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

, the defendant. In particular, the defendant contends that Michael Casey, the purported agent of Minor Victim-1, "would be able to testify" about Minor Victim-l's behavior during the "relevant time period" and the "lack of any 'outcry' or `grooming."' (Id. at 10). The defense suggests that Casey not having re

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

, the defendant. In particular, the defendant contends that Michael Casey, the purported agent of Minor Victim-1, "would be able to testify" about Minor Victim-l's behavior during the "relevant time period" and the "lack of any `outcry' or 'grooming.'" (Id. at 10). The defense suggests that Casey not having re

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter regarding birth certificates that are marked as Government

, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Gove

New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan:

id. 902(4)(A). That is the case for each of the birth certificates: EFTA00068495 Page 4 • has signed and certified that Government Exhibit 12, Minor Victim-l's birth certificate, is a "true and exact copy of the document officially registered and placed on file in the issuing office." • certified that Gov