EFTA00099391

U.S. Department of Justice 
Criminal Division 
VAA:WHG:JEC:JTM 
DOJ No. CRM-182-73090 
Office of International Affairs 
Washington, D.C. 20530 
FROM: 
The Central Authority of the United States 
TO: 
The Central Authority of the United Kingdom 
SUBJECT: 
Request for Assistance in the Matter of Material Witness PA 
DATE: 
April 3, 2020 
The Central Authority of the United States of America ("U.S.") requests the assistance of 
the Central Authority of the United Kingdom ("UK") under the 1994 Treaty of Mutual Legal 
Assistance in Criminal Matters between the U.S. and the UK, as amended by the 16 December 
2004 Instrument and exchange of notes ("the Treaty"). The United States Attorney for the 
Southern District of New York and the Federal Bureau of Investigation (collectively the "U.S. 
authorities") seek to interview H.R.H. Prince Andrew Albert Christian Edward, the Duke of York, 
also known as Andrew Mountbatten-Windsor ("Prince Andrew" or "the witness"), relating to two 
ongoing criminal investigations. 
In addition, U.S. authorities seek records of certain 
communications and meetings between Prince Andrew and the subjects of one investigation. 
With regard to the interview, U.S. authorities request to conduct a voluntary interview of 
Prince Andrew and request the assistance of UK authorities in arranging for such an interview. In 
the event that the witness declines to participate in a voluntary interview, U.S. authorities request 
that UK authorities conduct a compelled interview of the witness under oath. 
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The U.S. authorities may use the requested records and information in the U.S. criminal 
investigation and proceedings, as defined at Article 19 of the Treaty, and in other U.S. criminal 
investigations and proceedings, as well as non-criminal judicial or administrative proceedings 
directly related to the U.S. criminal investigations and proceedings, pursuant to Article 7 of the 
Treaty. 
CONFIDENTIALITY 
The U.S. authorities are conducting ongoing criminal investigations. Notwithstanding 
that one or more of the persons referenced in this request is aware to some extent of the U.S. 
authorities' attention to this matter, this request also recounts specifics and evidentiary detail that 
may not be known, exposure of which could impede the investigation with regard to the integrity 
of evidence and witness accounts. Because the persons referenced in this request are generally 
aware of the U.S. authorities' investigations, U.S. authorities are not requesting that the existence 
of this legal assistance request be kept confidential. However, premature notification of the 
specific subject matter and the questions outlined in the attachments to this request could seriously 
jeopardize the investigations or compromise any trial, by prompting a witness to alter or prepare 
his/her answers to specific questions, by prompting others to destroy or tamper with evidence; 
change patterns of behavior; intimidate potential witnesses; or alert others who could do the same. 
Accordingly, and pursuant to articles 4(3)(j) and 7 of the Treaty, please keep the contents of this 
request, including the subject matter of questioning and the questions themselves, confidential and 
please ensure that they are not shared with any persons (including the witness, the witness's 
representatives, or subjects of the investigation), or with any government officials whose 
knowledge is not absolutely necessary for purposes of executing this request. In addition, please 
advise all who must be made aware of this request that the contents are to be kept confidential and 
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should not be shared with any witness, potential subjects of the investigation or any other persons. 
If this request cannot be executed without breaching such confidentiality, please notify U.S. 
authorities through the U.S. Department of Justice, Office of International Affairs prior to taking 
any action. U.S. authorities also request that UK authorities keep a written log of all those 
individuals who have been made aware of the contents of this request, noting when those 
individuals were so made aware. 
THE FACTS 
Investigation I: The Jeffrey Epstein Investigation 
U.S. citizen Jeffrey Epstein is alleged to have engaged in the sexual abuse of minor girls 
during the period of approximately 1994 through 2005. On or about July 2, 2019, a grand jury in 
the Southern District of New York returned an Indictment charging Epstein with violations of 
U.S. criminal laws in connection with his sexual abuse of minors, including with engaging in a 
conspiracy to sexually traffic in minors. Epstein was arrested pursuant to the Indictment on or 
about July 6, 2019, and had been detained pending trial in New York. On or about August 10, 
2019, Epstein committed suicide in his cell. Notwithstanding Epstein's death, the investigation 
that led to his indictment remains ongoing. That ongoing investigation has revealed evidence of 
additional criminal conduct by Epstein's associates, including Ghislaine Maxwell. 
