents is an email sent by Ghislaine Maxwell to her lawyer in 2015. In it, Jeffrey Epstein's ex-lover and business partner is overwhelmed after being sued for defamation by Virginia Giuffre, one of the victims. "Apparently, even saying Virginia is a liar is dangerous," he says. Maxwell notes that she had never had a civil or criminal lawsuit. "I need time to process," he says. Subsequently, heiress Ghislaine Maxwell, daughter of media mogul Robert Maxwell, settled Giuffre's lawsuit (from which all documents originate), but was criminally prosecuted, found guilty of sex trafficking of minors, and sentenced to 20 years in prison in June 2022.

Document 2: "Adult" Sexual Activity

Lawyers for Giuffre, the plaintiff, are asking the judge in a brief to force Maxwell, the defendant, to answer questions about whether she massaged Jeffrey Epstein and had sex with him. Maxwell had declined to answer those questions about "adult" sexual activity, but the plaintiff's lawyers believe it's important for her to answer because she was the one who taught Giuffre how to do the sexually charged massages she was hired to do when she was a minor and they would test a pattern of performance.

Document 3: "I've Never Had Non-Consensual Sex With Anyone"

It is the transcript of an excerpt from a statement by Maxwell in April 2016 that is asked about another of the victims, Johanna Sjoberg. Maxwell says he gave her "career advice" to become a massage therapist, which she calls "a wonderful job opportunity." He admits that Johanna massaged her, but refuses to answer whether he had sex with her. "I've never had non-consensual sex with anyone," she says.

Document 4: Clinton Appears for the First Time

In another excerpt of Maxwell's statement, she continues to maintain that the allegations of trafficking minors for sex with Jeffrey Epstein are "a gigantic tangle of lies." In that excerpt, former U.S. President Bill Clinton is mentioned for the first time in this batch of documents. The defendant asserts that "the allegations that Clinton had a dinner on Jeffrey Island are 100% false." Instead, he did eat aboard the plane. In 2019, the former president acknowledged that he had flown on Epstein's private plane on several occasions in 2002 and 2003, but said he knew nothing about the millionaire's "terrible crimes."

Document 5: "I Would Have Liked to Have Been Considered His Girlfriend"

This document is also from the same statement of April 2016. It's another, broader fragment. In it, Maxwell admits to visiting Mar-a-Lago, Donald Trump's private club in Palm Beach, Florida. Trump's relationship with Jeffrey Epstein is well known and no further details are elaborated in this statement. Maxwell says she hired many employees of all kinds for Epstein and that a very small portion of her job "was from time to time to find adult professional masseuses" for the billionaire financier. In the interrogation, Maxwell is asked about some of the girls recruited and whether girls were provided to people such as investor Glenn Dubin, modeling agent Jean Luc Brunel (who committed suicide in prison in France before being tried for sex crimes) and the former CEO of Limited and Victoria's Secret. Leslie Wexner. The defendant is evasive. She is also asked if she was Epstein's girlfriend: "It's a complicated question. There were times when I would have liked to consider myself his girlfriend," she replies. He also points out that Prince Andrew visited Epstein's island, but that there were no girls on that occasion.

Paper 6: In Search of Answers

It's another request by the plaintiff to order Maxwell to answer questions about sexual activity related to Epstein's sexual abuse and sex trafficking without evasion.

Document 7: An Epstein Employee

It's a 2009 statement from Alfredo Rodriguez, who worked for Jeffrey Epstein

Document 8: I Embrace the Fifth Amendment

This is a request by the plaintiff to testify as witnesses in the case of the civil lawsuit both Jeffey Epstein and Sarah Kellen and Nadia Marcincova, accused of collaborating in the network of recruitment of women. It is noted that in other cases, when the latter two have been questioned, they have taken refuge in the right not to testify against themselves. "I abide by the Fifth Amendment," they repeatedly declared.

Document 9: An for Prince Andrew

This is a document from another Florida case. In it, two victims whose identities are being kept anonymous apply to join a lawsuit alleging they have been forced to have sex with celebrities, politicians, presidents, "a well-known prime minister" and others. More details about Prince Andrew are given. "Stranger No. 3 was forced to have sex with this Prince when she was a minor in three different geographical locations: in London (in Ghislaine Maxwell's apartment), in New York, and on Epstein's private island in the U.S. Virgin Islands (in an with numerous other underage girls). Epstein ordered Stranger No. 3 to give the Prince everything he asked for and demanded Stranger No. 3 inform him of the details of the sexual abuse," the text reads.

Documents 10 & 11: Further Statements

This May 2016 brief summarises the testimonies of Maxwell and victim Johanna Sjoberg and the applicant requests the questioning of 15 additional witnesses, including Jeffrey Epstein himself and several of his employees. In another text from the same month, it is requested precisely to exceed the usual legal limit of 10 declarations in this type of lawsuit.

