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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
rly instances your access to the client. It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could before the court. But the n
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
rly instances your access to the client. It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could before the court. But the n
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, 9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, 9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, 9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, 9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, 9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, 9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
s arrested on July 2, 2020 and since that date has been detained in jaw-droppingly appalling conditions. The government claims that Ms. Maxwell was Jeffrey Epstein's "associate" and helped him "groom" minors for sex back in the 1990s and early 2000s. Doc. 187. The indictment does not name these accusers and the
vnv.dailymail.co.ulc/news/ article-8444B7/Jeffrey-Epsteins-fugitive-madam-Ghislaine- Maxwell-hiding-lwcury-P
ed public outrage over the inexplicable death of Jeffrey Epstein, while in their custody. The "Epstein Ef
(S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) 18 United States v. Williams-Bethea, No. 18-CR-78 (MN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020) 6 Statutes 18 U.S.C. § 3142 passim iii EFTA00093093 cggeei ThOesttuAlitqltdeggn
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) La
Page: EFTA00018515 →(S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) 18 United States v. Williams-Bethea, No. 18-CR-78 (MN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020) 6 Statutes 18 U.S.C. § 3142 passim iii EFTA00018518 --- PAGE BREAK --- Case 1:2
Page: EFTA00018518 →.uk/newstarlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine M
Page: EFTA00018531 →xwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https://svww.dailymail.co.uk/newstarlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Manvell: the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htt
Page: EFTA00018531 →Entities connected to both Jeffrey Epstein and Williams-Bethea

Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Stephen Hawking
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Michael Jackson
PERSON
Geoffrey S. Berman
PERSONCourtney Wild
PERSON
Harvey Weinstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Denver
LOCATION
Metropolitan Correctional Center
ORGANIZATION
Colorado
LOCATION
Bernie Sanders
PERSON
Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSON
Houston
LOCATION