Epstein Secrets

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

eport notes that the USAO-SDFL periodically consulted with the Chief of the Department of Justice Child Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea discussions, and that the CEOS Chief attended a meeting with defense counsel, during which defense counsel made

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

eport notes that the USAO-SDFL periodically consulted with the Chief of the Department of Justice Child Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea discussions, and that the CEOS Chief attended a meeting with defense counsel, during which defense counsel made

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

eport notes that the USAO-SDFL periodically consulted with the Chief of the Department of Justice Child Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea discussions, and that the CEOS Chief attended a meeting with defense counsel, during which defense counsel made

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

eport notes that the USAO-SDFL periodically consulted with the Chief of the Department of Justice Child Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea discussions, and that the CEOS Chief attended a meeting with defense counsel, during which defense counsel made

iberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation Page 12 of 18 SDNY GM 02742871 EFTA_00229520 EFTA01325064 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of 18 Bates Range Descript

s plan to demand a meeting with CEOS. Work Product Deliberative Process Investigative Privilege P-014048 8/7/2007 email from Marie Villafatia to Andrew Oosterbaan regarding Epstein meeting Work Product Deliberative Process Investigative Privilege P-014049 thru P-014050 8/7/2007 email chain from Jeff Slo