The investigation to date has revealed that Prince Andrew may have been a witness to 
and/or participant in certain events of relevance to the ongoing investigation. For example, one 
victim has alleged that Maxwell introduced her to Prince Andrew who, according to this victim, 
was present for certain of the victim's interactions with Epstein and Maxwell. Additionally, 
documentary evidence uncovered during the course of this investigation has revealed 
information suggesting that Prince Andrew had knowledge that Maxwell recruited females to 
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engage in sex acts with Epstein and other men. Finally, there is evidence that Prince Andrew 
engaged in sexual conduct involving one of Epstein's victims. Prince Andrew is not presently a 
target of the investigation, and U.S. authorities have not, to date, gathered evidence that he has 
committed any crime under U.S. law. 
Investigation II: The Peter Nygard Investigation 
The U.S. authorities are investigating Peter Nygard, a Canadian citizen, and other co-
conspirators' involvement in an international sex trafficking ring victimizing adult women and 
minor girls. The investigation concerns, among other things, allegations of sex trafficking at 
various locations inside and outside the United States, including Nygard's estate in Lyford Cay, 
Bahamas, referred to as "Nygard Cay." Sex trafficking victims were transported internationally, 
including between the Bahamas and locations in the United States. 
The investigation of Peter Nygard and others is ongoing and no charges have been filed as 
of this date. The investigation has revealed that, on at least one occasion, Prince Andrew travelled 
to Nygard Cay in the Bahamas, a location where Nygard is believed to have trafficked minor and 
adult female victims. U.S. authorities seek to question Prince Andrew regarding his visit(s) to 
Nygard Cay during the time period under investigation, and other information he may have about 
Peter Nygard and related individuals. Prince Andrew is not presently a target of this investigation, 
and U.S. authorities have not, to date, collected evidence that he committed any crime under U.S. 
law. 
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THE OFFENSES 
The criminal conduct being investigated currently implicates the following offenses. Note 
that pursuant to Articles 7 and 19 of the Treaty, U.S. authorities may determine that additional or 
different offenses may also be implicated in this matter: 
Title 18, United States Code, Section 1591 
Sex Trafficking of Minors and by Force, 
Fraud, and Coercion 
(a) Whoever knowingly —
(1) in or affecting interstate or foreign commerce, or within the special maritime 
and territorial jurisdiction of the United States, recruits, entices, harbors, 
transports, provides, obtains, advertises, maintains, patronizes, or solicits by 
any means a person; or 
(2) benefits, financially or by receiving anything of value, from participation in a 
venture which has engaged in an act described in violation of paragraph (1), 
knowing, or, except where the act constituting the violation of paragraph (1) is 
advertising, in reckless disregard of the fact, that means of force, threats of 
force, fraud, coercion described in subsection (e)(2), or any combination of 
such means will be used to cause the person to engage in a commercial sex 
act, or that the person has not attained the age of 18 years and will be caused 
to engage in a commercial sex act, shall [have committed a crime]. 
(b) The punishment for an offense under subsection (a) is -
(1) if the offense was effected by means of force, threats of force, fraud, or 
coercion ...or by any combination of such means, or if the person recruited, 
enticed, harbored, transported, provided, obtained, advertised, patronized, or 
solicited had not attained the age of 14 years at the time of such offense, by a 
fine under this title and imprisonment for any term of years not less than 15 or 
for life; or 
(2) if he offense was not so effected, and the person recruited, enticed, harbored, 
transported, provided, obtained, advertised, patronized, or solicited had 
attained the age of 14 years but had not attained the age of 18 years at the time 
of such offense, by a fine under this title and imprisonment for not less than 
10 years or for life.'
