Epstein Secrets

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00100024 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafaiia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity, or other influential associates." OPR Report at 168.11 In

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

le friend who was a well- known socialite, but, according to Villafafia, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaiia believed that the only "co-conspirators" of Epstein who would benefit from the provision were the four female assistants identified by name. 20

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

le friend who was a well- known socialite, but, according to Villafafia, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaiia believed that the only "co-conspirators" of Epstein who would benefit from the provision were the four female assistants identified by name. 20

aw 52 2. Discussion 54 IV. The Court Should Deny the Defendant's Motions to Suppress 59 A. Factual Background 61 1. The Civil Lawsuit against Maxwell 61 2. February 2016 Meeting 62 3. The April and July 2016 Depositions of Maxwell 64 4. The USAO-SDNY Commences the Instant Investigation in 201

v. Maxwell. 57 EFTA00103082 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

complying with certain parts of the NPA. OPR Report at 95. According to the report: At the same time, at [USAO-SDFL supervisor] Lourie's request, Villafaiia sent the NPA and its addendum to Lourie and Oosterbaan. Oosterbaan responded to Lourie that he was "not thrilled" about the NPA; described Epstein'

f Epstein; b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's • • witness, subject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other info

ubject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, Da

witness, subject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Vi

meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafaiia and I discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafaiia asked me to send any information that I want

E: l. Any and.all notes, letters, cards, gifts, payments, photographs, or other items that you have received from Jeffrey Epstein, MM Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 2. Any. and all photographs, whether printed or digital, of Jeffrey Epstein, i Se Lesley

nt: a yourself: b Jeffrey Epstein; c d. €. g Lesley Groff; h Ghislaine Maxwell; i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine Maxwell; ‘ j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine Maxwell; k, any person(s) who communicated with you to arrange

rself: b Jeffrey Epstein; c d. €. g Lesley Groff; h Ghislaine Maxwell; i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine Maxwell; ‘ j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine Maxwell; k, any person(s) who communicated with you to arrange appointm

by an officer acting on behalf of the court. June 18, 2007 (BY) DEPUTY CLERK Name, Address and Phone Number of Assistant U.S, Attomey Aun Marie C, Villafaiia, Assistant U.S. Anomey . 500 So. Australian Avenve, Suite 400 West Palm Beach, FL 33401-6235 Tel: (561) 820-8711 x3047. Fax; (561) 802-1787 To b

— ■ Page 151 i i 1 with Mr. Indyke? 2 A No. 3 Q There appear to be a number of 4 corporations. El Zorro Ranch Corporation, New York 5 Strategy Group, Ghislaine, G-HT-S-L-ArEN-E, 6 Corporation, J. Epstein and Company and the 7 Financial Strategy Group. Do you see those? 8 A Ido. 9 Q‘ Do you recall anything, s

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nd Belohlavek told OPR that the Chief of the Police Department would not regularly play a role in the state victim notification process. 427 Although Villafaiia’s notes indicate that she researched Florida Statutes §§ 960.001 and 921.143 when she drafted unsent letters to victims in November and December 2007