Epstein Secrets

ic events and acts of ,ib.:se d,=t=ilnl above. STATUTORY ALLEGATIONS 11. From at _east. in or about 1994, up to and including in or about 2004, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 11 EFTA00078050 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12

t by, among other things, discussing sexual topics in front of Minor Victim-4 and being present when Minor Victim-4 was nude in the massage room of the Palm Beach Residence. On multiple occasions between approximately 2001 and 2004, Minor Victim-4 provided nude massages to Epstein at the Palm Beach Residence, during w

ic events and acts of ,ib.:se d,=t=ilnl above. STATUTORY ALLEGATIONS 11. From at _east. in or about 1994, up to and including in or about 2004, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 11 EFTA00080649 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12

t by, among other things, discussing sexual topics in front of Minor Victim-4 and being present when Minor Victim-4 was nude in the massage room of the Palm Beach Residence. On multiple occasions between approximately 2001 and 2004, Minor Victim-4 provided nude massages to Epstein at the Palm Beach Residence, during w

ic events and acts of ,ib.:se d,=t=ilnl above. STATUTORY ALLEGATIONS 11. From at _east. in or about 1994, up to and including in or about 2004, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 11 EFTA00093655 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12

t by, among other things, discussing sexual topics in front of Minor Victim-4 and being present when Minor Victim-4 was nude in the massage room of the Palm Beach Residence. On multiple occasions between approximately 2001 and 2004, Minor Victim-4 provided nude massages to Epstein at the Palm Beach Residence, during w

ic events and acts of ,ib.:se d,=t=ilnl above. STATUTORY ALLEGATIONS 11. From at _east. in or about 1994, up to and including in or about 2004, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 11 EFTA00097595 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12

t by, among other things, discussing sexual topics in front of Minor Victim-4 and being present when Minor Victim-4 was nude in the massage room of the Palm Beach Residence. On multiple occasions between approximately 2001 and 2004, Minor Victim-4 provided nude massages to Epstein at the Palm Beach Residence, during w

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

le sex acts" with Accuser-4. (Id. ¶ 9d). (4) The dates when Ms. Maxwell allegedly was "present" when [Accuser-4] "was nude in the massage room of the Palm Beach Residence." (Id. ¶ 9d). 23 EFTA00103784 (5) The dates when, and locations where, Ms. Maxwell allegedly paid Accuser-4 "hundreds of dollars in cash." (Id.

ecific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 11. From at least in or about 1994, up to and including in or about 2004, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 11 EFTA00155317 Epstein, and others known and unknown, willfully and knowin

t by, among other things, discussing sexual topics in front of Minor Victim-4 and being present when Minor Victim-4 was nude in the massage room of the Palm Beach Residence. On multiple occasions between approximately 2001 and 2004, Minor Victim-4 provided nude massages to Epstein at the Palm Beach Residence, during w

all pertain to the negotiation and eventual entering into of a Non-Prosecution Agreement (NPA) with the United States Attorney's Office (USAO) for the Southern District of Florida. See part I above herein. Again, the constitutional issues raised in Defendant's response permeate these discovery requests. The full te

not identified in response to interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. No. 3. Identify all persons who came to the Palm Beach Residence and who gave a massage or were asked to give a massage to Defendant. No. 4. Identify all persons who came to the New York Residence and who gave a

as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010. 6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agree

OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon

girl they brought to the Palm Beach Residence. STATUTORY ALLEGATIONS 20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of NeW York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederat

nt, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence. 6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and 2 EFTA00257734 recruited,

ic events and acts of ,ib.:se d,=t=ilnl above. STATUTORY ALLEGATIONS 11. From at _east. in or about 1994, up to and including in or about 2004, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 11 EFTA01659472 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12

t by, among other things, discussing sexual topics in front of Minor Victim-4 and being present when Minor Victim-4 was nude in the massage room of the Palm Beach Residence. On multiple occasions between approximately 2001 and 2004, Minor Victim-4 provided nude massages to Epstein at the Palm Beach Residence, during w