Epstein Secrets

no utility, to your case. Our client is willing to provide you with a witness statement, addressing any issues that he may be able to,in relation to Ghislaine Maxwell and Jeffrey Epstein, his association with them and his knowledge of them such as may be relevant to the prosecution of Ghislaine Maxwell. In additi

ry written responses be treated with the utmost confidentiality, not used for any purpose other than in relation to the criminal proceedings against Ms Maxwell, and not be shared with any parties EFTA00104838 outside of your department, including complainants and their representatives in your investigatio

s that he may be able to,in relation to Ghislaine Maxwell and Jeffrey Epstein, his association with them a

any issues that he may be able to,in relation to Ghislaine Maxwell and Jeffrey Epstein, his association wit

e A7-327) to the limitations and protections on use when their compulsory powers are used in MLAT requests, an approach which reflects such cases as Kastigar it. United States, 406 U.S. 441 (1972) as well as decisions in UK domestic law. We reiterate the protection at Article 7 (2) of the MLAT treaty alth

Foley Square New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S. PagRoca Denver, Colorado 80203 wv.rw.nmnaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We write in

80203 wv.rw.nmnaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We write in response to the government's letter about Ms. Maxwell's pending motions to suppress and requ

kt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We wr

rado 80203 wv.rw.nmnaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 2

921 F.2d 442, 447 (2d Cir. 1990) ("The government bears the burden of proving that the taint [of an illegal search] has been alleviated.")). Like a Kastigar hearing, "the government bears `the heavy burden of proving that all of the evidence it proposes to use was derived from legitimate independent sou

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administra

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administra

Also, while the agreement included the language "including but not limited to," at the time that the NPA was signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any co-conspirators other than those listed. I recall that there was extensive discussion of Lefkowitz's propo

signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any co-cons

he NPA was signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any

nusz Banasiak and Mucinska. Both initially asked for immunity. After speaking with Banasiak's attorney, Mr. Banasiak was satisfied with I standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to thi

Also, while the agreement included the language "including but not limited to," at the time that the NPA was signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any co-conspirators other than those listed. I recall that there was extensive discussion of Lefkowitz's propo

signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any co-cons

he NPA was signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any

in employees — Janusz Banasiak Both initially asked for immunity. After speaking with Banasiak's attorney, r. anasi was satisfied with a standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to thi

Previous And Non-Verified Address(es): 457 MADISON AVE FL 4, NEW YORK NY 10022-6843, NEWYORK COUNTY (Mar 1992 - Sep 2005) Current ddress: TEIN MAXWELL 3814 S F, BROOKLYN NY 11224-1224. KINGS COUNTY (Jan 1983- Dec 1991) 373-2262 3265 E 66TH ST APT, NEW YORK NY 10021.6404, NEWYORK COUNTY (Jun 1974)

s(es): View All Address Variation Sources 457 MADISON AVE FL 4, NEW YORK NY 10022-6843, NEW YORK COUNTY (Mar 1992 • Sep 2005) Current Address: N GHISLAINE NOELLE MAXWELL https://secure.accurint.com/app/bps/report 5/2/2008 EFTA01728375 Law Enforcement Report Page 3 of 16 Nei). .11.11000 Census)

h evidence should not be introduced because it was obtained as a result of the debriefing. This provision is necessary to avoid the necessity for a Kastigar hearing. Furthermore, under this agreement, no information disclosed by you during the debriefing will be offered in evidence against you in any cr

parts $1,217.20 9 6/18/2005 Extra Touch Flower $13.85 Flowers $1,203.35 10 6/18/2005 Cingular $159.74 Telephone parts $1,043.61 11 6/19/2005 GM $20.00 Cash $1,023.61 12 6/19/2005 Main Street News $9.59 Newspapers $1,014.02 13 6/19/2005 Publix $66.63 Groceries $947.39 14 6/19/2005 Pal

bpoenaed solely as a witness. During our last conversation, you stated that Mr. Banasiak would be willing to speak with investigators pursuant to a Kastigar letter. Please let me know if that is the case and, if so, when you and Mr. Banasiak are available. My office would rightly question why I would as

ting about the full range of topics relevant to your ongoing investigation, including events not covered by the currently pending indictment against Ghislaine Maxwell. If you want to ask any questions in person or via video rather than in writing I am sure the Duke would be willing to receive your questions in tha

indictment against Ghislaine Maxwell? Please note that we will interpret a repeat of your client's offer to answer written questions relevant to the Maxwell indictment as an answer in the negative as to both questions. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew'

t's offer to answer written questions relevant to the Maxwell indictment as an answer in the negative as to bo

no utility, to your case. Our client is willing to provide you with a witness statement, addressing any issues that he may be able to,in relation to Ghislaine Maxwell and Jeffrey Epstein, his association with them and his knowledge of them such as may be relevant to the prosecution of Ghislaine Maxwell. In

Pagliuca 150 East I Oth Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 wvv.hmftaw.com jpogliucatihmflaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We write in

jpogliucatihmflaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We write in response to the government's letter about Ms. Maxwell's pending motions to suppress and requ

kt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's Motions to Suppress Dear Judge Nathan: We wr

.com jpogliucatihmflaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 2

921 F.2d 442, 447 (2d Cir. 1990) ("The government bears the burden of proving that the taint [of an illegal search] has been alleviated.")). Like a Kastigar hearing, "the government bears `the heavy burden of proving that all of the evidence it proposes to use was derived from legitimate independent sou