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-cr-00330-AJN Document 342 Filed 10/13/21 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. • • • • x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JURO
20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIR
trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t
Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of
the allegations in this case. The following is just a small sample of recent publications concerning Ms. Maxwell: Documentaries • Jeffrey Epstein: Filthy Rich (Netflix) • Notorious: Ghislaine Maxwell (ABC 20/20) • Epstein's Shadow: Ghislaine Maxwell (Peacock) Podcasts: • Chasing Ghislaine: The Untold St
927, In the 151st Judicial District Court of Harris County, Texas Law Firm: Arnold & Itkin LLP 2016 Deposition Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States District Court Southern District of New York Law Firms: Boies Schiller & Flexner LLP and
16 Deposition Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States
tion Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States
ww.yumpu.com www.yumpu.corn/en/document/view/36896254/4dminfplaJ35 www.yumpu.com 92 EFTA00601668 Appendix E Some of the many links to the book, Filthy Rich: A Powerful Billionaire, the Sex Scandal that Undid Him, and All the Justice that Money Can Buy: The Shocking True Story of Jeffrey Epstein by Jame
Confidential — For Settlement Purposes Only Subject to Federal Rule of Evidence 408 & State Law Analogues Jane Doe 43 v. Jeffrey Epstein hislaine Maxwell, =, Lesley Groff & 17-cv-00616 (S.D.N.Y.) Claim ID: FJV4-KWCW BOIES SCHILLER FLEXNER LIP Fort Lauderdale. FL 33301 I vwwbsfllp.com EFTA001466
here he sexually abused her and caused her incredible physical pain. was required to go to the island a number of times. During those visits, and Ghislaine Maxwell would direct and the other girls as to how to Confidential — For Settlement Purposes Only 2 of 8 EFTA00146680 BSF please Epstein and demanded
13 and she and other survivors were interviewed by Glamour magazine. In that interview, discussed bringing Epstein's co-conspirators to justice: Ghislaine [Maxwell] is still walking the streets. Jean-Luc [Brunel] is still walking the streets. It's not good enough just to be heard. There are some people
bars, where they can't hurt anybody else.10 Finally, was interviewed for and appeared on Netflix's documentary miniseries entitled Jeffrey Epstein: Filthy Rich, which aired on May 27, 2020. Conclusion mental health has been deeply impacted by the abuse she suffered at the hands of Epstein. Maxwell, and th
ed Attorneys: ffi ' lic Corruption Unit. Assistant U.S. AttomeyilIM in charge of the prosecution. /,4 6 -6/itaia /1// /a co? PLEASE try to get Ghislaine Maxwell to give information on the former Gov. of US Virgin Islands, John DeJongh, who facilitated Jeffrey Epstein's construction and USE of his private Li
6/itaia /1// /a co? PLEASE try to get Ghislaine Maxwell to give information on the former Gov. of US Vir
/,4 6 -6/itaia /1// /a co? PLEASE try to get Ghislaine Maxwell to give information on the former Gov. of
frightful bollocks about "not knowing" being spouted by so many rich and powerful former friends of Epstein. One of the most telling admissions in Filthy Rich, the Epstein documentary currently showing on Netflix, comes from the former telephone engineer on Epstein's private island. "You tell yourself that
esser number than male perpetrators • LR has not met or interviewed victims in this case • LR is aware of multiple news reports about Epstein and Maxwell as his longtime companion • LR is aware of allegations by some victims that Maxwell was present for or participated in or knew about the abuse •
ticles that raised questions about the initial plea deal that Epstein negotiated in Florida o LR saw one of documentaries about Epstein on Netflix (Filthy Rich) o Heard some episodes of podcast called Seeking Justice; not sure which episodes o Reviewed those before retained as expert witness • Relevant t
be I was ACTUALLY KIDNAPPED and never an adult sex worker, my sister was actually kidnapped as well as a 16 year old. My sister testified against Maxwell and I am the one who was forced by David BOIES to file the affidavit against Epstein! it STOPPING .'JEFFREY EPSTEIN PART 113 PART 1/3: Stoppin
tommerysusommon to datharrnen • • F v. A ir I CRIME VICTIM Empowering. Compassionate. Trustworthy. 8 FEATURED ON Netflix Jeffrey Epstein: Filthy Rich ABC 20/20 Truth & Lies: The Jeffrey Epstein Story Lifetin, Surviving Jeffrey the Nett; Bark CCitn C5 NI Nag Mossacia 1:26 . N if CRIME V
Entities connected to both Ghislaine Maxwell and Filthy Rich

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Denver
LOCATIONJane Doe
PERSON
David Boies
PERSON
Samantha Power
PERSON
Michael Jackson
PERSONSigrid McCawley
PERSON
Alexander Acosta
PERSON
Andrew Cuomo
PERSON
James Patterson
PERSON