Epstein Secrets

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS ME

exual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth GM 7 The defendant also argues that Dr. is not an expert in "the human brain or memory generally." (Def. Mot. 3 at 17). The overnment agrees. But Dr.

m-3's allegations "may reflect conduct 43 EFTA00088845 undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (id. at 26-27). B. Applicable Law It is axiomatic that the Government may offer proof of acts included within the indictment. Th

together while nude. This evidence corroborates witness testimony expected at trial, which will describe topless swimming in the pool at Epstein's Palm Beach House. It is also relevant to the relationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defend

he '90s Tom Pritzker, 3 Ace, Jimmy Cayne, Lou Ranieri. I mean, there were -- 4 TODD BLANCHE: What about the royal 5 family? 6 GHISLAINE MAXWELL: No. He didn't know 7 them in the '90s. 8 TODD BLANCHE: What about the -- the -- 9 what about Prince Andrew? 10 GHIS

(Break at 12:15 p.m. to 12:59 p.m.) 12 SPENCER HORN: Good afternoon. We are 13 continuing the recorded proffer interview of 14 Ms. Maxwell. The time is 12:59, Thursday, July 24th. 15 TODD BLANCHE: Okay. So just to continue 16 what we're talking about, Ms. Maxwell, still foc

CHE: What about the royal 5 family? 6 GHISLAINE MAXWELL: No. He didn't know 7 them in the '90s. 8

3 continuing the recorded proffer interview of 14 Ms. Maxwell. The time is 12:59, Thursday, July 24th. 15

e MAGNA9 LEGAL SERVICES Page 161 1 island? 2 GHISLAINE MAXWELL: Yes. 3 TODD BLANCHE: Did he go to Palm -- 4 meet -- go to Palm Beach House? 5 GHISLAINE MAXWELL: Yes, he went -- yeah, 6 he went everywhere. I saw him in every place. 7 TODD BLANCHE: Did do you ever

Page 1 United States Department of Justice INTERVIEW OF: GHISLAINE MAXWELL DATE: July 24, 2025 APPEARANCES: For the United States: Todd Blanche, Deputy Attorney General Diego Pestana, Acting Associate Deputy Attorney

Page 1 United States Department of Justice INTERVIEW OF: GHISLAINE MAXWELL DATE: July 24, 2025 APPEARANCES: For the United States: Todd Blanche, Deputy Attorney General Diego Pestana, Acting Associate Deputy Attorney General

, Deputy Attorney General Diego Pestana, Acting Associate Deputy Attorney General Spencer Horn, FBI Special Agent Mark Beard, Deputy U.S. Marshal For Ghislaine Maxwell: David Markus Leah Saffian Melissa Madrigal 2 (Pages 2 to 5) 2 (Pages 2 to 5) Page 2 1 I N T E R V I E W 2

rk. 8 Today we're doing a proffer of 9 Ms. Maxwell. The date is July 24th and the time is 10 10:12

E: Did -- did he visit the Page 161 1 island? 2 GHISLAINE MAXWELL: Yes. 3 TODD BLANCHE: Did he go to Palm -- 4 meet -- go to Palm Beach House? 5 GHISLAINE MAXWELL: Yes, he went -- yeah, 6 he went everywhere. I saw him in every place. 7 TODD BLANCHE: Did do you ever

ninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are producing the materials listed in the below index. These discovery materials are stamped with control

obbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are pr

fices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today w

GM 02763005 SDNY GM 02763007 Photographs SDNY_GM_02763008 SDNY_GM_02763016 Photographs Confidential SDNY_GM_02763017 SDNY_GM_02763017 Photos of Palm Beach House The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it bec