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and Confidential - Attorney Work Product Do Not Disseminate Outside of the SDNY USAO (or other DOS COMPONENT, as needed) USAO #: United States v. Maxwell, S2 20 Cr. 330 (AJN) 3/14/2021 I. Overview This memorandum seeks authorization to charge GHISLAINE MAXWELL with additional criminal offenses ba
OMPONENT, as needed) USAO #: United States v. Maxwell, S2 20 Cr. 330 (AJN) 3/14/2021 I. Overview This memorandum seeks authorization to charge GHISLAINE MAXWELL with additional criminal offenses based on her participation in the recruitment, grooming, and abuse of minor girls with Jeffrey Epstein in
e, recalls that Maxwell would engage * her in conversation when would first arrive at t e ouse before going up to the massage room. For example, Maxwe would ask questions about her family and her life. During those conversations, told Maxwe tat er parents were separated, that her parents would f
we have confirmed with the U.S. Attorney's Office in Georgia that it does not possess any substantive witness statements or any material regarding Ghislaine Maxwell. Second, we have obtained all emails from the lead AUSA who handled the USAO-SDFL investigation of Epstein, and have run keyword search terms throu
20, our office has obtained and reviewed for Rule 16 material agency files from the FBI's Miami Field Office, the Palm Beach Police Department, and the Palm Beach State's Attorney's Office. Also consistent with the October 7, 2020 letter, we have taken the following steps to obtain additional agency files to review f
VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide additional information in response to the Court's
tates Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern
United States Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th
Florida Investigation (2005-2010) Between approximately 2005 and 2010, and as detailed further below, members of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI
ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide additional information in response to the Court's
, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern
gathered any information regarding the defendant, Ghislaine Maxwell. If so, the Government will request any
Florida Investigation (2005-2010) Between approximately 2005 and 2010, and as detailed further below, members of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI
ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide additional information in response to the Court's
, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern
gathered any information regarding the defendant, Ghislaine Maxwell. If so, the Government will request any
Florida Investigation (2005-2010) Between approximately 2005 and 2010, and as detailed further below, members of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI
ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide additional information in response to the Court's
, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern
gathered any information regarding the defendant, Ghislaine Maxwell. If so, the Government will request any
Florida Investigation (2005-2010) Between approximately 2005 and 2010, and as detailed further below, members of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI
ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to provide additional information in response to the Court's
, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern
gathered any information regarding the defendant, Ghislaine Maxwell. If so, the Government will request any
Florida Investigation (2005-2010) Between approximately 2005 and 2010, and as detailed further below, members of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI
Entities connected to both Ghislaine Maxwell and the Palm Beach State's

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
New York
LOCATIONFBI
ORGANIZATION
Alison J. Nathan
PERSON
Audrey Strauss
PERSON
New York City
LOCATION
Alfredo Rodriguez
PERSON
U.S. Virgin Islands
LOCATION
Scarlett Johansson
PERSON
Juan Alessi
PERSON
Martha Stewart
PERSON
Southern District of New York
ORGANIZATION
Sarah Ferguson
PERSONNadia Marcinkova
PERSON
Palm Beach Police Department
ORGANIZATION