Document 12: Prince Andrew, Trump, Clinton, Michael Jackson, David Copperfield...

Johanna Sjoberg's statement, 179 pages long, is perhaps the star document of the whole batch on which the judge has lifted the secrecy of the proceedings. In it, she says that at a meeting in which Virginia Giuffre was also present, she discovered that she was with Prince Andrew because there was a puppet puppet of the prince himself with his name and that she found it funny. "I just remember someone suggesting we take a picture, and they told us to get on the couch. So Andrew and Virginia sat down on the couch, and put the puppet on their laps. And then I sat on Andrew's lap, and I think of my own free will, and they took the puppet's hands and put them on Virginia's chest, and then Andrew put his on mine," she says.

In that same statement, the victim claims that Epstein once told her that "[Bill] Clinton likes young men, referring to girls." In 2019, the former president acknowledged that he had flown on Epstein's private plane on several occasions in 2002 and 2003, but said he knew nothing about the millionaire's "terrible crimes." Sjoberg also recounts that once he was on the tycoon's private plane, the pilots told them they couldn't land in New York and that they would divert to Atlantic City and then "Jeffrey [Epstein] said, 'Great, we'll call Trump and go ... to the casino."

The witness is asked if she had sex with him or massaged him, to which she replies that she did not, in a series of questions in which scientist Marvin Minsky, filmmaker George Lucas and lawyer Alan Dershowitz are also quoted, in all cases with negative answers.

Sjoberg also says she met Michael Jackson at Epstein's mansion in Palm Beach, Florida, which she says he didn't give her a massage, and on another occasion with magician David Copperfield. He did some magic tricks and asked her, according to her statement, if she knew that "girls get paid to find other girls."

Paper 13: The Arrest of Epstein

This is a police report from Palm Beach, Florida, from 2005 with the first incident that blew up the Epstein scandal. He was arrested after being accused of paying a 14-year-old girl for sex, which is partly described in the affidavit. Dozens of other minors described similar sexual abuse, but prosecutors eventually allowed the financier to plead guilty in 2008 to a charge involving a single victim.

Paper 14: Stephen Hawking

These are two emails. One of them, with multiple typos, is written by Jeffrey Epstein and reads: "A reward may be offered to any of Virginia's friends and acquaintances who step forward and help prove their accusations false. The strongest is the dinner with Clinton, and the new version in the Virgin Islands that Stephen Hawking participated in an underage."

Documents 15 & 16: Attorney-Client Privilege

It is a long list of emails from the plaintiff subject to professional secrecy because they contain communications with her lawyers in relation to the case. There is another, shorter list of messages from the defendant, also subject to attorney-client privilege.

Documents 17 and 18: Objections

The defendant objects to some of the applicant's requests to produce documents in the case. The applicant, in turn, refuses in another document to provide certain documents because of the attorney-client privilege. These are documents with legal arguments, but they do not provide substantial content.

Paper 19: "A Massage Means Sex"

It is an excerpt from the testimony given by the applicant. Virginia Giuffre says Ghislaine Maxwell asked her to massage Glenn Dubin; Prince Andrew, and Bill Richardson, who was governor of New Mexico. "A massage means sex," Giuffre says. In that statement, another of the most powerful revealed in this batch, Giuffre also says that she was sent to have sex with modeling agent Jean Luc Brunel, the owner of a hotel chain (around the birthday of supermodel Naomi Campbell, whose party she was at), scientist Marvin Minsky, "another prince" and many other people she doesn't remember. She took notes, but then burned them in agreement with her husband, because they're both "very spiritual" people, she says.

Documents 20, 21 and 22: Scuffle over the Declarations

Maxwell's lawyers oppose exceeding the limit of 10 depositions or, in the alternative, ask that the plaintiff bear the extra costs, while Giuffre's lawyers point out the importance of having those testimonies, including that of a person whose name is kept crossed out. This is reiterated by his counsel in another document, which is later corrected.

Paper 23: Reprise on Prince Andrew

It is an excerpt from Johanna Sjoberg's statement, where she repeats the incident of the puppet in which she says that Prince Andrew touched her breast.

Document 24: Clinton's Request for Statement

The plaintiff's lawyers requested in their amended request to exceed the limit of 10 witnesses that former President Bill Clinton would testify, but they were unsuccessful.

Paper 25: More About Witnesses

Another procedural brief about the scuffle over the number of witness depositions.

Paper 26: Repeated Fragments

Without the cause being clear, repeated fragments of Johanna Sjoberg's statement appear again, including for the third time the episode in which Prince Andrew touched her breast.

Documents 27 and 28: Procedural matters

Yet another procedural brief on whether the usual limit of 10 witness statements should be exceeded and an additional one on whether the time limit for witnesses to testify should be extended.

