Epstein Secrets

ristian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

7 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 12 Other Authorities Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghislaine Maxwell Arrested on Sex Abuse Charges." NBC New York. July 3, 2020 15 iii EFTA00028883 --- PAGE BREAK --- Ghislaine Maxw

F.3d 136 (2d Cir. 1999) 10 EFTA00028882 --- PAGE BREAK --- United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 17 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 12 Other Authorities Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghisl

of the NPA states, without limitation, that "the United States .. . will not institute any criminal charges against any potential co-conspirators of Epstein." Because the Superseding Indictment ("Indictment") contends that Ms. Maxwell was a co-conspirator of Epstein, the NPA, on its face, applies here.

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving a defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows a history that is both highly unusual and deeply troubling. The gov

ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK), 2003 WL 22510398 (S.D.N.Y. Nov. 5, 2003) 29 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 24 United States v. Vaval, 404 F.3d 144 (2d Cir. 2005) 13 Statutes 18 U.S.C. § 2422 26 18 U.S.C.§ 2423 26 Ot

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving I defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows I history that is both highly unusual and deeply troubling. The gov

overnment has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimat

ameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK), 2003 WL 22510398 (S.D.N.Y. Nov. 5, 2003) 29 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 24 United States v. Vaval, 404 F.3d 144 (2d Cir. 2005) 13 Statutes 18 U.S.C. § 2422 26 18 U.S.C.§ 2423 26 Ot