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80 Oct 3 Deposit U85 BANK USA DEPOSIT ACCOUNT 161 56 Oct 17 Deposit UBS BANK USA DEPOSIT ACCOUNT 1300.00 41220.70 continued next page SDNY GM 00021097 OW70003005748009 NP7000193796 00003 1014 030575004 CONFIDENTIAL 000000 ►age 31 of 98 EFTA_00 1 3 17 17 EFTA01273924 4tUBS UBS Strat
trived pate Money balance ec0vities (continued) Oct 27 Withdrawal UBS BANK USA DEPOSIT ACCOUNT ASOF 10124114 -1220.78 Activity Account name: GHISLAINE MAXWELL Friendly account name: Account number: Your II nuncio' Advisor: SCOTT STACK MANY LYLE CASRIEL Desuption Amount (5) Oct31 Closing UBS
cial Services Inc. 299 Park Avenue 25th Floor New York NY 10171.0002 UBS Strategic Advisor November 2014 CM-70056752 59 1111 Y2 YI 0 GHISI ANF MAXWELL Account name: GHIStANE MAXWELL Friendly account name: Account number Your financial Advisor. SC077 STACKMAAULYLE CASRIEL Phone Questions about
ASOF 10124114 -1220.78 Activity Account name: GHISLAINE MAXWELL Friendly account name: Account number: Your II
Park Avenue 25th Floor New York NY 10171.0002 UBS Strategic Advisor November 2014 CM-70056752 59 1111 Y2 YI 0 GHISI ANF MAXWELL Account name: GHIStANE MAXWELL Friendly account name: Account number Your financial Advisor. SC077 STACKMAAULYLE CASRIEL Phone Questions about your statemeat? Call your Fina
s ode the kaolin hien Protection Act (SPA) • tithe Medi matron on the top left of the lroot of the nalernmt is not LUIS FitinCulSenCen IBS Pravda Soares caries you accord as dearkg broke by arongemett oath the Mated mouton We Intoned you on this reblionthp %hen yea (*.red this =urn In the caok far
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
2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), aff'd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts
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
, 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts
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
, 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts
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
C), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007) United States v. Snyder, 159, 160, 167 162 139 668 F.2d 686 (2d Cir. 1982) 44, 53 United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) 203 United States v. Spears, 159 F.3d 1081 (7th Cir. 1999) 43, 45, 46 United States v. Sprouts, 282 F.3d 1
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
, 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts
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
to Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency .. ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00103228 Southern District, cases are commonly transferred from one courthouse to an
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
Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency . . . ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00077835 Southern District, cases are commonly transferred from one courthouse to an
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
to Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency .. ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00100170 Southern District, cases are commonly transferred from one courthouse to an
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
Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency . . . ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00039650 Southern District, cases are commonly transferred from one courthouse to an
Entities connected to both Ghislaine Maxwell and Soares

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONFBI
ORGANIZATIONJane Doe
PERSONEmmy Taylor
PERSON
Audrey Strauss
PERSON
David Boies
PERSON
Lesley Groff
PERSON
John F. Kennedy
PERSON
Sarah Kellen
PERSON