Epstein Secrets

sed meant and she stated no. then said that she thought Epstein was on steroids because e was a "really built guy and his wee wee was very tiny." Gonzalez would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, p acing it on the floor as

sed meant and she stated no. then said that she thought Epstein was on steroids because e was a "really built guy and his wee wee was very tiny." Gonzalez would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, p acing it on the floor as

sed meant and she stated no. then said that she thought Epstein was on steroids because e was a "really built guy and his wee wee was very tiny." Gonzalez would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, p acing it on the floor as

sed meant and she stated no. then said that she thought Epstein was on steroids because e was a "really built guy and his wee wee was very tiny." Gonzalez would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, p acing it on the floor as

stein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the followin affiliated names: w/m dob Maxwell, uk , coy A computer history. On 03/23/2005, I spoke with cell phone wk . I requested that she not discuss e incident with anyone inc u ing he

stein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the followin affiliated names: w/m dob Maxwell, uk , coy A computer history. On 03/23/2005, I spoke with cell phone wk . I requested that she not discuss e incident with anyone inc u ing he

stein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the followin affiliated names: w/m dob Maxwell, uk , coy A computer history. On 03/23/2005, I spoke with cell phone wk . I requested that she not discuss e incident with anyone inc u ing he

stein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the followin affiliated names: w/m dob Maxwell, uk , coy A computer history. On 03/23/2005, I spoke with cell phone wk . I requested that she not discuss e incident with anyone inc u ing he

stein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the followin affiliated names: w/m dob Maxwell, uk , coy A computer history. On 03/23/2005, I spoke with cell phone wk . I requested that she not discuss e incident with anyone inc u ing he

lane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly.

lane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly.

lane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly.

lane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly.

lane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION TO DISMISS THE SUPERSEDING INDICTMENT FOR BREACH OF

of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00028880 --- PAGE BREAK --- TABLE OF CONTENTS Page I. The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce It. 2 II. The Co-Conspirator Immunity Provision is Not Limited to the SDFL. 7 III. The Co-Conspirator Immunit

TABLE OF CONTENTS Page I. The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce It. 2 II. Th

West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 3, 4, 6 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 12 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 8 United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 12 United States v. Mariamma Viju (01), No. 3:15-CR-0

20-cr-00330-AJN Document 207 Filed 04/16/21 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. Maxwell filed twelve pretrial motions seeking to dismiss portions of the

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

e of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States

20-cr-00330-AJN Document 207 Filed 04/16/21 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. Maxwell filed twelve pretrial motions seeking to dismiss portions of the

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

e of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States

20-cr-00330-AJN Document 317 Filed 08/13/21 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY PILED DOC N: DATE FILED:8/13/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Jud

cking count and sex trafficking conspiracy count. The Court did not address the new charges in the April 16, 2021 Opinion & Order. On May 25, 2021, Maxwell filed another round of pretrial motions seeking to dismiss the S2 indictment in whole or in part and to compel discovery. Dkt. No. 292, 293. For app

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

1985) (per curiam). The Second Circuit's opinion in Annabi is clear, and that court has followed it steadfastly since. See, e.g., United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004); United States v. Brown, No. 99-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States v. Sal

20-cr-00330-AJN Document 208 Filed 04/16/21 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 4/16/21 20-cr-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Jud

acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. Maxwell filed twelve pretrial motions seeking to dismiss portions of the

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

e of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States