Epstein Secrets

aw 52 2. Discussion 54 IV. The Court Should Deny the Defendant's Motions to Suppress 59 A. Factual Background 61 1. The Civil Lawsuit against Maxwell 61 2. February 2016 Meeting 62 3. The April and July 2016 Depositions of Maxwell 64 4. The USAO-SDNY Commences the Instant Investigation in 201

v. Maxwell. 57 EFTA00103082 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00100024 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197,199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Borti, No. 08 Cr. 2

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights On Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's nefarious reasons for d

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 174 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 120, 127, 133, 135 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 179 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 174, 175, 182 United States v. Botti, No. 08 Cr. 2

nder bates numbers SDNY_GM_00380550 through SDNY GM 00380554 as part of the Government's discovery pr

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("1E]videntiaty detail is not the function of the bill of particulars.' 179 EFTA00103204 Particulars are nece

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("`[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00100146 Particulars are nec

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("c[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00077811 Particulars are nec

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

the defense motion be ripe. Accordingly, the motion should be denied as premature. X. The Defendant's Various Disclosure Motions Should be Denied Maxwell's motions also include an assortment of requests for orders requiring the Government to make various disclosures, all of which are meritless or, at

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("c[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00039626 Particulars are nec

White Plains Division" and a "Manhattan Division." (See, e.g., Def. Mot. 9 at 2 ("On June 29, 2020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The government has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White

020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The gov

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) (m[E]videntiary detail is not the function of the bill of particulars.' Particulars are necessary only where ind