I The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that 
occurred prior to that time, the penalties would be lower and may not include mandatory 
minimum sentences. 
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Title 18, United States Code, Section 2423 
Transportation of Minors 
(a) Transportation with intent to engage in criminal sexual activity 
(1) A person who knowingly transports an individual who has not attained the age 
of 18 years in interstate or foreign commerce, or in any commonwealth, 
territory or possession of the United States, with intent that the individual 
engage in prostitution, or in any sexual activity for which any person can be 
charged with a criminal offense, shall [have committed a crime and be] 
imprisoned not less than 10 years or for life.2
Title 18 United States Code Section 2422 
Coercion and Enticement 
(1) (b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or 
within the special maritime and territorial jurisdiction of the United States knowingly 
persuades, induces, entices, or coerces any individual who has not attained the age of 18 
years, to engage in prostitution or any sexual activity for which any person can be 
charged with a criminal offense, or attempts to do so, shall [have committed a crime and 
be] imprisoned not less than 10 years or for life.; 
Title 18, United States Code, Section 371 
Conspiracy 
If two or more persons conspire ... to commit any offense against the United 
States ... and one or more of such persons do any act to effect the object of the 
conspiracy, each shall [have committed a crime and be] imprisoned not more than 
five years. 
PERSONS INVOLVED 
Name: 
H.R.H. Prince Andrew Albert Christian Edward, Duke of York 
Also known as Andrew Mountbatten-Windsor 
Date of birth: 
19 February 1960 
Place of birth: 
Buckingham Palace, London, England 
Citizenship: 
UK 
Address: 
Royal Lodge, Windsor, England 
2 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that 
occurred prior to that time, the penalties would be lower and may not include mandatory 
minimum sentences. 
3 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that 
occurred prior to that time, the penalties would be lower and may not include mandatory 
minimum sentences. 
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Name: 
Ghislaine Maxwell 
Date of Birth: 
25 December 1961 
Place of Birth: 
Maison-Laffitte, France 
Citizenship: 
U.S., UK, France 
Name: 
Peter Nygard 
Date of Birth: 
24 July 1941 
Place of Birth: 
Helsinki, Finland 
Citizenship: 
Canada, Finland 
ASSISTANCE NEEDED 
Voluntary Interview Conducted by U.S. Authorities 
U.S. authorities seek to conduct an investigative interview of Prince Andrew. U.S. 
authorities specifically request to conduct the questioning themselves in the presence of UK 
authorities to ensure that all necessary lines of inquiry are completed in the most efficient 
fashion. The specific subject matters of questioning are set forth in Attachment A. U.S. 
authorities further request that the interview be recorded using both video and audio recording 
equipment. U.S. authorities request that at least two members of each of the following 
investigatory teams be permitted to attend the questioning: 
For Investigation I (Epstein): 
a. 
b. 
c. 
ey, Southern District of New York 
ey, Southern District of New York 
ey, Southern District of New York 
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d. 
e. 
Detective, New York City Police Department' 
For Investigation II (Nygard): 
a. 
b. 
c. 
d. 
e. 
If the witness requests, U.S. authorities are prepared to conduct the interview pursuant to a "proffer 
letter" similar to that attached as Attachment B. The letter outlines the conditions under which 
U.S. authorities will not use the witness's statements against him. 
4 NYPD detective serving on the FBI task force, and assisting in the federal investigation. 
5 NYPD detective serving on the FBI task force, and assisting in the federal investigation. 
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Voluntary Interview Conducted by UK Authorities 
In the event that UK authorities decline to permit the U.S. case team to directly question 
the witness, U.S. authorities request that UK authorities question the witness about the subject 
matters set forth in Attachment C. As noted on that list, U.S. authorities request that additional 
follow-up questions be asked by UK authorities to clarify answers given or to follow relevant lines 
of inquiry. In the event it would assist UK authorities, U.S. authorities will produce a list of 
specific questions covering each of the topics outlined in Attachment C. 
