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

Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 17 United States v. Van Thornout, 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

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V <https://vvww.nbcnewyork.corn/news/local/crime-and-courts/nyc-doctor- charged-with-illegally-prescribing-oxycodone-pills/2734839/> New York (11/19, Valiquette, 344K) New York reports a doctor who ran a pain management clinic in New York City and the clinic's manager have been arrested "on federal narcotic

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ed stores where narcotics allegedly were peddled." Pain Clinic's Doctor, Manager Facing Drug Charges. In website coverage, WNBC-TV New York (11/19, Valiquette, 344K) New York reports a doctor who ran a pain management clinic in New York City and the clinic's manager have been EFTA00149174 arrested "on f

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ed stores where narcotics allegedly were peddled." Pain Clinic's Doctor, Manager Facing Drug Charges. In website coverage, WNBC-TV New York (11/19, Valiquette, 344K) New York reports a doctor who ran a pain management clinic in New York City and the clinic's manager have been arrested "on federal narcotic