Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSED

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Mark S. Cohen Christian R. Everdell COHEN &

31-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00103709 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 SUMMARY OF ALLEGATIONS 2 ARGUMENT 3 I. The 2003 Amendment Does Not Apply Retr

. Step Two: Application of the 2003 Amendment to Ms. Maxwell's alleged offenses would have impermissible effe

necessarily entail the sexual or physical abuse or kidnapping of a child. 15 CONCLUSION 18 EFTA00103710 TABLE OF AUTHORITIES Page(s) Cases Bowen v .Georgetown Univ. Hosp., 488 U.S. 204 (1988) 5 Bridges v. United States, 346 U.S. 209 (1953) 12, 13, 15, 17 Bureau of Alcohol, Tobacco & Fir

3-1 Virginia Giuffre (then known as Virginia Roberts), alleged in a sworn affidavit that at age 17, she had been sexually trafficked by Epstein and Ghislaine Maxwell for their own,nse and for use by several others, including Prince AndrewtWl and retired Harvard Law professor Alan Dershowitz$)1-1i4~1 Giu

a Giuffre (then known as Virginia Roberts), alleged in a sworn affidavit that at age 17, she had been sexually trafficked by Epstein and Ghislaine Maxwell for their own,nse and for use by several others, including Prince AndrewtWl and retired Harvard Law professor Alan Dershowitz$)1-1i4~1 Giuffre also

02.04.2053 MN: Phone: 08 8632 1244 Fax: 08 8633 0579 blightsewestnetcom.au www.professionals.com.au TAX INVOICE ReinT pelkr) -to (271 it 'goa) Bowen FOR 11 MEAOOv4 CRESeaT Re LOC -A-TE (a3 i 't lac`a) To: David Johnson & Property Owners: Tracey Heimers Re Property at Inv No Due Date Account

Ceiling This Summer. • Labor Department Blocks Rule Classifying Gig Workers As Contractors. • Apple Investing $410M In Texas Manufacturing Firm. • GM Reports $3.3B Q1 Net Profit. • Ford Says Summer Deliver Of Bronco "On Track" Despite Supply Chain Challenges. • Dow Hits Record As Major Indexes Po

uments filed in the case "could undermine that argument in U of L's infractions case with the NCAA's Independent Accountability Resolution Process." Bowen "was prevented from playing college basketball amid allegations arising from an FBI probe that his signing was induced by a promise of $100,000, in

Ceiling This Summer. • Labor Department Blocks Rule Classifying Gig Workers As Contractors. • Apple Investing $410M In Texas Manufacturing Firm. • GM Reports $3.3B Q1 Net Profit. • Ford Says Summer Deliver Of Bronco "On Track" Despite Supply Chain Challenges. • Dow Hits Record As Major Indexes Po

uments filed in the case "could undermine that argument in U of L's infractions case with the NCAA's Independent Accountability Resolution Process." Bowen "was prevented from playing college basketball amid allegations arising from an FBI probe that his signing was induced by a promise of $100,000, in

Ceiling This Summer. • Labor Department Blocks Rule Classifying Gig Workers As Contractors. • Apple Investing $410M In Texas Manufacturing Firm. • GM Reports $3.3B Q1 Net Profit. • Ford Says Summer Deliver Of Bronco "On Track" Despite Supply Chain Challenges. • Dow Hits Record As Major Indexes Po

ments filed in the case "could undermine that argument in U of L's infractions case with the NCAA's Independent Accountability Resolution Process." Bowen "was prevented from playing college basketball amid allegations arising from an FBI probe that his signing was induced by a promise of $100,000, in