U.S. authorities also request to be present during the questioning of the witness by UK 
authorities. Those observing would include at least two members of the teams listed above. U.S. 
authorities also request that they be permitted to propose, during or at the conclusion of the 
interview, additional questions to be asked by UK authorities of the witness after hearing the 
witness's initial responses. 
U.S. authorities request that UK authorities record the interview using audio and video 
recording equipment. U.S. authorities further request that the witness be cautioned in the event of 
a voluntary interview that if he were to provide false information to authorities in connection with 
this mutual legal assistance request, he could be prosecuted for perverting the course of justice in 
the UK, and he may be prosecuted for making a false statement, in violation of Title 18, United 
States Code. Section 1001, in the U.S. 
Compelled Interview 
If the witness declines to participate in either type of voluntary interview requested above, 
U.S. authorities request that UK authorities conduct a compelled interview under oath employing 
the subject matters set out in Attachment C. As noted above, if it would assist UK authorities, 
U.S. authorities will produce a list of specific questions covering each of the topics outlined in 
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Attachment C. U.S authorities also request that the compelled interview be audio- or video-
recorded. If the witness declines to respond to questions by asserting his right to remain silent, 
U.S. authorities request that such a declination be to each question set forth in Exhibit C and that 
declination be on the audio or video recording under oath. 
Prior to conducting the compelled interview, U.S. authorities request that the witness be 
read the following caution on the record: 
• 
Pursuant to the 1994 Treaty of Mutual Legal Assistance in Criminal Matters between the 
United States of America and the United Kingdom, as amended by the 16 December 2004 
Instrument and exchange of notes, and [relevant provisions of UK domestic law], you have 
been subpoenaed to answer questions under oath. 
• 
Authorities in the United States are conducting an investigation of possible violations of 
Federal criminal laws including Sex Trafficking in violation of 18 United States Code 
Section 1591, Transportation of Minors to Engage in Sex in violation of 18 United States 
Code Section 2423, Coercion and Enticement of Minors to Engage in Sex in violation of 
18 United States Code Section 2422, and related crimes. 
• 
You may refuse to answer any question if a truthful answer to the question would tend to 
incriminate you. 
• 
Anything you do say may be used against you. 
• 
If you have retained counsel, you will be permitted a reasonable opportunity to consult 
with counsel if you so desire. 
• 
Note that if you make any knowingly false statements you can be prosecuted for perverting 
the course of justice and other related crimes under the laws of the United Kingdom. 
Future Testimony 
If the witness provides relevant information during the interview, the U.S. authorities 
request that the witness be asked if he is willing to testify in U.S. criminal proceedings in the 
Southern District of New York related to one or more of these investigation and any ensuing 
prosecutions at some future date. 
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Documents 
U.S. authorities also seek certain records which are relevant to the Epstein Investigation. 
In particular, the U.S. authorities request production of the following categories of 
communication, including email, text, recorded or transcribed voicemail, and any other written 
correspondence or notes of oral communications, which is in the custody or control of the 
witness or his representatives: 
a. 
Any notes or calendar entries reflecting communications or meetintwith 
the following individuals: Jeffrey Epstein; Ghislaine Maxwell; or 
b. 
Any documents reflecting travel to the following locations: residence 
located at 9 East 71st Street, New York, New York; "Zorro Ranch," located 
in Santa Fe, New Mexico; 358 El Brillo Way, Palm Beach, Florida; any 
other property owned or leased by Jeffrey Epstein or Ghislaine Maxwell. 
c. 
Any documents, such as receipts or tickets, reflecting events or meals at 
which the followin individuals were present: Jeffrey Epstein; Ghislaine 
Maxwell; or 
d. 
Any communication to, from, or copying Ghislaine Maxwell involving the 
followin to ics: 
i. 
ii. 
Any females Maxwell, Jeffrey Epstein or any associate or 
representative of Maxwell or Epstein arranged for Prince Andrew to 
meet; 
iii. 
Any females Maxwell, Epstein or any associate or representative of 
Maxwell or Epstein arranged for other adult men to meet. 
iv. 
Massage, massages, and/or masseuses. 
v. 
