Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) OMNIBUS MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO

RN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) OMNIBUS MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Av

lorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00103758 TABLE OF CONTENTS Page PRELIMINARY STATEMENT SUMMARY OF NEW ALLEGATIONS IN THE S2 INDICTMENT 4 ARGUMENT 5 I. The NPA Bars Ms.

E S2 INDICTMENT 4 ARGUMENT 5 I. The NPA Bars Ms. Maxwell's Prosecution on Counts One, Three, Five, and Six

ell with sex trafficking offenses under 18 U.S.C. § 1591 (Counts Five and Six) and has dramatically expanded the timeframe of the Mann Act 2 Ex. A (Dep't of Justice, Office of Professional Responsibility, Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-

d of dozens of letters from Mr. Epstein's friends in celebration of his 50th birthday in 2003.8 The letters were collected by Mr. Epstein's partner Ghislaine Maxwell and included one from President Trump that allegedly "contains several lines of typewritten text framed by the outline of a naked woman, which appe

ere collected by Mr. Epstein's partner Ghislaine Maxwell and included one from President Trump that alleg

letters were collected by Mr. Epstein's partner Ghislaine Maxwell and included one from President Trump th

will get everything"; that you were "assured" there was more; and that the country would eventually see "the full Epstein files."6 1 Memorandum from Dep't of Justice and Fed. Bureau of Investigation on Review of Investigative Holdings Relating to Jeffrey Epstein (Jul. 7, 2025), available at https://www.justice.go

d of dozens of letters from Mr. Epstein's friends in celebration of his 50th birthday in 2003.8 The letters were collected by Mr. Epstein's partner Ghislaine Maxwell and included one from President Trump that allegedly "contains several lines of typewritten text framed by the outline of a naked woman, which appe

ere collected by Mr. Epstein's partner Ghislaine Maxwell and included one from President Trump that alleg

letters were collected by Mr. Epstein's partner Ghislaine Maxwell and included one from President Trump th

will get everything"; that you were "assured" there was more; and that the country would eventually see "the full Epstein files.' 1 Memorandum from Dep't of Justice and Fed. Bureau of Investigation on Review of Investigative Holdings Relating to Jeffrey Epstein (Jul. 7, 2025), available at https://www.justice.go