Epstein Secrets

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 THE SUPERSEDING INDICTMENT FOR BREACH OF

of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00028880 --- PAGE BREAK --- TABLE OF CONTENTS Page I. The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce It. 2 II. The Co-Conspirator Immunity Provision is Not Limited to the SDFL. 7 III. The Co-Conspirator Immunit

TABLE OF CONTENTS Page I. The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce It. 2 II. Th

rnout, 100 F.3d 590 (8th Cir. 1996) 12 Other Authorities Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghislaine Maxwell Arrested on Sex Abuse Charges." NBC New York. July 3, 2020 15 iii EFTA00028883 --- PAGE BREAK --- Ghislaine Maxwell respectfully subm

From: To: Cc: Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases Date: Wed, 14 Oct 2020 18:27:50 +0000 Hi, Just the documents tagged as listed below, please (not the full family).

e following three productions to be prepared for the Maxwell case. I've listed those tasks below in the order

end of October in order to meet our discovery deadline. Finally, I believ hould be sending you a drive containing the scans of boxes of files from the USAO-SDFL. We need all of those files loaded into the US v Epstein database on Relativity in a new folder entitled "USAO-SDFL Files," ASAP so that we can rev

From: To: Cc: Subject: RE: Discovery Tasks for Maxwell on Epstein Relativity Databases Date: Wed, 14 Oct 2020 16:27:04 +0000 Thanks very much. From: Sent: Wednesday, October 14, 202012:22 PM To Subj

e following three productions to be prepared for the Maxwell case. I've listed those tasks below in the order

d of October in order to meet our discovery deadline. Finally, I believe should be sending you a drive containing the scans of boxes of files from the USAO-SDFL. We need all of those files loaded into the US v Epstein database on Relativity in a new folder entitled "USAO-SDFL Files," ASAP so that we can rev