Any investigation into Epstein or is associates, including but not limited 
to any prosecutions brought by the U.S. authorities against Epstein. 
vi. 
Any civil lawsuits threatened or brought against Prince Andrew, 
Maxwell, Epstein, and/or their associates. 
vii. 
Any reference to or evidence of the destruction of evidence, the 
obstruction of investigations, or other efforts to conceal criminal 
activity by Epstein, Maxwell, or their associates. 
viii. 
Any payments made, in cash or in kind, to Maxwell, Epstein, or their 
representatives or associates. 
ix. 
Any sexual encounters and/or romantic relationships involving Prince 
Andrew and any female he met through Maxwell and/or Epstein. 
x. 
The involvement of Maxwell and/or any associate of Maxwell's in 
recruiting, enticing, transporting or trafficking minors for the purpose 
of engaging in unlawful sexual contact. 
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e. 
Any communication to, from, or copying Jeffrey Epstein involving the 
foll 
1. 
ii. 
Any females Epstein or his associates or representatives, including 
Maxwell, arranged for Prince Andrew to meet. 
iii. 
Any females Epstein or his associates or representatives, including 
Maxwell, arranged for other adult men to meet. 
iv. 
Massage, massages, and/or masseuses. 
v. 
Any investigation into Epstein or is associates or representatives, 
including but not limited to any prosecutions brought by the U.S. 
authorities against Epstein. 
vi. 
Any civil lawsuits threatened or brought against Prince Andrew, 
Maxwell, and/or their associates. 
vii. 
Any reference to or evidence of the destruction of evidence, the 
obstruction of investigations, or other efforts to conceal criminal 
activity by Epstein, Maxwell, or their associates. 
viii. 
Any payments made, in cash or in kind, to Maxwell, Epstein, or their 
representatives or associates. 
ix. 
Any sexual encounters and/or romantic relationships involving Prince 
Andrew and any female he met through Maxwell and/or Epstein. 
x. 
The involvement of Epstein and/or any associate of Epstein's in 
recruiting, enticing, transporting or trafficking minors for the purpose 
of engaging in unlawful sexual contact 
CONCLUSION 
We thank you for your assistance with this matter of Material Witness PA and ask that 
you keep us apprised of all developments. 
3 April 2020 
Date 
Jason E. Carter 
Associate Director 
Office of International Affairs 
Criminal Division 
U.S. Department of Justice 
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ATTACHMENT A 
The Jeffrey Epstein Investigation 
The U.S. Authorities would seek to question Prince Andrew regarding the following 
topics during a voluntary interview: 
I. The history and nature of Prince Andrew's relationship with Jeffrey Epstein. 
2. The history and nature of Prince Andrew's relationship with Ghislaine Maxwell. 
3. The history and nature of Prince Andrew's relationship with 
4. The details regarding any trips Prince Andrew took with and/or to visit Maxwell and/or 
Epstein. 
5. The details regarding any trips Maxwell and/or Epstein took to visit Prince Andrew. 
6. The details regarding any payments Prince Andrew made to or received from Maxwell, 
Epstein, or any female associated with Maxwell and/or Epstein. 
7. The names and identifying features of any females Prince Andrew met through Epstein 
and/or Maxwell. 
8. The details of any conversations Prince Andrew participated in or witnessed during 
which anyone discussed Epstein's sexual preferences, practices or history; Maxwell's 
sexual preferences, practices, or history; and/or Maxwell's role assisting Epstein or other 
men in locating females with whom to engage in sexual activity. 
9. The details of Prince Andrew's interactions with and/or conversations regarding 
10. Communications, including email correspondence, between Prince Andrew and Maxwell 
regarding Maxwell's attempts to introduce Prince Andrew to females. 
II. Any knowledge Prince Andrew had or may have had of inappropriate relationships, 
including improper or unlawful sexual contact, involving Epstein and/or his associates 
with any minor. 
12. Prince Andrew's involvement, if any, in any sexual contact and/or relationship with any 
person Prince Andrew met through or with Epstein and/or Maxwell. 
