Epstein Secrets

egraph (UK) <https://www.telegraph.co.ukrnews/2020/07/27/ghislaine-maxwell-fights-keep-nude- photos-sexualised-videos/> (7/27, Ensor, 956K) reports, "Ghislaine Maxwell is trying to prevent nude photographs and `sexualised video' evidence from being unsealed ahead of her trial, according to a new court appeal." Acc

e photographs and `sexualised video' evidence from being unsealed ahead of her trial, according to a new court appeal." According to the Telegraph, Maxwell's attorney "details the 'highly confidential' material in a proposed protective order filed at a Manhattan court on Monday, arguing it should be kep

e highly confidential information contains nude, partially-nude, or otherwise sexualised images, videos, or other depictions of individuals,' which Ms Maxwell does not wish to be 'disseminated, transmitted, or otherwise copies,' it reads." Maxwell "is being held in Metropolitan Detention Centre in Brooklyn

sexualised-videos/> (7/27, Ensor, 956K) reports, "Ghislaine Maxwell is trying to prevent nude photographs an

papers that the delay was needed to research and address `significant and multiple issues' regarding briefs he anticipates filing in connection with Marquez's sentencing. The government has recommended 25 years in prison for Marquez, 28. He remains in custody." The Sun adds, "Federal authorities have sa

berattack. • Report: Russian Scientists Were In Contact With Military Science Institute Developing Novichok Nerve Agent. Criminal Investigations • Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence. • Teenager Sentenced To Time In Juvenile Facility, Probation For Plotting Attac

g.com/news/articles/2020-10-24/maxwell-claims-u-s-reneging-on-promise- to-turn-over-evidence?srnd-premium> (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneging on a promise to provide her with the evidence they've collected in her sex- trafficking case." According t

emium> (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneg

"Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare

an-who-supplied- guns-in-san-bemardino-mass-shootingP (10/23, Rokos, 546K) reports, "U.S. District Court Judge Jesus G. Bernal said he couldn't hold Marquez legally responsible for the 14 slayings. Authorities have said that Marquez did not know about the plot in advance." Marquez, of Riverside, Californ

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00065989 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 7 A. The Structure of the NPA 8 B. The Negotiation of the

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NO

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESS

ould Be Dismissed for Breach of the NPA. 14 A. Ms. Maxwell Has Standing to Enforce the NPA. 15 B. The NPA

, 791 F.2d 294 (4th Cir. 1986) 24 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y.), aff'd, 867 F.2d 1425 (2d Cir. 1988) 21 United States v. Marquez, 909 F.2d 738 (2d Cir. 1990), cert. denied, 498 U.S. 1084 (1991) 15 United States v. Mozer, 828 F. Supp. 208 (S.D.N.Y. 1993) 12 iii EFTA000659

erattack. • Report: Russian Scientists Were In Contact With Military Science Institute Developing Novichok Nerve Agent. CRIMINAL INVESTIGATIONS • Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence. • Teenager Sentenced To Time In Juvenile Facility, Probation For Plotting Attac

AL INVESTIGATIONS Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence. Bloomberg (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneging on a promise to provide her with the evidence they've collected in her sex-trafficking case." According t

omberg (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneg

"Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare

e with authorities." The Orange County (CA) Register (10/23, Rokos, 546K) reports, "U.S. District Court Judge Jesus G. Bernal said he couldn't hold Marquez legally responsible for the 14 slayings. Authorities have said that Marquez did not know about the plot in advance." Marquez, of Riverside, Califor

o a 21st century problem." CRIMINAL INVESTIGATIONS Maxwell Seeks To Seal Evidence. EFTA00150391 The Telegraph (UK) (7/27, Ensor, 956K) reports, "Ghislaine Maxwell is trying to prevent nude photographs and 'sexualised video' evidence from being unsealed ahead of her trial, according to a new court appeal." Acc

e photographs and 'sexualised video' evidence from being unsealed ahead of her trial, according to a new court appeal." According to the Telegraph, Maxwell's attorney "details the 'highly confidential' material in a proposed protective order filed at a Manhattan court on Monday, arguing it should be ke

e highly confidential information contains nude, partially-nude, or otherwise sexualised images, videos, or other depictions of individuals,' which Ms Maxwell does not wish to be 'disseminated, transmitted, or otherwise copies,' it reads." Maxwell "is being held in Metropolitan Detention Centre in Brooklyn

