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) GIIISLAINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN & FOR

eys for Ghislain Maxwell 58 EFTA00155965 Certificate of Service I hereby certify that on January 19, 2022, I electronically filed the foregoing Ohislaine Maxwell's Motion for a New Trial, with the Court and counsel for the government: U.S. Attorney's Office SDNY One Saint Andrew's Plaza New York. NY 10007 s

w.dailymail.co.uk/news/article-10379445/Ghislaine-Maxwells- lawyers-fought-ask-jurors-detailed-questions-sex

e Law 21 I. Juror No. 50's misconduct deprived Ms. Maxwell of her constitutional right to a fair trial by a

nally threatened." Id. at 48. Although the Court in Torres declined to define the "precise scope of a trial judge's discretion to infer bias," Judge Calabresi further explained: It is enough for the present to note that cases in which a juror has engaged in activities that closely approximate those of th

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

e Indictment as untimely. Moreover, Maxwell has identified no case in the intervening seventeen years in which the Supreme Court has embraced Judge Calabresi's view. See Nader, 425 F. Supp. 3d at 631 (finding arguments relating to Judge Calabresi's footnote unpersuasive, and concluding that Section 3283 a

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

he Indictment as untimely. Moreover, Maxwell has identified no casein the intervening seventeen years in which the Supreme Court has embraced Judge Calabresi's view. See Nader,425 F. Supp. 3d at 631 (finding arguments relating to Judge Calabresi's footnote unpersuasive, and concluding that Section 3283 ap

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

e Indictment as untimely. Moreover, Maxwell has identified no case in the intervening seventeen years in which the Supreme Court has embraced Judge Calabresi's view. See Nader, 425 F. Supp. 3d at 631 (finding arguments relating to Judge Calabresi's footnote unpersuasive, and concluding that Section 3283 a

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

e Indictment as untimely. Moreover, Maxwell has identified no case in the intervening seventeen years in which the Supreme Court has embraced Judge Calabresi's view. See Nader, 425 F. Supp. 3d at 631 (finding arguments relating to Judge Calabresi's footnote unpersuasive, and concluding that Section 3283 a

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

criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 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 nefarious reasons for d

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

e Indictment as untimely. Moreover, Maxwell has identified no case in the intervening seventeen years in which the Supreme Court has embraced Judge Calabresi's view. See Nader, 425 F. Supp. 3d at 631 (finding arguments relating to Judge Calabresi's footnote unpersuasive, and concluding that § 3283 applies

Pledges Rigorous Investigation. • FBI Joins Army Probe Of Killing Of Fort Bragg Paratrooper. • Epstein Accuser Alleged In Unsealed Deposition That Maxwell Was His Partner In Abuse. • Idaho Prosecutor Subpoenas FBI Agents In Daybell Probe. • Man Shot By FBI In Arkansas Will Remain Jailed. • Kentucky A

ed financier Jeffrey Epstein of years-long abuse that began when she was a teenager alleged in a newly unsealed deposition that his former partner, Ghislaine Maxwell, was both his chief accomplice and a participant in the sexual abuse." Maxwell, "who was arrested earlier this month and charged with trafficking mi

wly unsealed deposition that his former partner, Ghislaine Maxwell, was both his chief accomplice and a part

n-coronavirus.html> (7/30, 18.61M), "I have voted Republican in every presidential election since 1980, including voting for Donald Trump in 2016." Calabresi adds that he also publicly criticized Robert Mueller's investigation of Trump and opposed the President's impeachment. He continues, "But I am frank

Pledges Rigorous Investigation. • FBI Joins Army Probe Of Killing Of Fort Bragg Paratrooper. • Epstein Accuser Alleged In Unsealed Deposition That Maxwell Was His Partner In Abuse. • Idaho Prosecutor Subpoenas FBI Agents In Daybell Probe. • Man Shot By FBI In Arkansas Will Remain Jailed. • Kentucky A

sed financier Jeffrey Epstein of years-long abuse that began when she was a teenager alleged in a newly unsealed deposition that his former partner, Ghislaine Maxwell, was both his chief accomplice and a participant in the sexual abuse." Maxwell, "who was arrested earlier this month and charged with trafficking m

ewly unsealed deposition that his former partner, Ghislaine Maxwell, was both his chief accomplice and a par

Times (7/30, 18.61M), "I have voted Republican in every presidential EFTA00150189 election since 1980, including voting for Donald Trump in 2016." Calabresi adds that he also publicly criticized Robert Mueller's investigation of Trump and opposed the President's impeachment. He continues, "But I am fran

Pledges Rigorous Investigation. • FBI Joins Army Probe Of Killing Of Fort Bragg Paratrooper. • Epstein Accuser Alleged In Unsealed Deposition That Maxwell Was His Partner In Abuse. • Idaho Prosecutor Subpoenas FBI Agents In Daybell Probe. • Man Shot By FBI In Arkansas Will Remain Jailed. • Kentucky A

sed financier Jeffrey Epstein of years-long abuse that began when she was a teenager alleged in a newly unsealed deposition that his former partner, Ghislaine Maxwell, was both his chief accomplice and a participant in the sexual abuse." Maxwell, "who was arrested earlier this month and charged with trafficking m

ewly unsealed deposition that his former partner, Ghislaine Maxwell, was both his chief accomplice and a par

n the New York Times (7/30, 18.61M), "I have voted Republican in every presidential election since 1980, including voting for Donald Trump in 2016." Calabresi adds that he also publicly criticized Robert Mueller's investigation of Trump and opposed the President's impeachment. He continues, "But I am fran