Epstein Secrets

S 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 HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca L

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 HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A.

-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00091875 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii INTRODUCTION 1 OVERVIEW OF THE ALLEGATIONS 2 A. Counts One throu

use Their Inclusion Will Substantially Prejudice Ms. Maxwell at Trial 9 CONCLUSION 13 Certificate of Servi

Sampson, 385 F.3d 183 (2d Cir. 2004) Turoff, 853 F.2d 1037 (2d Cir.1988) Walker, 142 F.3d 103 (2d Cir. 1998) Werner, 620 F.2d 922 (2d Cir. 1980) Winchester, 407 F. Supp. 261 (D. Del. 1975) 5, 6, 11 4 4 5 3, 5, 10 5 3, 4, 10 5 ii EFTA00091877 Statutes 18 U.S.C. § 1623 3 18 U.S.C.

r women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits. Ghlslaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years Epstein's live-in partner, also recruited young girls.

odeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and "deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the

ed newspaper baron Robert Maxwell, that gives most concern. He was first seen with the pair on holiday in Thailand, and was pictured cavorting with Ghislaine at a Halloween fetishthemed party in Manhattan. The photograph that appeared last weekend shows the prince strolling through Central Park with 58-

. And we all know how morally corrupt the rest of the Maxwell family were/are. Prince Andrew is not the epitom

EY AT LAY January 6, 2010 I I, Record/InfonnatkM Dissemination Section —Federaltureau-Othwestigarion DepartuOnt of ilustice 170 Marcel Drive ! Winchester, V4 22602-4843 • I Pietas. ADDRESSES' REQUEST UNDER FREEEDOM OF INFORMATION ACT AND PRIVACY ACT . ' " " • • I • • • .. i I . ' •To3iVhei

lenge should be dismissed." Lord Justice Bean and Mr Justice Lewis "are expected to deliver a ruling in the near future." CRIMINAL INVESTIGATIONS Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spouse To FBI. The London (UK) Evening Standard (7/15, Somerville, 856K) reports, "Ghislaine Maxwell is secret

to charges she had trafficked at least three underage girls for billionaire paedophile Jeffrey Epstein." Assistant US Attorney Alison Moe "revealed Maxwell had a spouse while questioning who would co-sign her bond at a bail hearing in New York. She told the courthouse late on Tuesday: 'In addition to fa

dges' Inquest Ruling. CRIMINAL INVESTIGATIONS • Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spou

employees and his payroll expenses and falsely certified that the United States was the primary residence for his employees, prosecutors said." The Winchester (MA) Star (7/15, 57K) and WCVB-TV Boston (7/15, 402K) also report. Investment Fund Accused Of Running Ponzi Scheme Got Millions In PPP Money. Behin

s secured him favorable treatment by the DO). Given that a civil defamation trial between one of Epstein's victims and his alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of renewed interest to the public and therefore is worthy of expedited processing. filefikird-sfile-fdpsffiDPS_Repos

ictims and his alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of renewed interes

pstein's victims and his alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of renewed

equested information is likely to advance that interest. Fax your request to the Work Process Unit at (540) 868-4997, or mail to 170 Marcel Drive, Winchester, VA 22602. If we do not receive a response from you within 30 days from the date of this letter, your request will be dosed. You must include the FO

pstein'S victims and his alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of renewed

s secured him favorable treatment by the DOJ. Given that a civil defamation trial between one of Epstein'S victims and his alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of renewed interest to the public and therefore is worthy of expedited processing. file://hqrd-sfile-fdps/FDPS_Repos

ictims and his alleged co-conspirator, Ghislaine Maxwell, has just begun, the topic is of renewed interes

equested information is likely to advance that interest. Fax your request to the Work Process Unit at (540) 868-4997, or mail to 170 Marcel Drive, Winchester, VA 22602. If we do not receive a response from you within 30 days from the date of this letter, your request will be closed. You must include the F

Records Politico (11/21, Cheney) reported that the justice Department renewed its effort to unseal grand Jury records from the Jeffrey Epstein and Ghislaine Maxwell prosecutions, arguing that President 'frump's newly signed Epstein Files Transparency Act now requires public release of nearly all investigative fl

y records from the Jeffrey Epstein and Ghislaine Maxwell prosecutions, arguing that President 'frump's new

grand Jury records from the Jeffrey Epstein and Ghislaine Maxwell prosecutions, arguing that President 'fru

BI records by mid-December. Bloomberg (11/21, Leopold) added that the FBI deployed uniformed police officers to guard its Central Records Complex in Winchester, Virginia, after online commenters—reacting to unsubstantiated claims by Mark Epstein that Director Patel was leading a "coverup"—suggested protesti

Records Politico (11/21, Cheney) reported that the justice Department renewed its effort to unseal grand Jury records from the Jeffrey Epstein and Ghislaine Maxwell prosecutions, arguing that President 'frump's newly signed Epstein Files Transparency Act now requires public release of nearly all investigative fl

y records from the Jeffrey Epstein and Ghislaine Maxwell prosecutions, arguing that President 'frump's new

grand Jury records from the Jeffrey Epstein and Ghislaine Maxwell prosecutions, arguing that President 'fru

BI records by mid-December. Bloomberg (11/21, Leopold) added that the FBI deployed uniformed police officers to guard its Central Records Complex in Winchester, Virginia, after online commenters—reacting to unsubstantiated claims by Mark Epstein that Director Patel was leading a "coverup"—suggested protesti

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very) Evidence items have been shipped to: DocLab - Telephone Application Audit - Evidence Room Federal Bureau of Investigation 170 Marcel Drive Winchester, Virginia 22602 Non-Evidence items have been shipped to: DocLab - Telephone Application Audit Processing Team Federal Bureau of Investigation 170

ple appear to have creativity in abundance and the things they create are truly wonderful. I’m thinking here of Picasso, Einstein, Mozart, Edison, or Maxwell, but a precise definition of creative thinking is hard to pin down. Here are some generally accepted categories: Divergent Thinking The first sort

led annual data on every facet of their business. For an academic, this is gold dust. IBM invented the hard disk drive in their research center near Winchester, England. The first prototypes were, consequently, called Winchester Drives. When Christiansen examined the industry, he found something very strange