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te's beau is a CIA spook, a math teacher, .a ncert pianist or a corporate head- inter. "But what is the truth about rn?" the newspaper wondered. ike Maxwell, Epstein is both anboyant and intensely private." The media frenzy did not begin full until a decade later. In Sep- mber 2002, Epstein was flung i
say I have nothing good to say about him." Among the characteristics most attributed to Epstein is a penchant for women. • He has been linked to Maxwell, a fixture on the high-society party circuits in both New York and Lon- don. Previous girlfriends are said to Police interview 5 alleged victims
rgest private residehce in Manhattan, It is reported to have closed-circuit television and a heated sidewalk to melt fallen snow. Women in his ilf Ghistaine Maxwell, a fixture at elite parties and the intensely private daughter of a media tycoon, dated Epstein in the 1990s. 'he odd thing is I never met him
n Ghislaine Maxwell, daughter of the fat and fraudulent former owner of the Daily News, the late Robert Maxwell. I hear that some of the 39-year-old Ghislaine's friends on the Manhattan and London party circuit are cutting her because she's had so much adverse press over her relationship with Prince Andre
the background as he vigated New York high society. When he first attracted notice in e early 1990s, it was on account of e woman he was dating: Ghislaine axwell, daughter of the late British edia tycoon Robert Maxwell. In a lengthy article, headlined he Mystery of Ghislaine Max- ill's Secret Love," the Bri
: His band is actually good. Con: Wears "ironic" 1980$ concert T-shirts by Def Lepard and Michael Jackson. SHEPHERD SMITH, 39. Next to the blustery Bill O'Reilly, this Southern-fried anchorman is probably the most recognizable face on the top-rated Fox News Channel. Pro: His sprawling Lower East Side pad has
-cr-00330-AJN Document 342 Filed 10/13/21 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. • • • • x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JURO
20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIR
trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t
Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of
mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and intrigue of this case. There
other, there's 8 people from Australia - and you'll see soon in 9 the papers - that they're coming out with a 10 whole story about this case, with Ghislaine 11 Maxwell, and the brother, and these victims, 12 who they're claiming, we're not really victims. 13 You know? You know, that these are just, as
8 people from Australia - and you'll see soon in 9 the papers - that they're coming out with a 10 whole story about this case, with Ghislaine 11 Maxwell, and the brother, and these victims, 12 who they're claiming, we're not really victims. 13 You know? You know, that these are just, as my 14 mothe
on. Oh, that's what got Bill Cosby 21 out, right? Another prosecution, a non- 22 disclosure agreement, yeah. Which I believe is 23 the defense that Ghislaine Maxwell is going to 24 use, but, you know, I'm not an attorney, and 25 (Indiscernible *01:01:44). 70 1 MR. : Right. 2 MR. EPSTEIN: Mm-hmm. 3 MS. O
a 3 MR. EPSTEIN: 4 MR. 5 MR. EPSTEIN: 6 MR. 7 done? 8 MR. EPSTEIN: 9 That was. 29 -- President Trump there, news reporter. O'Reilly. Bill O'Reilly. Bill O'Reilly. (Indiscernible *00:27:54). Do you know when that was It was prior to the death. 10 MR. Prior to the death. 11 MR. EPSTEIN: B
her, there's 14 people from Australia - and you'll see soon in 15 the papers - that they're coming out with a 16 whole story about this case, with Ghislaine 17 Maxwell, and the brother, and these victims, 18 who they're claiming, we're not really victims. 19 You know? You know, that these are just, as
14 people from Australia - and you'll see soon in 15 the papers - that they're coming out with a 16 whole story about this case, with Ghislaine 17 Maxwell, and the brother, and these victims, 18 who they're claiming, we're not really victims. 19 You know? You know, that these are just, as my 20 mothe
ution. Oh, that's what got Bill Cosby 2 out, right? Another prosecution, a non- 3 disclosure agreement, yeah. Which I believe is 4 the defense that Ghislaine Maxwell is 5 (Indiscernible *01:01:41), you know, but I'm 6 not an attorney, and they charge a 7 (Indiscernible *01:01:44). 8 : Right. 9 MR. EPSTEIN:
5 : So, we're looking at -- 6 MR. EPSTEIN: I've met Trump. 7 -- President Trump there, 8 as well as a news reporter. 9 MR. EPSTEIN: O'Reilly. Bill O'Reilly. 10 : Bill O'Reilly. 11 MR. EPSTEIN: (Indiscernible *00:27:54). 12 13 done? : Do you know when that was 14 MR. EPSTEIN: It was prior to the
is known—the Wexner family, founders of The Limited clothing stores. EFTA00214242 Women. • Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have also dated a former Miss Sweden and a Romanian model. The Case. • Investigation began after a mother heard her daughter discussing
