Epstein Secrets

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 THE SUPERSEDING INDICTMENT AS IT WAS OB

URT 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 THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Ever

31-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00077249 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

Westchester, Putnam, and Rockland counties. The White Plains master wheel contains names from Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess counties. For the three overlapping counties (Westchester, Putnam, and Rockland), the names are apportioned among the two master wheels so as to "r

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 THE SUPERSEDING INDICTMENT AS IT WAS OB

URT 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 THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Ever

lorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00099510 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

Westchester, Putnam, and Rockland counties. The White Plains master wheel contains names from Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess counties. For the three overlapping counties (Westchester, Putnam, and Rockland), the names are apportioned among the two master wheels so as to "r

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 THE SUPERSEDING INDICTMENT AS IT WAS OB

URT 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 THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Ever

olorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New Y rk NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00106017 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

Westchester, Putnam, and Rockland counties. The White Plains master wheel contains names from Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess counties. For the three overlapping counties (Westchester, Putnam, and Rockland), the names are apportioned among the two master wheels so as to "r

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (MN) GHISLAINE MAXWELL, Defendant. [PROPOSED] JOINT REQUESTS TO CHARGE EFTA00074500 TABLE OF CONTENTS INTRODUCTORY INSTRUCTIONS 1 Role of the Court 1 Role

d States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 17 Cr. 151 (AJN). 11 EFTA00074514 The Indictment The defendant, GHISLAINE MAXWELL, has been formally charged in what is called an Indictment. An indictment is simply a charge or accusation. It is not evidence. It is not proof of

RK UNITED STATES OF AMERICA S2 20 Cr. 330 (MN) GHISLAINE MAXWELL, Defendant. [PROPOSED] JOINT REQUESTS TO CHARGE

York. The Southern District of New York encompasses the following counties: New York County (i.e., Manhattan), Bronx, Westchester, Rockland, Putnam, Dutchess, Orange and Sullivan Counties. Anything that occurs in any of those places occurs in the Southern District of New York. Venue must be examined sep

nder bates numbers SDNY_GM_00380550 through SDNY GM 00380554 as part of the Government's discovery pr

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess. See id. Both Master Jury Wheels are emptied and refilled no later than September 1 following the date of each Presidential Election. Id. at Art. II

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess. See id. Both Master Jury Wheels are emptied and refilled no later than September 1 following the date of each Presidential Election. Id. at Art. II

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess. See id. Both Master Jury Wheels are emptied and refilled no later than September 1 following the date of each Presidential Election. Id. at Art. II

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess. See id. Both Master Jury Wheels are emptied and refilled no later than September 1 following the date of each Presidential Election. Id. at Art. II

White Plains Division" and a "Manhattan Division." (See, e.g., Def. Mot. 9 at 2 ("On June 29, 2020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The government has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: Westchester, Putnam, Rockland, Orange, Sullivan, and Dutchess. See id. Both Master Jury Wheels are emptied and refilled no later than September 1 following the date of each Presidential Election. Id. at Art. II