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The Peter Nygard Investigation 
1. The history and nature of Prince Andrew's relationship with Peter Nygard. 
2. The details regarding any trips Prince Andrew took with and/or to visit Nygard. 
3. The details of any trips Prince Andrew took to Nygard Cay, whether or not Nygard was 
present. 
4. The names and/or descriptions of any females Prince Andrew met through Nygard or at 
Nygard Cay. 
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ATTACHMENT B 
PROFFER AGREEMENT 
With respect to the meeting of 
("Client") and his attorney, 
Esq., with Assistant United States Attorney 
to be held at the Office of the 
United States Attorney for the Southern District of New York on [Meeting Date] ("the 
meeting"), the following understandings exist: 
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to 
provide the Government with information, and to respond to questions, so that the Government 
may evaluate Client's information and responses in making prosecutive decisions. By receiving 
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to 
enter into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. 
The Government makes no representation about the likelihood that any such agreement will be 
reached in connection with this proffer. 
(2) In any prosecution brought against Client by this Office, except as provided below the 
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing 
proceeding for the purpose of determining an appropriate sentence, any statements made by 
Client at the meeting, except (a) in a prosecution for false statements, obstruction of justice or 
perjury with respect to any acts committed or statements made during or after the meeting or 
testimony given after the meeting; or (b) if, at any time following the meeting, Client becomes a 
fugitive from justice. 
(3) Notwithstanding item (2) above: (a) the Government may use information 
derived directly or indirectly from the meeting for the purpose of obtaining leads to other 
evidence, which evidence may be used in any prosecution of Client by the Government; (b) in 
any prosecution brought against Client, the Government may use statements made by Client at 
the meeting and all evidence obtained directly or indirectly therefrom for the purpose of cross-
examination should Client testify; and (c) the Government may also use statements made by 
Client at the meeting to rebut any evidence or arguments offered by or on behalf of Client 
(including arguments made or issues raised sua sponte by the District Court) at any stage of the 
criminal prosecution (including bail, all phases of trial, and sentencing) in any prosecution 
brought against Client. 
(4) The Client understands and agrees that in the event the Client seeks to qualify for a 
reduction in sentence under Title 18, United States Code, Section 3553(0, United States 
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office 
may offer or use at any stage of the criminal proceeding any statement made by Client during the 
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is 
consistent with Section 402 of the First Step Act of 2018. 
(5) To the extent that the Government is entitled under this Agreement to offer in 
evidence any statements made by Client or leads obtained therefrom, Client shall assert no claim 
under the United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or 
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any other federal rule that such statements or any leads therefrom should be suppressed. It is the 
intent of this Agreement to waive all rights in the foregoing respects. 
(6) If this Office receives a request from another prosecutor's office for access to 
information obtained pursuant to this Proffer Agreement, this Office may furnish such 
information but will do so only on the condition that the requesting office honor the provisions of 
this Agreement. 
(7) It is further understood that this Agreement is limited to the statements made by 
Client at the meeting and does not apply to any oral, written or recorded statements made by 
Client at any other time. No understandings, promises, agreements and/or conditions have been 
entered into with respect to the meeting other than those set forth in this Agreement and none 
will be entered into unless in writing and signed by all parties. 
(8) The understandings set forth in paragraphs 1 through 7 above extend to the 
continuation of this meeting on the dates that appear below. 
(9) Client and Attorney acknowledge that they have fully discussed and understand 
every paragraph and clause in this Agreement and the consequences thereof. 
Dated: New York, New York 
GEOFFREY S. BERMAN 
United States Attorney for the 
Southern District of New York 
by: 
Client 
Assistant United States Attorney 
Attorney for Client 
Witness 
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ATTACHMENT C 
The Jeffrey Epstein Investigation 
I. Please provide a list of all dates of travel or visits to any of the following locations: 
a. An Epstein-owned property located at 358 El Brillo Way, Palm Beach, Florida 
b. An Epstein-owned private island known as "Little St. James," located in the U.S. 
