Epstein Secrets

form the basis for Counts Five and Six—to the grand jury in the Southern District of Florida in support of a proposed 60-count federal indictment of Jeffrey Epstein and Sarah Kellen. (Id. at 22:17-31:6). The indictment included a conspiracy count and a substantive count alleging a sex trafficking offense involvi

torney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And remarkably, although interviewed just a few years after she claims any misconduct occurred

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

5a). "[F]rom 2001 to 2004, [Accuser-4] provided Mr. Epstein with ... over 100 massages and all but three of

passim 820 F.2d 572 (2d Cir. 1987) 22, 23 United States v. Brown, No. 99-1230(L), 2002 WL 34244994 (2d Cir. Apr. 26, 2002) 16 United States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979) 20 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 17 United States v. Garcia-Gonzalez, 714 F.3d 306 (5th C

ed here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "potential co-conspirators" and abandoned any potential federa

s Office for the Southern District of New York ("USAO-SDNY") decided that it was not satisfied with this outcome and is now seeking a "do-over." But Epstein died as a result of the government's own negligence before he could be brought to trial. The government has now targeted Ms. Maxwell as the next be

RESSER LLP 800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

er alleged abuse to the FBI, at a time when the events were most fresh in her mind, is extraordinarily significant. It 5 The government argues that Cambindo Valencia is inapposite because it contends that the charges against the defendant's wife were dismissed because her prosecution violated the defendant's plea

001) 12 North Carolina v. Pearce, 395 U.S. 711 (1969) II, 12, 13 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) passim United States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979) 13, 14 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 10 United States v. Dionisio, 503 F.3d 78 (2d Cir. 2

its conclusions here and its reasoning on the pages that follow: • Maxwell moves to dismiss counts one, three, five, and six as barred by Jeffrey Epstein's non-prosecution agreement. The Court again concludes, as it did in its April 16, 2021 Opinion & Order, that the agreement does not bind the United

iss counts one, three, five, and six as barred by Jeffrey Epstein's non-prosecution agreement. The Court a

mmary of its conclusions here and its reasoning on the pages that follow: • Maxwell moves to dismiss counts one, three, five, and six as barred by Jeffrey Epstein's non-prosecution agreement. The Court again concludes, as it did in its April 16, 2021 Opinion & Order, that the agreement does not bind the

In its April 16, 2021 Opinion & Order on Maxwell's first set of pretrial motions, the Court held that the non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida did not bar the charges against Maxwell in the S1 superseding indictment. See U

ht not be permissible against a defendant whose charges were dismissed after her husband pleaded guilty. Dkt. No. 293 at 19 (citing United States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979)). However, the Court agrees with the Government that the result in Cambindo Valencia rested on the terms of the husban