The Telegraph (UK) (7/27, Ensor, 956K) reports, "Ghislaine Maxwell is trying to prevent nude photographs an

apers that the delay was needed to research and address 'significant and multiple issues' regarding briefs he anticipates filing in connection with Marquez's sentencing. The government has recommended 25 years in prison for Marquez, 28. He remains in custody." The Sun adds, "Federal authorities have sai

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NO

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Attorneys for Ghislaine Maxwell EFTA00099352 TAB

AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Attorneys for Ghislaine Maxwell EFTA00099352 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 7 U The Structure of the NPA 8 B. The Negotiation of the

hould Be Dismissed for Breach of the NPA. 14 a Ms. Maxwell Has Standing to Enforce the NPA. 15 B. The NPA

, 791 F.2d 294 (4th Cir. 1986) 24 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y.), aff'd, 867 F.2d 1425 (2d Cir. 1988) 21 United States v. Marquez, 909 F.2d 738 (2d Cir. 1990), cert. denied, 498 U.S. 1084 (1991) 15 United States v. Mozer, 828 F. Supp. 208 (S.D.N.Y. 1993) 12 iii EFTA000993

ury solution to a 21st century problem." CRIMINAL INVESTIGATIONS Maxwell Seeks To Seal Evidence. The Telegraph (UK). (7/27, Ensor, 956K) reports, "Ghislaine Maxwell is trying to prevent nude photographs and 'sexualised video' evidence from being unsealed ahead of her trial, according to a new court appeal." Acc

e photographs and 'sexualised video' evidence from being unsealed ahead of her trial, according to a new court appeal." According to the Telegraph, Maxwell's attorney "details the 'highly confidential' material in a proposed protective order filed at a Manhattan court on Monday, arguing it should be ke

e highly confidential information contains nude, partially-nude, or otherwise sexualised images, videos, or other depictions of individuals,' which Ms Maxwell does not wish to be 'disseminated, transmitted, or otherwise copies,' it reads." Maxwell "is being held in Metropolitan Detention Centre in Brooklyn

The Telegraph (UK). (7/27, Ensor, 956K) reports, "Ghislaine Maxwell is trying to prevent nude photographs an

apers that the delay was needed to research and address 'significant and multiple issues' regarding briefs he anticipates filing in connection with Marquez's sentencing. The government has recommended 25 years in prison for Marquez, 28. He remains in custody." The Sun adds, "Federal authorities have sai

tory Lineup From Last Night's Network News: ABC: Final Debate; Final Debate-Expert Comment; Foreign Interference in Election; COVID-FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman Dies On Flight; Early Winter Storm Warnings; Michigan-Cancer Survivor Runs For Nonprofits. CBS: Final Deba

nce in Election; COVID-FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman Dies On

Interference in Election; COVID-FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman

d wounded 22 others." According to the OCR, "The ruling by U.S. District Court Judge Jesus G. Bernal in Riverside could mean a 19-year difference in Marquez's prison term. Marquez, 28, pleaded guilty in February 2017, but his sentencing has been delayed by attorney motions and Marquez's unsuccessful att

tory Lineup From Last Night's Network News: ABC: Final Debate; Final Debate-Expert Comment; Foreign Interference in Election; COVID-FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman Dies On Flight; Early Winter Storm Warnings; Michigan-Cancer Survivor Runs For Nonprofits. CBS: Final Deba

nce in Election; COVID-FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman Dies On

Interference in Election; COVID-FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman

wounded 22 others." According to the OCR, "The ruling by U.S. District Court Judge Jesus G. Bernal in Riverside could mean a 19-year difference in Marquez's prison term. Marquez, 28, pleaded guilty in February 2017, but his sentencing has been delayed by attorney motions and Marquez's unsuccessful atte

tory Lineup From Last Night's Network News: ABC: Final Debate; Final Debate-Expert Comment; Foreign Interference in Election; COVID- FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman Dies On Flight; Early Winter Storm Warnings; Michigan-Cancer Survivor Runs For Nonprofits. CBS: Final Deba

nce in Election; COVID- FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman Dies On

Interference in Election; COVID- FDA; Wildfires; Ghislaine Maxwell; George Floyd Case; COVID-Infected Woman

d wounded 22 others." According to the OCR, "The ruling by U.S. District Court Judge Jesus G. Bernal in Riverside could mean a 19-year difference in Marquez's prison term. Marquez, 28, pleaded guilty in February 2017, but his sentencing has been delayed by attorney motions and Marquez's unsuccessful att