Virgin Islands 
c. An Epstein-owned mansion located at 9 East 71st Street, New York, New York 
d. An Epstein-owned property known as "Zorro Ranch," located in Santa Fe, New 
Mexico 
2. For any dates provided for Question 1, please provide the following information: 
a. Length of visit; 
b. The names of any other individuals who were part of the visit, including family 
members and security detail; 
c. The names of any other individuals who were present at the property at the time; 
d. Any related itineraries or schedules; and 
e. Whether Prince Andrew observed any females who appeared to be, or stated that 
they were, under the age of 18 years old, the names of any of those females, any 
other observations Prince Andrew made of those females or conversations Prince 
Andrew had or witnessed involving those females, and whether Prince Andrew 
himself engaged in any sexual contact involving any of those females. 
3. Please describe the history and nature of Prince Andrew's relationship with Ghislaine 
Maxwell, including but not limited to how they met, how frequently they were in contact 
during the general time period 1994-2005, how they communicated, and when they most 
recently communicated. 
4. Please describe the history and nature of Prince Andrew's relationship with Jeffrey 
Epstein, including but not limited to how they met, how frequently they were in contact 
during the general time period 1994-2005, how they communicated, and when they most 
recently communicated. 
5. Please describe the history and nature of Prince Andrew's relationship with 
including but not limited to any sexual interactions between Prince 
Andrew and 
as well as the history and nature of any relationship between 
and Maxwell, or 
and Epstein. 
6. Please identify the approximate date(s) of any oral or written communications between 
Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or 
representative for Ghislaine Maxwell and any agent, intermediary, and/or representative 
for Prince Andrew at any time, regarding any of the following topics: 
a. Females associated with Ghislaine Maxwell; 
b. Females Ghislaine Maxwell or her representative arranged for Prince Andrew to 
meet; 
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c. Females Ghislaine Maxwell or her representative arranged for other adult men to 
d. 
e. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; 
f. Massage, massages, and/or masseuses. 
g. Any investigation into Epstein or his associates, including but not limited to any 
prosecutions brought by the U.S. authorities against Epstein. 
h. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, and/or 
their associates. 
i. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or 
otherwise cover up criminal activity by Epstein, Maxwell, or their associates. 
j. Any payments Maxwell received or expected to receive from Epstein for 
attorneys' fees or otherwise. 
7. For any communications identified in response to Question 6, please provide the 
following information: 
a. Contact information, including phone numbers and email addresses for Ghislaine 
Maxwell and/or any other individual acting as an agent, intermediary, and/or 
representative for Ghislaine Maxwell; 
b. Contact information, including phone numbers and email addresses for any 
individual acting as an agent, intermediary, and/or representative for Prince 
Andrew; and 
c. Subject matter of the communications. Please be as detailed as possible. In 
particular, please describe any communications regarding the following topics: 
i. Females associated with Ghislaine Maxwell; 
ii. Females Ghislaine Maxwell or her representative arranged for Prince 
Andrew to meet; 
iii. Females Ghislaine Maxwell or her representative arranged for other adult 
men to meet. 
iv. 
v. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; 
vi. Massage, massages, and/or masseuses. 
vii. Any investigation into Epstein or his associates, including but not limited 
to any prosecutions brought by the U.S. authorities against Epstein. 
viii. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, 
and/or their associates. 
ix. Any attempts to destroy evidence, obstruct or impede ongoing 
investigations, or otherwise cover up criminal activity by Epstein, 
Maxwell, or their associates. 
x. Any payments Maxwell received or expected to receive from Epstein for 
attorneys' fees or otherwise. 
8. Please identify the approximate date(s) of any oral or written communications between 
Jeffrey Epstein or any other individual acting as an agent, intermediary, and/or 
representative for Jeffrey Epstein and any agent, intermediary, and/or representative for 
Prince Andrew at any time, regarding any of the following topics: 
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a. Females associated with Jeffrey Epstein; 
b. Females Jeffrey Epstein or his representative arranged for Prince Andrew to meet; 
c. Females Jeffrey Epstein or his representative arranged for other adult men to 
meet. 
d. 
e. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; 
f. Massage, massages, and/or masseuses. 
g. Any investigation into Epstein or his associates, including but not limited to any 
prosecutions brought by the U.S. authorities against Epstein. 
h. Any civil lawsuits threatened or brought against Epstein and/or his associates. 
i. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or 
otherwise cover up criminal activity by Epstein, Maxwell, or their associates. 
j. Any payments Epstein made or intended to make to Maxwell for attorneys' fees 
or otherwise. 
