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

he, and not =, was Ms. Maxwell's assistant from when she was hired in 1996 up through the end of her employment in 2002. (Tr. 2332-33, 2376-77).8 Espinosa further testified that in the last two years of her employment (2000-2002), s- later clarified on cross-examination that he "didn't know what her ex

axwell trial in order to identify the individuals and any related derogatory information. FBI New York Criminal Division squad C-20 is investigating Ghislaine Maxwell in a child sex trafficking investigation based on information regarding several victims reportedly sexually abused by Jeffrey Epstein and Ghislaine

islaine Maxwell Trial (U) Executive Summary (U/fFOUO) FBI New York Intelligence Division conducted research on suspected defense witnesses for the Ghislaine Maxwell trial in order to identify the individuals and any related derogatory information. FBI New York Criminal Division squad C-20 is investigatin

sses associated to Jeffrey Epstein. (U) Opportunities (U//FOUO) Interviewing Michelle Healy may reveal more information regarding her knowledge of Ghislaine Maxwell's involvement in Jeffrey Epstein's life. (U) Michelle Healy was an employee for Jeffrey Epstein and Ghislaine Maxwell. • (11///FOUO) As of December

E EXTERNALLY Epstein's company in 1996, when Michelle Healy was currently working as a receptionist. When Espinosa worked at 457 Madison Avenue for Maxwell, it was understood Maxwell to be the office manager of 457 Madison Avenue (FBI I FD-302 50D-NY-3027571, serial 568 I 9 February 2021). (U) Michell

FBI INTERNAL USE ONLY - DO NOT DISSEMINATE EXTERNALLY Epstein's company in 1996, when Michelle Healy was currently working as a receptionist. When Espinosa worked at 457 Madison Avenue for Maxwell, it was understood Maxwell to be the office manager of 457 Madison Avenue (FBI I FD-302 50D-NY-3027571, se

axwell trial in order to identify the individuals and any related derogatory information. FBI New York Criminal Division squad C-20 is investigating Ghislaine Maxwell in a child sex trafficking investigation based on information regarding several victims reportedly sexually abused by Jeffrey Epstein and Ghislaine

islaine Maxwell Trial (U) Executive Summary (U/fFOUO) FBI New York Intelligence Division conducted research on suspected defense witnesses for the Ghislaine Maxwell trial in order to identify the individuals and any related derogatory information. FBI New York Criminal Division squad C-20 is investigatin

es associated with Jeffrey Epstein. (U) Opportunities (U//FOUO) Interviewing Michelle Healy may reveal more information regarding her knowledge of Ghislaine Maxwell's involvement in Jeffrey Epstein's life. (U) Michelle Healy was employed by Jeffrey Epstein and Ghislaine Maxwell. • (U///FOLIO) As of December 2021

NOT DISSEMINATE EXTERNALLY Epstein's company in 1996, when Michelle Healy worked as a receptionist. When Espinosa worked at 457 Madison Avenue for Maxwell, it was understood Maxwell to be the office manager of 457 Madison Avenue (FBI I FD-302 50D-NY-3027571, serial 568 I 9 February 2021). (U) Michell

ICIAL USE ONLY FBI INTERNAL USE ONLY - DO NOT DISSEMINATE EXTERNALLY Epstein's company in 1996, when Michelle Healy worked as a receptionist. When Espinosa worked at 457 Madison Avenue for Maxwell, it was understood Maxwell to be the office manager of 457 Madison Avenue (FBI I FD-302 50D-NY-3027571, ser

slaine Maxwell Trial (U) Executive Summary (U//FOLIO) FBI New York Intelligence Division conducted research on suspected defense witnesses for the Ghislaine Maxwell trial in order to identify the individuals and any related derogatory information. FBI New York Criminal Division squad C-20 is investigatin

sociated with Jeffrey Epstein. (U//FOLIO) Interviewing may reveal more information regarding her knowledge of victims and the relationship between Ghislaine Maxwell's and Jeffrey Epstein. (U//FOUO) Interviewing other witnesses may reveal more information regarding Healy's relationship with Ghislaine Maxwell and J

al with direct access, I was hired as a receptionist at for Epstein's compan in 1996 when worked as a receptionist. When Espinosa worked at for Maxwell, it was understood Maxwell to be the office manager o (FBI I FD-302 50O-NY-3027571, serial 568 I 9 February 2021). • (U) As of December 2021, ac

interview of an individual with direct access, I was hired as a receptionist at for Epstein's compan in 1996 when worked as a receptionist. When Espinosa worked at for Maxwell, it was understood Maxwell to be the office manager o (FBI I FD-302 50O-NY-3027571, serial 568 I 9 February 2021). • (U)

n affidavit that at age 17, Epstein caseffittus://www.youtube.c slit had bet sexually ttafficked by Epstein and Gbiplgue, orniwatcirN=yBnerc,iqpn Maxwell for their own-use and for use by several others, Perversion of Justice, The Miami including Prince Andrew[W1 and retired Harvard Law Herald, Novem

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n amended her complaint to include over 20 corporate entitles associated with Epstein and named the additional individuals Lesley (off and Limberly Espinosa as enablers.[Ma __ c., rn•c..-(-.•,./911191 EFTA00264893 el CO tom- 130S l•)S- 5 e thwi Do) eto PhieNrr - frt - aooci NEts (co:xi cePi..irr