Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) 11ENIORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF II E:R OB JECTIONS TO THE PRESENTENCE INVESTIGATION RE

ESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00156337 TABLE OF CONTENTS Page I. The 2003 Guidelines Apply to the Offense Conduct 1 A. A Jury Must Determine the End Date of Criminal

the More Onerous 2004 Guidelines Based Solely on Epstein's Conduct 8 II. The Five-Point Adjustment Under USSG § 4B1.5 Does Not Apply 10 A. Ms. Maxwell Does Not Present a Continuing Danger to the Public. 11 B. Applying § 4BI.5 Would Lead to Absurd Results. 14 III. Ms. Maxwell Does Not Qualif

stment Under USSG § 4B1.5 Does Not Apply 10 A. Ms. Maxwell Does Not Present a Continuing Danger to the Publi

tes v. Santos, No. 21-10381, 2022 WL 1196761 (5th Cir. Apr. 22, 2022) 13 United States v. Skys, 637 F.3d 146 (2d Cir. 2011) 16 United States v. Suarez, No. 21-1721, 2022 WL 1449174 (3d Cir. May 9, 2022) 13 United States v. Torres, 901 F.2d 205 (2d Cir. 1990) 3 United States v. Tykarsky, 446 F

gned the written waiver of rights at approximately 2:31 PM. He then provided the following information. RODRIGUEZ advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his former employer, JEFFERY EPSTEIN, approximately 3-4 months after he was fired from his

ritten waiver of rights at approximately 2:31 PM. He then provided the following information. RODRIGUEZ advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his former employer, JEFFERY EPSTEIN, approximately 3-4 months after he was fired from his position

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nk and withdraw a specified amount of funds. or GHISLAINE MAXWELL would then instruct RODRIGUEZ as to whom to make

on, cellular telephone , residence , Kendall, Florida was interviewed in the vicinity of the Hilton Hotel, 7920 Glades Road, Boca Raton, Florida. Suarez had a North Carolina Driver's License in his possession which reflected a previous address of , Charlotte, North Carolina. Suarez was a vised of t

y 2:30 PM sig the written waiver of rights at approximately 2:31 PM. He then provided the following information. advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his fo employer, JEFFERY EPSTEIN, approximately 3-4 months after he s fired from his posi

sig the written waiver of rights at approximately 2:31 PM. He then provided the following information. advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his fo employer, JEFFERY EPSTEIN, approximately 3-4 months after he s fired from his position as h

bank and Withdraw a specified amount of fund or GHISLAINE MAXWELL would then instru as to whom to make payment an

ident emplo as a kitchen cabinet salesperson, cellular telephone residence interviewed in the vicinity of the Hilton Hotel, Boca Raton, Florida. Suarez had a North Carolina Drivers License in his essi n which reflected a previous address of harlotte. North Carolina. Suarez was advised of the iden

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p. INTERNATIONAL RELATIONS • FBI Used Ghislaine Maxwell's Phone To Locate Her. • Florida Man To Be Arrai

someware Up. INTERNATIONAL RELATIONS • FBI Used Ghislaine Maxwell's Phone To Locate Her. • Florida Man To

from the Federal Bureau of Investigation gave more details about the actions of Marissa Suarez and Patricia Todisco," who were at the Capitol riot. Suarez, then a probationary corrections officer at the Monmouth County Corrections Facility, used an "emergency holiday" to get off work for that day. Sec

sag the written waiver of rights at approximately 2:31 PM. He then provided the following information. RODRIGUEZ advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his fo er employer. JEFFERY EPSTEIN. approximately 3-4 months after he s fired from his p

ritten waiver of rights at approximately 2:31 PM. He then provided the following information. RODRIGUEZ advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his fo er employer. JEFFERY EPSTEIN. approximately 3-4 months after he s fired from his position a

raw a specified amount of funds. SARAH KELLAN or GHISLAINE MAXWELL would then instruct RODRIGUEZ as to whom to make

kitchen cabinet salesperson, cellular tele one residence was interviewed in the vicinity of the Hilton Hotel. 7920 Glades Road. Boca Raton. Honda Suarez had a North Carolina Driver's License in his possession which reflected a revious address of Suarez was advised of the identity of the interviewin

There is an agreement with GM and KCP where WM can be an ACO in GM account. titan is aware of this agreement and this account is agreed to be green from a WM perspective and Aziz

ort of 08St or any of its affiliates. From: Marcus Spooner On Behalf Of ITC ACO Sent: Thursday, January 03, 2019 5:25 AM To: Xavier Avila eonardo Suarez titan Patel >- Matthew Peckman Shanna Cooke <a Oluwasegun Ajiboye ; Sameer Lalji Cc: Nina Tona < ; Martin Zeman mi 11=>; Ian Salters Mathew