Epstein Secrets

f the following documents: a. Any notes, memoranda, or recordings of interviews of conducted by French law enforcement. b. Materials seized from Jeffrey Epstein's Parisian residence located at Paris 16th district, which was searched on September 23, 2019; in particular: i. Photographs of and other females

was a witness to certain events, conduct, or conversations relevant to its prosecution of Maxwell and, in particular, that was sexually abused by Epstein 1 EFTA00090290 in New York after meeting Epstein and Maxwell in in approximately In addition, the U.S. authorities seek the assistance of Fren

exploitation and abuse of multiple minor girls by Jeffrey Epstein from at least in or about 1994, up to an

secution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following doc

f the following documents: a. Any notes, memoranda, or recordings of interviews of conducted by French law enforcement. b. Materials seized from Jeffrey Epstein's Parisian residence located at Paris 16th district, which was searched on September 23, 2019; in particular: i. Photographs of and other females

was a witness to certain events, conduct, or conversations relevant to its prosecution of Maxwell and, in particular, that was sexually abused by Epstein 1 EFTA00092519 in New York after meeting both him and Maxwell in In addition, the U.S. authorities seek the assistance of French authorities to

exploitation and abuse of multiple minor girls by Jeffrey Epstein from at least in or about 1994, up to an

secution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following doc

f the following documents: a. Any notes, memoranda, or recordings of interviews of conducted by French law enforcement. b. Materials seized from Jeffrey Epstein's Parisian residence located at Paris 16th district, which was searched on September 23, 2019; in particular: i. Photographs of and other females

was a witness to certain events, conduct, or conversations relevant to its prosecution of Maxwell and, in particular, that was sexually abused by Epstein 1 EFTA00095575 in New York after meeting bath-himEpstein and Maxwell in in approximately In addition, the U.S. authorities seek the assistance

exploitation and abuse of multiple minor girls by Jeffrey Epstein from at least in or about 1994, up to an

secution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following doc

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

s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro

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

nst the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims

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

r country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government's opposition that the French Code of Criminal Procedure "absolutely

Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

record would readily support release on strict bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the significant additional evidence proffered to the Court and further arg

documentary corroboration referenced by the government—which are the same examples that the government touted at the initial bail hearing—pertain to Epstein, not Ms. Maxwell. The government concedes that government further states that (Gov. Mem. at II (emphasis added)). The (Id. (emphasis added)). Th

LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

record would readily support release on strict bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the significant additional evidence proffered to the Court and further arg

documentary corroboration referenced by the government—which are the same examples that the government touted at the initial hail hearing pertain to Epstein, not Ms. Maxwell. The government concedes that ." (Gov. Mem. at 11 (emphasis added)). The government further states that " I=1=1 ." (Id. (emphas

Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

record would readily support release on strict bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the significant additional evidence proffered to the Court and further arg

documentary corroboration referenced by the government—which are the same examples that the government touted at the initial bail hearing—pertain to Epstein, not Ms. Maxwell. The government concedes that (Gov. Mem. at 11 (emphasis added)). The government further states that (Id. (emphasis added)). Th

LP 800 Third Avenue New York NY 10022 Phone:_ Jeffrey S. Pagliuca Laura A. Mcnninger HADDON, MORGAN &

retrial motions pending before the Court. Among other things, Ms. Maxwell has persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in 2007, which immunizes "any potential co-conspirators of Epstein," bars Ms. Maxwell's prosecution in this case, and that the counts charging her

s persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in 2007, which immunizes "any potential co-conspirators of Epstein," bars Ms. Maxwell's prosecution in this case, and that the counts charging her with alleged sexual abuse are time-barred. The government's respon

e de droll penal et de procedure penale Extradition Pa. - Conditions de fond de l'estradition Delphine Brach-Thiel-October 2t I 8„f59). 18. Third, the French Ministry of Justice's interpretation is contradicted by precedents and case law 19. The French Ministry of Justice's interpretation finds no support in case law, as no