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le income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a $10 million cash grant to the defendant. The financial report further shows that the defendant apparently spent the last five
1994 and 1997. The defendant played a critical role in the scheme by helping to identify, entice, and groom minor girls to engage in sex acts with Epstein. The defendant's presence as an adult woman normalized Epstein's abusive behavior, and she even took part in at least some acts of sexual abuse. Tog
ng the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The
requent international travel, "minimal" ties to the United States, and "extensive ties to foreign countries without extradition"); United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) (ordering defendant detained based on defendant's risk of flight and citing the strength of 28
10) 15 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 27 United States v. English, 629 F.3d 311 (2d Cir. 2011) 7 United States v. Epstein, 155 F. Supp. 2d 323 (E.D. Pa. 2001) 28 United States v. Epstein, 425 F. Supp. 3d 306 (S.D.N.Y. 2019) 15, 29 United States v. Esposito, 309 F. Su
le income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a $10 million cash grant to the defendant. The financial report further shows that the defendant apparently spent the last five
ng the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The
8, 2016 WL 7421924 (W.D.N.Y. Dec. 23, 2016) 15 United States v. Namer, 238 F.3d 425, 2000 WL 1872012 (6th Cir. Dec. 12, 2000) 19 United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) 28 United States v. Petrov, 15 Cr. 66 (LTS), 2015 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 7, 8 Un
9/08, Knox) (2) (3), and the Associated Press (09/08, Verduzco, Brumfield). Fox News (09/08, Harris) also published an opinion piece on the story. Epstein Birthday Letter With President Trump's Signature Revealed The Wall Street Journal (09/08, Safdar, Palazzolo) reported that lawyers for Jeffrey Epste
ory. Epstein Birthday Letter With President Trump's Signature Revealed The Wall Street Journal (09/08, Safdar, Palazzolo) reported that lawyers for Jeffrey Epstein's estate turned over a professionally bound birthday book from Epstein's 50th birthday to the House Oversight Committee, which included a letter bear
/08, Safdar, Palazzolo) reported that lawyers for Jeffrey Epstein's estate turned over a professionally bo
e later admitted to leaking sensitive information to an Albanian businessman connected to the Chinese conglomerate CEFC, whose executives, including Patrick Ho, had business dealings with Hunter Biden. Ho was convicted in 2019 of bribery charges unrelated to Biden but had agreed to pay Hunter Biden a $1 mi
9/06, Millward). MSNBC (09/06, Video) published broadcast coverage of the story. House Speaker Backs Off Claim That Trump Was An 'FBI Informant' in Jeffrey Epstein Case The Washington Post (09/07, Partlow, Alfaro) reported that House Speaker Mike Johnson backed off his claim that President Donald Trump was an FBI i
fied that Trump was criticizing Democrats' use of the scandal against him politically, saying, "It's been misrepresented. He's not saying that what Epstein did is a hoax. It's a terrible, unspeakable evil; he believes that himself. When he first heard the rumor, he kicked him out of Mar-a-Lago." Johnson
t Donald Trump served as an FBI informant in the Jeffrey Epstein case while defending Trump's recent comme
obe multiple times in 2017, including during a Florida trip and in a later phone call where he said, "we are ready for them," before CEFC executive Patrick Ho was arrested on bribery charges. According to the article, McGonigal initially downplayed his relationship with Ho but admitted to the leaks after a
ne 29, 2020. a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that
t 30 years, might flee to the United Kingdom or France if granted bail, despite the fact that she did not leave the country for nearly a year after Epstein's arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France "does not extradite its citizens to the United States pursuant to F
eve of the one-year anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxw
8, 2016 WL 7421924 (W.D.N.Y. Dec. 23, 2016) 15 United States v. Namer, 238 F.3d 425, 2000 WL 1872012 (6th Cir. Dec. 12, 2000) 19 United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) 28 United States v. Petrov, 15 Cr. 66 (LTS), 2015 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 7, 8 Un
Entities connected to both Jeffrey Epstein and Patrick Ho

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
Donald Trump
PERSON
United States
LOCATION
Glenn Dubin
PERSON
Joe Biden
PERSON
Prince Charles
PERSONSouthern District
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Alfredo Rodriguez
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Michael Jackson
PERSON
Bloomberg L.P.
ORGANIZATION