Paper 29: A Witness

Declaración de Rinaldo Rizzo, que trabajaba para Glenn Dubin y Eva Anderson Dubin, sin grandes revelaciones.

Documento 30: Interrogada sobre Andrés de Inglaterra

Son 27 páginas con parte de la declaración de Virginia Giuffre de mayo de 2016. En concreto, la demandante habla acerca de sus cuadernos, donde anotó los recuerdos vividos con Ghislaine Maxwell y Jeffrey Epstein, que quemó en una hoguera junto a su marido en 2013. También le preguntan por la fotografía junto al príncipe Andrés de Inglaterra, que afirma haber tomado ella misma y cree tener, seguramente guardada en cajas en la casa de sus suegros en Sídney, Australia, donde ahora reside con su esposo e hijos. También explica ahí que ella contó que Bill Clinton había volado en helicóptero junto a Ghislaine Maxwell porque a ella misma se lo contó Maxwell, no porque Clinton se lo hubiera dicho ni porque ella estuviera en ese aparato.

Documento 31: Buscando pruebas de Brunel

In this February 2016 document, the plaintiff seeks to investigate with "documents, information or objects" the modeling agent Jean Luc Brunel, who committed suicide in the Parisian prison of La Santé in February 2022, before being tried for rape, although at that time that order refers to his residence, located then in Florida. They demand documents and evidence such as recordings, CDs, photographs, proof of payments or trips, telephone recordings, etc. between 1996 and 2016 that are related or in which Virginia herself (then surnamed Roberts), Jeffrey Epstein or Ghislaine Maxwell (among others, when in the presence of minors), the lawyer Alan Dershowitz or "Emmy Taylor, Sarah Kellen or Nadia Marcinkova", three of Epstein's alleged underage victims, appear. This document also reports that Brunel's statement will be recorded on 7 June 2016, although it was eventually postponed for a few weeks.

Paper 32: The Pilot and the Detective

The key piece of information in this document is crossed out in black: the name of the person to whom it is addressed. It is a summons by Virginia Giuffre's lawyers for that person, man or woman, to testify in June 2016, again providing all documentation, correspondence, recordings, notes... that is of interest to the case for the past 20 years. Only one name is mentioned in passing: that of David Rodgers, who was Epstein's pilot for 28 years and under whose supervision several of the victims flew in the late 2000s. They are asking for information about Sarah Kellen, an assistant hired by Epstein in the early 2016s, who scheduled the massages in which he later abused dozens of women, and about Nadia Marcinkova, one of the victims. Joe Recarey, the investigator who took the first steps against Epstein in Florida and who died in 2018, is also summoned to testify in June <>.

Document 33: Ghislaine Maxwell Pursues Giuffre for Evasions

In this April 2016 document, Ghislaine Maxwell accuses Virginia Giuffre of "playing the catch-and-release game," of providing the health data she wants and when it suits her. "She is withholding information that the Court ordered to be presented and only disclosing it when she is caught in her deception." Specifically, Maxwell claims that Giuffre has been asked by her lawyers for information about her medical providers and that she has avoided doing so: "All of this information is directly relevant and necessary to defend against the plaintiff's claims for damages for 'psychological and psychiatric injuries and resulting medical expenses.'" When some of Giuffre's ailments or medical results, physical or psychological, are exposed, they are crossed out.

Paper 34: Legal Technicalities

Document 34 is barely four pages long and is pure technicality. In it, Laura A. Menninger, a lawyer at the law firm that defends Ghislaine Maxwell, certifies that 14 pieces of evidence have been presented, such as statements and transcripts of the same, especially from Virginia Giuffre and her mother, Lynn Trude, related to those evasions of which Maxwell accused her in document 33.

Paper 35: "Ghislaine Maxwell Introduced Me to the Sex Trafficking Industry"

This is one of the main documents published, in which over 12 pages 40 pages of Virginia Giuffre's statements in May 2016 are transcribed. The text begins with a half-hearted question: "... another prince, the owner of the big hotel chain and [scientist] Marvin Minsky, is there anyone else that Ghislaine Maxwell forced her to have sex with?" The answer: "I'm sure, definitely, that there is. But can I remember everybody's name? No." Asked if she can elaborate, Giuffre says: "Look, I've given them everything I know. I am sorry. This is very difficult for me and it's very frustrating to have to go through it all over again. No... I don't remember everybody. They sent me with a huge number of people."

