Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) OPINION AND ORDER ALISON J. NATHAN, District Judge: Defendant Ghislaine Maxwell has been indicted by a grand jury on

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) OPINION AN

islaine Maxwell."); id. ¶ 77 ("[I]t is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell. . . ."). Nor has the Defendant presented any cases where courts addressed the question of whether an anticipatory waiver of extradition is enforce

extradition request is pending in Canada and may be subject to withdrawal."); United States v. Stroh, No. 396-CR-139 (AHN), 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000) ("[I]t appears that there is a substantial legal question as to whether any country to which he fled would enforce any waiver of extr

se approximation of the value of the assets that Ms. Maxwell held in her own name at the time of her arrest..

t aL Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write to Move to Stay proceedings in

of the courts, the public, the other parties and Ms. Maxwell all will best be served by a stay of this civil

7-1312 Re: Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et aL Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write to Move to Stay proceedings in this matter until the conclusion of her pending criminal case. "[T]he power to stay proceedings is incident

letier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012) (citations omitted). The interests of the courts, the public, the other parties and Ms. Maxwell all will best be served by a stay of this civil case. A stay will allow Ms. Maxwell to vigorously contest her criminal charges, and there is little

impose a stay on overlapping civil cases during the pendency of a criminal case. See, e.g., Nesbitt v. Berner, 18-CV-00699 (VLB), 2018 WL 5619716 (D. Conn. Oct. 30, 2018) (granting stay of federal Trafficking Victims Protection Act civil after defendant was charged in state court with patronizing a min

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 COUNTS ONE THROUGH FOUR OF THE SUPERSEDIN

fices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00028903 --- PAGE BREAK --- TABLE

etroactivity and Rejected a Proposal to Do So 3 1. Congress' explicit rejection of a retroactivity provision ends the inquiry at step one in Ms. Maxwell's favor. 3 2. Cases applying the 2003 Amendment retroactively are readily distinguishable. 5 3. The government cannot prevail at step one. 7

tivity provision ends the inquiry at step one in Ms. Maxwell's favor. 3 2. Cases applying the 2003 Amendmen

on, 285 U.S. 518 (1932) 8 United States v. Schneider, 801 F.3d 186 (3d Cir. 2015) 14 United States v. Sensi, No. 08 Cr. 253, 2010 WL 2351484 (D. Conn. June 7, 2010) 5 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) 15 Vernon v. Cassadaga Valley Cent

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 17, 2020 (t

, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th

ars to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to modify protective orders in criminal cases), se

:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 4/27/21 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: Defen

Maxwell seeks an order authorizing a subpoena pursuant to Rule 17(c)(3) of the Federal Rules of Criminal Procedure. As detailed in the subpoena and Maxwell's moving papers, she seeks authorization to serve a subpoena to the law firm of Boies, Schiller and Flexner LLP. BSF has filed a letter in oppositi

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

, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 4577303, at *3 (D. Conn. Dec. 26, 2007). Maxwell also argues that compulsion of the materials' production under Rule 17(c) is justified because the materials appear not to

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

v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *8 (W.D.N.Y. May 8, 2014); United States v. Sensi, No. 3:08-CR-253 (WWE), 2010 WL 2351484, at *3 (D. Conn. June 7, 2010). The sex trafficking charges are therefore not time-barred. Regardless of whether it was the general five-year limitations period in

ase 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN,

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY

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

protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3:15-CR-25 (JCR), 2017 WL 6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (L

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Gleislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the abo

New York 10007 Re: United States v. Gleislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

nal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' I Specifically, the defendant's propo

e identities of .. . victims so that other victims will not be deterred from reporting such crimes." United States v. Paris, 2007 WL 1484974, at *2 (D. Conn. May 18, 2007). Moreover, and consistent with those interests, courts in this Circuit have routinely acknowledged the need to protect victim-witness

as212-6r310193MACINnEEIVANN95202QIERVON0:37217a Fab efi5of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 9/2/20 20-CR-330 (AJN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN,

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3:15-CR-25 (JCH), 2017 WL 6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (L

Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is

orro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Finan