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-cr-00330-AJN Document 342 Filed 10/13/21 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. • • • • x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JURO
20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIR
trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t
Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of
man Andrew Wiener, not to mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and
icle http://gawker.com/news/consPiracy-theories/the-truth-about-jeffrey-epstein-and-vanity-fair... 9/26/2007 EFTA01682285 Prince Andrew's friend. Ghislaine Maxwell, some underage girls and a very disturbing sto... Page 1 of 16 JACOB'S CREEK. e_ Discover more. Oa tI u 24 HOURS A DAY - Evening Morning 11°C
ansion involved nothing more than running errands for printer cartridges and science magazines, but her second trip brought a surprising question. "Ghislaine asked me, 'Do you want to make $100 rubbing feet? I said I would love to do that" Impressed with Jeffrey's knowledge of psychology — one of her coll
EFTA01682285 Prince Andrew's friend. Ghislaine Maxwell, some underage girls and a very disturbing sto...
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iate with a Hoffenberg, it turned out that along perfectly well. elf and the way ner was. — would | a Ponzi king like Steven would get! 4 oe “) Ghislaine Maxwell obert Meister v q Epstein, the bc 4 social ladder. T heiress from the Unite q of the world’s most gla: 7 Maxwell was the ' _ the most famous— - | Robert Ma
Page: HOUSE_OVERSIGHT_021972 →e, Wendy, had her suspicions Epstein, the hay ftom Coney istand, on bd ) 1s way up the e presented himself and the way social ladder. There was also Ghislaine Maxwell Ith ell, a wealthy enn heiress from the United Kingdom who'd retained her ties to som e ing Epstein the virus. ; weren't the point. Wexner was- stand
Page: HOUSE_OVERSIGHT_021973 →s and brothers, relatives, and neighbors. 1 don’t know what went through their minds as they realized that they’d been tricked into a gas chamber.” Maxwells own death was followed by an international scan- dal. It turned out that he’d stolen hundreds of millions of pounds from his companies’ pension fund
Page: HOUSE_OVERSIGHT_021974 →panies’ pension funds and used them to prop Up his e tried for conspiracy to commit empire. Two of his sons wet fraud and ultimately exonerated. But Ghislaine, who had grown d counted the Duke of York, up in luxurious surroundings an Prince Andrew, among her intimates, could not escape the dark shadow her
Page: HOUSE_OVERSIGHT_021974 →UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av
Page: EFTA00011096 →New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011096 --- PAGE BREAK --- INTRO
Page: EFTA00011096 →trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t
Page: EFTA00011097 →Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of
Page: EFTA00011097 →man Andrew Wiener, not to mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and
Page: EFTA00011103 →New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011115 --- PAGE BREAK --- Case
Page: EFTA00011115 →UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av
Page: EFTA00011115 →Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of
Page: EFTA00011116 →trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t
Page: EFTA00011116 →man Andrew Wiener, not to mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and
Page: EFTA00011122 →in a blue] pologized for his crimes and. asked i flew to Sandringham, the queen’s estate in Norfolk, England, for | a party Prince Andrew threw for Ghislaine’s thirty-ninth birthday. The prince had also visited Epstein on several occasions, in | Palm Beach as well as in New York. And if allegations Virgin
Page: HOUSE_OVERSIGHT_022118 →- TTERSON Firtuyy Ricw A m a yacht surrounded by topless which I don’t think is right,” she said a few days later when inter- viewed by Today host Matt Lauer. “It’s a defamation of character, suit, Epstein had forced her into and as a great father and a humongously good man and all the Jeff's. work he does
Page: HOUSE_OVERSIGHT_022120 →n. Seckel had also been trying to sell papers belonging to Isa- : The further I can keep bel’s father. 3 ’ better,” said Ballet Palm Beac Isabel is Ghislaine Maxwell's sister and the daughter of Rob- : q But in 2012, Bpsicin halil 4 Jeff's Once again, three Nobe Stephen Hawking was also th HWwenty-one physicists—
Page: HOUSE_OVERSIGHT_022131 →Entities connected to both Ghislaine Maxwell and Matt Lauer

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Marc Rich
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONDoug Band
PERSON
Les Wexner
PERSON
Denver
LOCATIONJane Doe
PERSON
Lesley Groff
PERSON