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18 19 20 21 22 23 24 25 were sometimes partially or fully nude. She also encouraged these minors to engage in additional acts of abuse with Jeffrey Epstein. The indictment makes plain, your Honor, this was not a single incident or a single victim or anything isolated but, instead, it was an ongoing sch
.C. (212) 805-0300 EFTA00066240 Lb k7e2MaxC kjc 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include information as to her whereabouts? : Your Honor, that information did not include information about her whe
deliver me, with full knowledge of the heinous and dehumanizing abuse that awaited me, straight to the hands of Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done what he did. She was in charge. She egged him on and encouraged him. She told me of others she recruited and she thought it wa
16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include informati
s hiding and we have evidence, your Honor, that the defendant was making plans to leave the country. That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that
16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include informati
encouraged 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 these minors to engage in additional acts of abuse with Jeffrey Epstein. The indictment makes plain, your Honor, this was not a single incident or a single victim or anything isolated but, instead, it was an ongoing sch
04/01/2021, 3068296. Page75 of 351 26 k7e2MaxC kjc 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include information as to her whereabouts? : Your Honor, that information did not include information about her whe
deliver me, with full knowledge of the heinous and dehumanizing abuse that awaited me, straight to the hands of Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done what he did. She was in charge. She egged him on and encouraged him. She told me of others she recruited and she thought it wa
s hiding and we have evidence, your Honor, that the defendant was making plans to leave the country. That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that
ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (t
Page: EFTA00015532 →a defendant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday
Page: EFTA00015534 →ation about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of decades
Page: EFTA00015538 →ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8, 2019, in
Page: EFTA00024584 →New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: Th
Page: EFTA00024584 →erties and residences around the world, including in Manhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary residence in the United States. His mansion i
Page: EFTA00024586 →rable Henry Pitman United States Magistrate Judge July 8, 2019 Page 8 merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home dete
Page: EFTA00024591 →ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8, 2019, in
Page: EFTA00029004 →New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: Th
Page: EFTA00029004 →erties and residences around the world, including in Manhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary residence in the United States. His mansion i
Page: EFTA00029006 →rable Henry Pitman United States Magistrate Judge July 8, 2019 Page 8 merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home dete
Page: EFTA00029011 →ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 9,
Page: EFTA00028297 →s District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 9, 2019, in
Page: EFTA00028297 →mong other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida. B. The Defendant Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant and through his direction of others, including certain of his employee
Page: EFTA00028298 →as required. At best, home confinement with electronic monitoring would merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home dete
Page: EFTA00028304 →ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (t
Page: EFTA00028785 →a defendant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday
Page: EFTA00028787 →ant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. `It's t
Page: EFTA00028787 →ation about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of decades
Page: EFTA00028791 →ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8,
Page: EFTA00030832 →s District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8, 2019, in
Page: EFTA00030832 →mong other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida. B. The Defendant Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant and through his direction of others, including certain of his employee
Page: EFTA00030833 →rable Henry Pitman United States Magistrate Judge July 8, 2019 Page 8 merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home dete
Page: EFTA00030839 →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 tha
Page: EFTA00013308 →nst the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims
Page: EFTA00013308 →including flight records and other witnesses' corroborating testimony, will further support the main witnesses' testimony and link the Defendant to Epstein's conduct. Gov't Opp'n at 10-11. And while the Defendant contends that much of this evidence focuses on Epstein, not the Defendant, the nature of t
Page: EFTA00013316 →observed, "home detention with electronic monitoring does not prevent flight; at best, it limits a fleeing defendant's head start." United States v. Zarger, No. 00- CR-773-S-1 (JG), 2000 WL 1134364, at *I (E.D.N.Y. Aug. 4, 2000). Furthermore, while the Defendant now represents that she would be released
Page: EFTA00013325 →erefore order her detained. The charges in this case are unquestionably serious: the Indictment alleges that Ghislaine Maxwell, in partnership with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very
Page: EFTA00018506 →eges that Ghislaine Maxwell, in partnership with Jeffrey Epstein, a serial sexual predator, exploited and
Page: EFTA00018506 →S.C. § 2423 and 2; and two counts of perjury, in violation of 18 U.S.C. § 1623. The charges arise from a scheme to sexually abuse underage girls at Epstein's properties in New York, Florida, and New Mexico, between approximately 1994 and 1997. During that time, Maxwell had a personal and professional r
Page: EFTA00018507 →ing device. At best, home confinement with electronic monitoring would merely reduce her head start should she decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 8 EFTA00018513 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 10 of 10 (E.D.N
Page: EFTA00018514 →Entities connected to both Jeffrey Epstein and Zarger

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George Mitchell
PERSON
United States
LOCATION
Harry Reid
PERSON
Stephen Hawking
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Reid Weingarten
PERSON
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATION
Palm Beach
LOCATIONEmmy Taylor
PERSON
Michael Jackson
PERSON
Geoffrey S. Berman
PERSON