Giuffre admits that she has no notes, that she has burned her diaries, as she said in document 30, written a posteriori and that only her husband has read. She has only discussed this issue with him, not with friends or in her new life in Colorado, USA, first, and then in Sydney, Australia. The question about Clinton and the helicopter comes up again; Alan Dershowitz does talk about him: "He lies to himself; Prince Andrew is lying to himself." He also states that he has been taking medication for years "to manage the pain suffered at the hands of Ghislaine Maxwell and Jeffrey Epstein." "Ghislaine Maxwell introduced me to the sex trafficking industry. He was the one who abused me on a regular basis. She's the one who exposed me, told me what to do, trained me as a sex slave, abused me physically and mentally," she says, claiming that Maxwell has hurt her doubly, assuring that her testimony is a lie.

Paper 36: Maxwell's Team Technicalities

In contrast to the amount of content in the previous one, document 36 is just three pages, again signed by attorney Laura A. Menninger, of Ghislaine Maxwell's defense team, in which it is stated that she presents 13 pieces of evidence: letters, medical records and copies of the statements of Virginia Giuffre, her mother and her doctor.

Paper 37: The Evidence Virginia Giuffre Doesn't Want to Present

This document is made up of almost fifty pages that make up the so-called Exhibit C. In it, second answers and modifications to a score of Giuffre's statements are presented, and above all her refusal to present more evidence, because she claims that this violates the law, among other things because the rule states that the maximum number of interrogations is 25 per person and that Giuffre at that time already had 59 statements. Giuffre also opposes certain requests for evidence and depositions (such as giving her current or past address, e.g., passports, bank statements, or prescriptions), because she claims that she has either already submitted them (such as photographs with Prince Andrew or work contracts at Mar-a-Lago, among others) or that they violate that law and bypass attorney-client privilege. "They are only required to invade her privacy, for the sole purpose of harassing and intimidating Ms. Giuffre, who was a victim of sex trafficking." In that document, he also opposes the request that he provide the photographs and videos he has in which he appears with a series of people, including Bill Clinton, former U.S. Vice President Al Gore and scientist Stephen Hawking.

Paper 38: The "Spanish" President, Trips to Thailand and France, Naomi Campbell's Birthday

Similar to Document 35, here are nearly 90 pages of Giuffre's statements, in a deposition made (and recorded; these are the transcripts) in May 2016. Each sheet is divided into four, amounting to more than 330 pages of statements. Throughout them, Giuffre details what her life is like now, in Austrialia, after having been a victim of Jeffrey Epstein in the 2000s and especially of Ghislaine Maxwell, the defendant. It is here that he is asked if he has had forced sexual encounters with foreign presidents and he assures that he has. "Honestly, I can't remember his name, I have visual memory...", he says, and when asked to describe him he says: "He's Spanish, tall, dark-haired, had a foreign accent. Man. I'd say around 40 years." The encounter took place in New Mexico, he believes, where Epstein had a ranch.

He also explains that he met Ghislaine Maxwell while working at the Mar-a-Lago club in Florida, where his father was a handyman, and got him a job for the summer. Since then, she spent long periods with Maxwell and Epstein, from the time she was a minor, at the age of 16 (there were many exploited girls, "especially between 15 and 21 years old", "all very beautiful"), and how they showered her with expensive gifts, such as a trip to Thailand, and exploited her all over the world, including Europe. where he remembers trips to Paris and the south of France or the birthday of the model Naomi Campbell. They constantly reminded her that they had very important friends and that she shouldn't "overstep the boundaries with them," and then offered her to celebrities, politicians, millionaires: "There are people I could name and people who are blurred. There was a lot going on," Giuffre says. Asked to name one of those people, he says, "Prince Andrew [of England]." He also talks about Bill Richardson, former governor of New Mexico, investor Glenn Dubin, artificial intelligence pioneer Marvin Minsky (who died in 2016) and "another prince whose name I can't remember."

After her time at the hands of Maxwell and Epstein, she has suffered from anxiety attacks and psychological problems. Giuffre also says that she has had a contract with the British newspaper Mail on Sunday in which she was paid £140,000 for the photo with Andrew, and £20,000 more for two printed stories, as well as that she has an unpublished manuscript of a book.

Paper 39: Exchange of Mails

This 35-page document is divided into two parts. First, a series of emails between the lawyers, or also by Virginia Giuffre herself where she asks them for details of the case or in which she addresses the FBI or victims' organizations. Then, a handful of tables where he gives an account of various email chains (usually between Giuffre and her lawyers) and explains the topics that are dealt with in them, from attorney-client privilege to the discussion of certain evidence, documents, possible statements or matters related to what is published by the media.

Document 40: "Persons Who May Have Relevant Information on Disputed Facts"

The last document consists of about twenty pages with a list of 77 people, called "Identities of people who may have pertinent information about disputed facts", with their full names, addresses and telephone numbers (not all), ranging from Ghislaine Maxwell, in the first place, and Virginia Giuffre, in the second, to Prince Andrew of England, and with a brief description of those people: from Mar-a-Lago staff to attorney Alan Dershowitz. Four of the names are hidden.

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