9. For any communications identified in response to Question 8, please provide the 
following information: 
a. Contact information, including phone numbers and email addresses for Jeffrey 
Epstein and/or any other individual acting as an agent, intermediary, and/or 
representative for Jeffrey Epstein; 
b. Contact information, including phone numbers and email addresses for any 
individual acting as an agent, intermediary, and/or representative for Prince 
Andrew; and 
c. Subject matter of the communications. Please be as detailed as possible. In 
particular, please describe any communications regarding the following topics: 
i. Females associated with Jeffrey Epstein; 
ii. Females Jeffrey Epstein or his representative arranged for Prince Andrew 
to meet; 
iii. Females Jeffrey Epstein or his representative arranged for other adult men 
to meet-
iv. 
• 
v. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; 
vi. Massage, massages, and/or masseuses. 
vii. Any investigation into Epstein or his associates, including but not limited 
to any prosecutions brought by the U.S. authorities against Epstein. 
viii. Any civil lawsuits threatened or brought against Epstein and/or his 
associates. 
ix. Any attempts to destroy evidence, obstruct or impede ongoing 
investigations, or otherwise cover up criminal activity by Epstein, 
Maxwell, or their associates. 
x. Any payments Epstein made or intended to make to Maxwell for 
attorneys' fees or otherwise. 
10. Please identif the a roximate date(s) of any oral or written communications between 
or any other individual acting as an agent, intermediary, and/or 
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representative for 
and any agent, intermediary, and/or 
representative for Prince Andrew 
11. For any communications identified in response to Question 10, please provide the 
following information: 
a. Contact information, including phone numbers and email addresses for 
and/or a 
' 
' 
as an agent, intermediary, 
and/or representative for 
b. Contact information, including phone numbers and email addresses for any 
individual acting as an agent, intermediary, and/or representative for Prince 
Andrew; and 
c. Subject matter of the communications. 
d. Nature of Prince Andrew's interactions with 
12. Please identify the approximately dates and locations of any meetings or other 
interactions with 
including the nature and/or purpose of the 
meeting, the approximate duration of the meeting, the name(s) of any other persons 
present for the meeting, and a detailed account of what occurred at the meeting. 
13. Please identify any payments made, in any form including by cash or in kind, to Prince 
Andrew by Ghislaine Maxwell or any other individual acting as an agent, intermediary, 
and/or representative for Ghislaine Maxwell. Please include travel, lodging, or other 
expenses paid in connection with any trip to visit Ghislaine Maxwell. 
14. Please identify any payments made, in any form including by cash or in kind, to 
Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or 
representative for Ghislaine Maxwell from or on behalf of Prince Andrew. 
15. Please identify any payments made, in any form including by cash or in kind, to Prince 
Andrew by Jeffrey Epstein or any other individual acting as an agent, intermediary, 
and/or representative for Jeffrey Epstein. Please include travel, lodging, or other 
expenses paid in connection with any trip to visit Jeffrey Epstein. 
16. Please identify any payments made, in any form including by cash or in kind, to Jeffrey 
Epstein or any other individual acting as an agent, intermediary, and/or representative for 
Jeffrey Epstein well from or on behalf of Prince Andrew. 
17. Please identif any payments made, in any form including by cash or in kind, to 
or an other individual acting as an agent, intermediary, and/or 
representative for 
well from or on behalf of Prince Andrew. 
18. Please identify any payments made, in any form including by cash or in kind, to any 
female Prince Andrew met through Ghislaine Maxwell and/or Jeffrey Epstein, or any 
other individual acting as an agent, intermediary, and/or representative for any such 
female from or on behalf of Prince Andrew. 
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