EFTA00079973.pdf

U.S. Depariment of Justice United States Attorney Southern District of New York The Silvio J. Atollo Building One Saint Andrew's Plaza New York New York 10007 January 23, 2020 VIA EMAIL Delta Airlines, Inc. Attn: Judy Gorham P.O. Box 20574 Atlanta GA 30320 Email: Re: Grand Jury Subpoena Please be advised that the accompanying grand jury subpoena has been issued in connection with an official criminal investigation of a suspected felony being conducted by a federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. While you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation. Thank you for your cooperation in this matter. Very truly yours, GE n FFREY S. BERMAN Un' ed States Attorney Assistant United States Attorney Southern District of New York EFTA00079973 (;rand Jury Subpoena pnitebroStatez Piztrie Tourt SOUTHERN DISTRICT OF NEW YORK TO: Delta Airlines, Inc. Attn: Judy Gorham P.O. Box 20574 Atlanta, GA 30320 Email: GREETINGS: WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the GRAND JURY of the people of the United States for the Southern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: February 7, 2020 Appearance Time: 10 a.m. to testify and give evidence in regard to alleged violations of federal criminal law, including: 18 U.S.C. §§ 1591, 1594(c), 2422(b), 371 and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: SEE ATTACHED RIDER. Personal appearance is not required quested records are (1) produced by on or before the return date to Special at: Federal Bureau of Investi ation 26 Federal Plaza VCAC/Human Trafficking, New York, NY 10278, telephone: and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. DATED: New York, New York January 23, 2020 GEOFFREY S. BERMAN U? ted States Attorney for the So then? District of New York Assistant United States Attorney One St. Andrew's Plaza New York, New York 10007 Tele hone: 212-637-2415 EFTA00079974 RIDER (Grand Jury Subpoena to Delta Airlines, Inc., dated January 23, 2020) Please provide any and all records, including but not limited to passenger, payment, membership or loyalty, or any other records, for each of the below-listed individuals, for the following periods: - January 1, 1994, through December 31, 1998, and - July 1, 2019, through the date of service: Individuals: • Ghislaine Maxwell, a/Ida Ghislaine Borgerson o Date of Birth: o Date of Birth: o Date of Birth: • • N.B.: Personal appearance is not required if the re nested records are (1) produced by on or before the return date to Special Agen t: Federal Bureau of Investigation, 26 Federal Plaza V AC uman Traffickin New York, NY 10278, telephone: ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. IMPORTANT: REQUEST FOR NON-DISCLOSURE Due to the ongoing nature of the investigation, it is requested that you do not disclose any information relating to this Grand Jury subpoena request to any third party. 3 EFTA00079975 Declaration of Custodian of Records Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: My name is (name of declarant) I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. I am in receipt of a Grand Ju Sub na, dated January 23, 2010, and signed by Assistant United States Attorney requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena: (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; (2) were kept in the course of regularly conducted business activity; and (3) were made by the regularly conducted business activity as a regular practice. I declare under penalty of perjury that the foregoing is true and correct. Executed on (date) (signature of declarant) (name and title of declarant) (name of business) (business address) Definitions of terms used above: As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit. EFTA00079976