Epstein Secrets

easons: BACKGROUND Accuser 4, was first contacted by the FBI in 2007. was interviewed on August 7, 2007 by Agents and asked about any abuse by Jeffrey Epstein. did not identify Ms. Maxwell as someone who recruited her, groomed her, or otherwise interacted with her in Palm Beach, Florida, or any other loca

ed with her in Palm Beach, Florida, or any other location. She identified as someone she interacted with and who took nude photographs of her at Mr. Epstein's direction. After her FBI interview, represented by counsel, filed i.' lawsuits against Jeffrey Epstein . Neither of those lawsuits mentions Ms

AINE MAXWELL'S MOTION TO SUPPRESS IDENTIFICATION Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

cted with and who took nude photographs of her at Mr. Epstein's direction. After her FBI interview, represen

R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Chislaine Maxwell EFTA00090466 TABLE OF CONTENTS BACKGROUND 1 ARGUMENT 2 i EFTA00090467 TABLES O

rtedly between Ms. Maxwell and third-party "influential" men whom she allegedly tried to set up on dates, and (b) a witness a woman who worked for Epstein between 2005-06 (after the conclusion of the charged conspiracy) whom the Government said it "may call" at trial. The Government asserted in the Le

ified] documentary evidence relating to the 4 EFTA00105960 charged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey Epstein with underage girls," apparently in 2005-06. This is hardly the type of "identiff ied]" evidence the Rule contemplates. What "documentary evidence"

RE TO COMPLY WITH THE RULE'S NOTICE REQUIREMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

e Letter makes clear that the witness worked for Mr. Epstein from 2005-06, after the conclusion of the charged

Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York, NY 10007 Phone Attorneys for Chislaine Maxwell EFTA00105954 TABLE OF CONTENTS BACKGROUND 1 I. 2020 Amendments to Rule 404(b) 1

ntified author, date of creation, or custodian. These pages are from a 97-page exhibit provide to the Government from lawyers who represent multiple Epstein accusers. The document, as produced to the Government, is attached as Exhibit 1. As produced, the document appears to be a compilation of material

ENTICATED HEARSAY DOCUMENT FROM SUSPECT SOURCES Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ds, one of the lawyers who was involved in suing Mr. Epstein in 2009. According to the Criminal Complaint fil

COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 Phone: 212-243-1100 Attorneys for Chislaine Maxwell EFTA00074468 TABLE OF CONTENTS INTRODUCTION I. The Document Cannot be

native, the Court Should Preclude the Government and Accuser-3 from Representing that Accuser-3 Was a "Minor," or that She Was "Sexually Abused" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00074480 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merre

was a "minor" at the time of the alleged sex acts, (2) to preclude the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey Epstein, and (3) for an appropriate limiting instruction concerning Accuser-3's testimony. PRELIMINARY STATEMENT The government and the defense agree on at

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

ger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Ghislaine Maxwell EFTA00074479 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMEN

ion at Trial and Facilitates the Presentation of False Testimony None of the identified purported coconspirators are available to testify at trial. Jeffrey Epstein is dead, and neither have been granted immunity for their trial testimony. Accordingly, Ms. Maxwell cannot cross-examine any identified coconspira

advance of trial...." Dkt. 335 at 3. The government seized multiple electronic devices, including computers and servers from alleged co-conspirator Epstein. These devices contain hundreds of thousands of statements spanning decades. The emails on the devices are to and from many other individuals. Many

MPLY WITH THIS COURT'S SEPTEMBER 3, 2021, ORDER Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Ghislaine Maxwell EFTA00090451 TABLE OF CONTENTS Table of Contents ii Table of Authorities iii REL

Maxwell violated and conspired to violate the federal sex trafficking statute, 18 U.S.C. § 1591. Count Five alleges that Ms. Maxwell conspired with Epstein and others to recruit "a person" knowing that the person "had not attained the age of 18 years and would be caused to engage in a commercial sex act

by any means" individuals who were under the age of 18, including Accuser-4, "who were then caused to engage in at least one commercial sex act with Jeffrey Epstein." (Id. 127). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred "[f]rom at least in or about 2001,

A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Chislaine Maxwell EFTA00105542 Defendant Ghislaine Maxwell requests that the Court enter an Order author