MADOEN LTD SHOO MRGN 9.200 14.0700 129.444 MAXWELL SION CO INC-CL A INOIS &IRON 12.200 14.1000

83.939.84 12&itt61 1f/L$/o1 SOLD VANE 4,000 13.71440 123.410.48 12124/01 12/19/01 SOLD WISH -1.200 1126000 12616.54 12,24tol 12/19101 Bowen 12C 2.700 37.56460 101,601,42 02T 1619 EFTA01322956 t6i39ZZOO-V.L43 C) 0 m C in r _ ZOZPS£00 IN9 ANGS BEAR STEARNS Ofra SERVICING

ey. . A d I called and got his voicemail. I asked that he'll can back to • • 5:01PM 5:08PM From lansto Corp. I'm a realtor and I've dealt w/ Ghislaine at one point. If you can't stay at 457, what do you want? I have a unique duplex penthouse on 52nd/Madison, huge terrace, fire lace. 8,500 sqft or

ey. . A d I called and got his voicemail. I asked that he'll can back to • • 5:01PM 5:08PM From lansto Corp. I'm a realtor and I've dealt w/ Ghislaine at one point. If you can't stay at 457, what do you want? I have a unique duplex penthouse on 52nd/Madison, huge terrace, fire lace. 8,500 sqft or

ey. . A d I called and got his voicemail. I asked that he'll can back to • • 5:01PM 5:08PM From lansto Corp. I'm a realtor and I've dealt w/ Ghislaine at one point. If you can't stay at 457, what do you want? I have a unique duplex penthouse on 52nd/Madison, huge terrace, fire lace. 8,500 sqft or

ey. . A d I called and got his voicemail. I asked that he'll can back to • • 5:01PM 5:08PM From lansto Corp. I'm a realtor and I've dealt w/ Ghislaine at one point. If you can't stay at 457, what do you want? I have a unique duplex penthouse on 52nd/Madison, huge terrace, fire lace. 8,500 sqft or

ey. . A d I called and got his voicemail. I asked that he'll can back to • • 5:01PM 5:08PM From lansto Corp. I'm a realtor and I've dealt w/ Ghislaine at one point. If you can't stay at 457, what do you want? I have a unique duplex penthouse on 52nd/Madison, huge terrace, fire lace. 8,500 sqft or

Brtn — bl. 127 r at; 3 Fair,s 4 Micienion 5 4~40 w 1 -0. Pawl Mere (UP) (F•10 (MORO g=c„....... ResarGO Prone c , RCM cs,..., (20) Bowen note ( I TOT 4AC roar Tom 101* it/O beg r eaCCtaa at Conan NNi9I Coat t :ziOltinnant painm An3 /CI 0 000(411:• Pats; ToPl. WO Pro /a wen wa

Brtn — bl. 127 r at; 3 Fair,s 4 Micienion 5 4~40 w 1 -0. Pawl Mere (UP) (F•10 (MORO g=c„....... ResarGO Prone c , RCM cs,..., (20) Bowen note ( I TOT 4AC roar Tom 101* it/O beg r eaCCtaa at Conan NNi9I Coat t :ziOltinnant painm An3 /CI 0 000(411:• Pats; ToPl. WO Pro /a wen wa

Brtn — bl. 127 r at; 3 Fair,s 4 Micienion 5 4~40 w 1 -0. Pawl Mere (UP) (F•10 (MORO g=c„....... ResarGO Prone c , RCM cs,..., (20) Bowen note ( I TOT 4AC roar Tom 101* it/O beg r eaCCtaa at Conan NNi9I Coat t :ziOltinnant painm An3 /CI 0 000(411:• Pats; ToPl. WO Pro /a wen wa

Brtn — bl. 127 r at; 3 Fair,s 4 Micienion 5 4~40 w 1 -0. Pawl Mere (UP) (F•10 (MORO g=c„....... ResarGO Prone c , RCM cs,..., (20) Bowen note ( I TOT 4AC roar Tom 101* it/O beg r eaCCtaa at Conan NNi9I Coat t :ziOltinnant painm An3 /CI 0 000(411:• Pats; ToPl. WO Pro /a wen wa

Brtn — bl. 127 r at; 3 Fair,s 4 Micienion 5 4~40 w 1 -0. Pawl Mere (UP) (F•10 (MORO g=c„....... ResarGO Prone c , RCM cs,..., (20) Bowen note ( I TOT 4AC roar Tom 101* it/O beg r eaCCtaa at Conan NNi9I Coat t :ziOltinnant painm An3 /CI 0 000(411:• Pats; ToPl. WO Pro /a wen wa