Epstein Secrets

ELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Maxwell's Motion for Pretrial Release David Oscar Markus MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One Miami, Florida 33128 EFTA00093045 Case 21-

3068296, Page2 of 31 No. 21-770 & 21-58 In the Mufti) Sates' Court of 5Appeats for the £ieconb (Circuit UNITED STATES OF AMERICA. Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Max

nimous that such conditions produce mental deterioration, which prevents her from effective participation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute, she must review over 2,500,000 prosecution pages on a gutted computer, which does not have the abil

rticipation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute,

umstances under which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed security guards. Bozeman!, nevertheless, held that a defendant may be released on such a condition if the defendant "is deemed to be a flight risk primarily because of his w

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Eve

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffr

ruling on the admissibility for two weeks. 15 Ms. Maxwell reiterates her re, uest to defer III. THIS COUR

2015) 7 United States v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 26 United States v. Bocio, 103 F. Supp. 2d 531 (N.D.N.Y. 2000) 2 United States v. Bozeman, No. 3:11-CR-129, 2012 WL 1071207 (E.D. Tenn. Mar. 29, 2012) 3 United States v. Brewington, No. 15-CR-00073-PAB, 2018 WL 1411274 (D. Colo. Mar. 21,

"LR") • Richard Kahn (S) • Darren Indyke (S) • Erica Kellerhals (S) • Many Beller (S) BENEFICIARY ("B") OR LIMITED POA ("LPOA") • • hislaine Maxwell (B) • • Richard Kahn (B) • Darren Indyke (B) • Shuliak ) • • • • Darren Indyke PLLC Checking • Darren Indyke (UBO) • Darren Indyke (S)

s in connection with its sex trafficking probe into Epstein in November 2006.16 December 27, 2006 Epstein settles the Butterfly Trust, naming and "Gishlaine N. Maxwell" as beneficiaries. Richard Kahn and Darren Ind ke are named trustees. March 24, 2011 Darren Indyke and Richard Kahn add as a beneficiary. March

ALE BUTTERFLY TRUST BENEFICIARIES" Nvin I) O B CITIZENSHIP ADDRESS PROFESSION DATE DATE ADDED RENIOYED PI BLB CONNECT lov, TO EPs i r I\ Ghislaine Maxwell N/A IS N/A cio FIBRK Associates 575 Lexington Ave. 4th Floor New Yo NY N/A 12/27/2006 12/9/2014 Yes N/A N/A N/A 12/27/2006 12

given immunity in connection with Epstein's Non-Prosecution Agreement. 4) Through his attorney, Darren Ind l leffry Epstein appears to have paid for Ghislaine Maxwell's legal expenses in connection with a 2015 lawsuit filed against Maxwell by an Epstein accuser. See v e . Maxwell, 1:15-cv-07433 (S.D.N.Y. 2015). Ma

840 TBD 3 $30,000 Bank of America Jeffre E stein 1 $32,600 First Bank of Puerto Rico Jeffrey Epstein 2 $43,634 First Interstate Bank of Bozeman LS LLC 26 $68,009 Societe Generale Jeffrey Epstein (Custody) 41 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) EFTA01681904 WV Ma go /7

which has congressional oversight of the FBI, are pushing to subpoena the bureau for all records pertaining to sex traffickers Jeffrey Epstein and Ghislaine Maxwell a day after a federal court in New York finished unsealing more than 200 files regarding the pair. The article noted that FBI agents raided properti

to sex traffickers Jeffrey Epstein and Ghislaine Maxwell a day after a federal court in New York finished

ertaining to sex traffickers Jeffrey Epstein and Ghislaine Maxwell a day after a federal court in New York f

laint submitted by the FBI. The article noted that Keith Fagiana started an argument with a fight attendant during a flight on Jan. 3 from Dallas to Bozeman, Mont. last week, "yelling expletives" after he was asked to stop kicking the seat in front of him. Fagiana then punched the flight attendant multip

aled documents are part of a 2015 civil defamation suit brought by , an American woman who claimed Epstein sexually abused her as a minor and that Ghislaine Maxwell, Epstein's former girlfriend, aided in the abuse. The unsealing this week stems from a December 18 court order from the judge overseeing the lawsuit

sexually abused her as a minor and that Ghislaine Maxwell, Epstein's former girlfriend, aided in the abuse.

Epstein sexually abused her as a minor and that Ghislaine Maxwell, Epstein's former girlfriend, aided in th

rance Monday in Amarillo, Texas. The article noted that Fagiana was a passenger on an American Airlines flight Wednesday from Fort Worth, Texas, to Bozeman, Montana. Pilots landed the plane in Amarillo instead. The article stated that the FBI agent's account was in unsealed court documents Friday. A fli