242 Women. • Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have als
g linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have also dated a former Miss
Legal Immunity: Maybe It's Politics Jeffrey Epstein has some powerful friends but it seems he's made some pretty vocal enemies as well. Last night Bill O'Reilly apparently delivered his "Memo" on the subject of the Epstein prosecution—charging prosecutor Krischer with political bias. The gist of it is that K
is known—the Wexner family, founders of The Limited clothing stores. EFTA00221097 Women. • Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have also dated a former Miss Sweden and a Romanian model. The Case. • Investigation began after a mother heard her daughter discussing
097 Women. • Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have als
g linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have also dated a former Miss
Legal Immunity: Maybe It's Politics Jeffrey Epstein has some powerful friends but it seems he's made some pretty vocal enemies as well. Last night Bill O'Reilly apparently delivered his "Memo" on the subject of the Epstein prosecution—charging prosecutor Krischer with political bias. The gist of it is that K
is life. mostly young. but there is no one of them to whom he has been able to commit. He describes his most public companion of the last decade. Ghislaine Maxwell. 41. the daughter of the late. disgraced media baron Robert Max- well. as simply his "best friend.- He says she is not on his payroll, but she seem
t Side dinners." the woman recalls. "Many seemed foreign and dressed a little bizarrely: This same guest also at- tended a cocktail party thrown by Maxwell that Prince Andrew attended, which was tilled. she says. with young Russian mod- els. "Some of the guests were horrified: the woman says. "He's r
n Ghislaine Maxwell, daughter of the fat and fraudulent former owner of the Daily News, the late Robert Maxwell. I hear that some of the 39-year-old Ghislaine's friends on the Manhattan and London party circuit are cutting her because she's had so much adverse press over her relationship with Prince Andre
: His band is actually good. Con: Wears "ironic" 1980s concert T-shirts by Def Lepard and Michael Jackson. SHEPHERD SMITH, 39. Next to the blustery Bill O'Reilly, this Southern-fried anchorman is probably the most recognizable face on the top-rated Fox News Channel. Pro: His sprawling Lower East Side pad has
to the FBI. Epstein, 54, leads a hedonistic lifestyle that has troubled Royal courtiers ever since ne was introduced to the Prince by their friend Ghislaine Maxwell, daughter of the late disgraced media tycoon Robert Maxwell. During his Thai holiday with Epstein, Andrew was photographed surrounded by topless wo
n Ghislaine Maxwell, daughter of the fat and fraudulent former owner of the Daily News, the late Robert Maxwell. I hear that some of the 39-year-old Ghislaine's friends on the Manhattan and London party circuit are cutting her because she's had so much adverse press over her relationship with Prince Andre
funds. Ghislaine's own funds are something of a mystery. Her father lavished money on her and set her up in at least one business in New York. But Maxwell's own ill-gotten gains were seized after he took a dive off his yacht, which was named for her. There are plenty of British pensioners who lost thei
: His band is actually good. Con: Wears "ironic" 1980s concert T-shirts by Def Lepard and Michael Jackson. SHEPHERD SMITH, 39. Next to the blustery Bill O'Reilly, this Southern-fried anchorman is probably the most recognizable face on the top-rated Fox News Channel. Pro: His sprawling Lower East Side pad has
is known—the Wexner family, founders of The Limited clothing stores. EFTA00067276 Women. • Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have also dated a former Miss Sweden and a Romanian model. The Case. • Investigation began after a mother heard her daughter discussing
276 Women. • Long linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have als
g linked to media mogul Robert Maxwell's daughter Ghislaine Maxwell. • Said to have also dated a former Miss
Legal Immunity: Maybe It's Politics Jeffrey Epstein has some powerful friends but it seems he's made some pretty vocal enemies as well. Last night Bill O'Reilly apparently delivered his "Memo" on the subject of the Epstein prosecution—charging prosecutor Krischer with political bias. The gist of it is that K
New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011115 --- PAGE BREAK --- Case
Page: EFTA00011115 →UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av
Page: EFTA00011115 →Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of
Page: EFTA00011116 →trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t
Page: EFTA00011116 →mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and intrigue of this case. There
Page: EFTA00011122 →Entities connected to both Ghislaine Maxwell and Bill O'Reilly

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSON