Epstein Secrets

INTEL REPO No Photo Available Addresses 358 EL BRILLO WAY PALM BEACH, FL 33480 Import From Per: Associates Urtkno... Girlizi Media Maxwell, Ghislaine W/F X1 1 EPSTEIN17S Notes IMAGE EPSTEIN_175.JPG See Drug Trak Case #2002-10 See associate Ghislaine Maxwell 03-11-04 File I 2600 Det. Silvest

kfu M A. MOO I l Asenq I mg I G4 I Narrative/Notes 12/07/01 File 100 Sgt. On 12/06/01, OCVAN received intelligence from the WPBPD concerning Maxwell. According to the report, Maxwell is hiring young women from PBAC to come toher house and answer the phone. They are paid $200.00 per day for htis

ash pull on 3/29/02), front page of bell south phone bill indicating phone account under the name of Jeffrey Epstein and account under the name of Ghislainne Maxwell, correspondence to in cate a weapon s kept on the property, financial information, nude photographs of women and numerous references to massages th

ch intern. once report read as follows: "Three female college students from PBAC and 2 were approached by an Eng is woman w o isenti ie• erse as Maxwe , on the Palm Beach Atlantic Campus. Maxwell said she needed young, beautifu l unmalried women to answer phones and do office work at her home on P

e. On 02/22/02, I received information from Bell South which revealed the following telephone lines are installed at 358 El Brillo Way: Under name G. Maxwell Jeffrey Epstein Main house line All above lines are considered to be residential linos. On 02/27/02, an investigative subpoena was completed reque

1, information was passed on from Sgt. regarding Ghislaine Maxwell and Jeffrey Epstein of 358 El Brillo way

ity of Bellingham 780 P,2d 272, 275-76 (Wash. App. 1989) (collecting cases). See also Bur. of Nat'l Affairs v. U.S. Delft. of Justice 742 F.3d 1484 (D.C. Cir. 1984) (holding that personal appointment materials, such as calendars and daily agendas for the convenience of Assistant Attorney General, are not

Dr. Rocchio's proposed testimony is silent as to whether she is expected to impute a theory of `grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself," but instead that she "recruited and grooming minors to provide sexualized

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM

`grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualiz

d Cir. 1997) 15 United States v. Valle, No. 12 Cr. 847 (PGG), 2013 WL 440687 (S.D.N.Y. Feb. 2, 2013) 3 United States v. Washington, 705 F.2d 489 (D.C. Cir. 1983) 16 United States v. Welch, 368 F.3d 970 (7th Cir. 2004) 30 United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) 6, 8 Yates v. State, 171

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSED

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Mark S. Cohen Christian R. Everdell COHEN &

31-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00103709 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 SUMMARY OF ALLEGATIONS 2 ARGUMENT 3 I. The 2003 Amendment Does Not Apply Retr

. Step Two: Application of the 2003 Amendment to Ms. Maxwell's alleged offenses would have impermissible effe

t natural reading" of the statute is "to construe `any offense involving' by reference to the elements of the offense at issue." 393 F.3d 192, 198 (D.C. Cir. 2004) (emphasis in original). The court then gave an illustrative example of a case in which a defendant travels in interstate commerce, commits a

ase 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, - against - GHISLA1NE MAXWELL, Defendant. : Case No. 15-cv-7433 (RWS) MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTIO

2 of 21 TABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMENT 6 I. MIAM

ABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMENT 6 I. MIAMI HERALD

. " or "Plaintiff') against Ghislaine Maxwell ("Ms. Maxwell" or "Defendant") on the grounds that Ms. Maxwell,

Fin. Corp. v. Deutsche Bank AG, 582 F. Supp. 2d 528 (S.D.N.Y. 2008) 9 Equal Emp's Opponunity Comm'n v. Nat? Children's Ctr., Inc., 146 F.3d 1042 (D.C. Cir. 1998) 8 FDIC v. Ernst & Ernst, 677 F.2d 230 (2d Cir. 1982) 8 Gambale v. Deutsche Bank, 377 F.3d 133 (2d Cir. 2004) 15 Globe Newspapers, Co.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAIN

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR

Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Limine to Exclude In Toto certain depositions designated by Plaintiff for use at trial a

203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Li

e of the jury and thereby substitute his spoken word for the written document.") (italics in original). Gaines v. United States, 349 F.2d 190, 192 (D.C. Cir. I965)(error to allow prior written statement to be read to the witness in front of the jury for the purpose of refreshing recollection because "it

the need for a trial and are pleased with the result' , 33, had persuaded a judge to throw out a motion preventing her from suing British socialite Ghislaine Maxwell, 55, for defamation The defamation suit alleged Maxwell instructed her spokesman to attack honesty and truthfulness and to accuse her of lying For

rsuaded a judge to throw out a motion preventing her from suing British socialite Ghislaine Maxwell, 55, for defamation The defamation suit alleged Maxwell instructed her spokesman to attack honesty and truthfulness and to accuse her of lying For internal use only SDNY_GM_00059503 CONFIDENTIAL - PURS

87111-8318 1602 PENNSYLVANIA ST NE APT E ALBUQUERQUE, NM 87110-5552 1501 TRAMWAY BLVD NE APT C206 ALBUQUERQUE, NM 87112-6108 14 MAX'WELL, GHISLAINE 116E 65TH ST 133-78-XXXX 12/1961 NOELLE NEW YORK, NY 10065- 12/1961 MAXWELL GHISLANE N 7007 For internal use only SDNY_GM_00059558 CONFIDE

UERQUE, NM 87111-8318 1602 PENNSYLVANIA ST NE APT E ALBUQUERQUE, NM 87110-5552 1501 TRAMWAY BLVD NE APT C206 ALBUQUERQUE, NM 87112-6108 14 MAX'WELL, GHISLAINE 116E 65TH ST 133-78-XXXX 12/1961 NOELLE NEW YORK, NY 10065- 12/1961 MAXWELL GHISLANE N 7007 For internal use only SDNY_GM_000595

e level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401, 244 U.S. App. D.C. 11 (D.C. Cir. 1985) (exception to attorney- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

l lawsuit commenced by against one the Clients, Ghislaine Maxwell, in the United States District Court for

hey share some common interests and that there are common legal and factual issues regarding a civil lawsuit commenced by against one the Clients, Ghislaine Maxwell, in the United States District Court for the Southern District of New York. Case No. 15-cv-7433, in which civil lawsuit allegations of misconduct a

ement may be signed in counterparts and each signed c teq:iart shall be deemed an original document. CLIENTS: Ghislaine Maxwell Date COUNSEL FOR MAXWELL: Date Jeffrey Epstein Date dy_zti —t_s COUNSEL FOR EgsT : ---tmAAA.A_ Date ik4f/ s5 Date Date 6 EFTA00622129

Cir. 1985); Schachar v. American Academy of Ophthalmology, Inc., 106 F.R.D. 187, 191-92 (N.D. lll. 1985); In Re Sealed Case, 29 F.3d 715, 719 n.5 (D.C. Cir. 1994); United States v. Bay State Ambulance and Hospital Rental Service. Inc.. 874 F.2d 20, 28 (1st Cir. 1989); and Hanover Ins. Co. v. Rapo & Jep

l lawsuit commenced by against one the Clients. Ghislaine Maxwell. in the United States District Court for

hey share some common interests and that there are common legal and factual issues regarding a civil lawsuit commenced by against one the Clients. Ghislaine Maxwell. in the United States District Court for the Southern District of New York. Case No. 15-cv-7433. in which civil lawsuit allegations of misconduct a

ts and each signed counterpart shall be deemed an original document. CLIENTS: Ghislaine Maxwell Date Jeffrey Epstein Date g_zq -ts COUNSEL FOR MAXWELL: Date , 1111111111c4A5 Date Date 6 EFTA_R1_00019604 EFTA01735586

Cir. 1985): Schachar it American Academy of Ophthalmology. Inc.. 106 F.R.D. 187. 191-92 (N.D. Ill. 1985): In Re Sealed Case. 29 F.3d 715. 719 n.5 (D.C. Cir. 1994); United States v. Bay Stale Ambulance and Hospital Rental Service. Inc.. 874 F.2d 20. 28 (1st Cir. 1989): and Hanover Ins. Co. r. Rapo & Jep

w enforcement. EFTA00188663 Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 3 of 28 7. 1 also knew what Epstein and Maxwell had been doing the years that I was with them. In addition to constantly finding underage girls to satisfy their personal sexual desires, Epstein an

ork). Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls). Epstein inst

that I had been sexually abused by Prince Andrew, Ghislaine Maxwell, Jean Luc Brunel, Alan Dershowitz, and o

by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey I. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"

mployees and underlings to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI deter

f the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not on

as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girl

of the final decision of the Attorney General" of any complaints of violations of the CVRA. Block v. Securities and Exchange Comm In, 50 F.3d I078 (D.C. Cir. 1995), is instructive. In Block, petitioners filed a petition asking the Court to find that the SEC had failed to fulfill its obligation to hold a