Epstein Secrets

nd Three. Conspiracy charges may be brought "in any district in which an overt act in furtherance of the conspiracy was committed." United States v. Lange, 834 F.3d 58, 68 (2d Cir. 2016). Here, the calls from New York to schedule appointments and the packages 2021.01.26 EFTA_00023140 EFTA02731246

axwell's knowledge of a e, Maxwell's knowledge that the massages were sexual, Maxwell's attempts to entice to travel with Epstein. and actions in the Southern District of New York in furtherance of the scheme to sexually abuse As detailed below, we have identified evidence from documents and at least one witness

much to prevent the criminal from being twice punished for the same offense as from being twice tried for it. Pearce, 395 U.S. at 717-18 (quoting Lange, 85 U.S. (18 Wall.) at 168) (emphasis added). Here, it is beyond dispute that Epstein was already punished for the offenses covered by the NPA. The

ive and Six Allege the Same Offenses that Were Part of the Florida Investigation and Are Covered by the Plain Terms of the NPA 6 B. The NPA Binds the Southern District of New York as to Counts Five and Six. 11 C. Counts One and Three Must Also Be Dismissed 17 II. Prosecuting Ms. Maxwell on Counts Five and S

The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page(s) Cases Ex parte Lange, 85 U.S. (18 Wall.) 163 (1873) 11 Morris v. Reynolds, 264 F.3d 38 (2d Cir. 2001) 12 North Carolina v. Pearce, 395 U.S. 711 (1969) II, 12, 13

axwell is a stunning example of prosecutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to pros