Epstein Secrets

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge Netburn

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, hftps://www.nydailynews.cominew-yorlc/ny-j effrey-epstein-maxwel I-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

and at least one timely overt act is committed in furtherance of the conspiracy within the applicable statute of limitations. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunwald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75

materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma

as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

her assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

and at least one timely overt act is committed in furtherance of the conspiracy within the applicable statute of limitations. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3 Christian R. Everdell

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO

not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the

he Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the governmen

es v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 6, 7, 8 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), of 'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 8 United States v. Carboni, 204 F.3d 39 (2d Cir. 2000) 6 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992)

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 STRIKE SURPLUSAGE FROM SUPERSEDING INDICTMENT

URT 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 STRIKE SURPLUSAGE FROM SUPERSEDING INDICTMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue

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 EFTA00086736 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 SUMMARY OF ALLEGATIONS 3 ARGUMENT 5 I. All References to Accuser-3 Should Be

plusage from the Indictment ("Motion"). Although Ms. Maxwell is charged with conspiring to cause individuals t

7) 8 Stogner v. California, 539 U.S. 607 (2003) 7 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), affd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 7 United States v. Curley, 639 F.3d 50 (2d Cir. 2011) 10 United States v. Greebel, No. 15-cr-637 (KAM), 2017 WL

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3 Christian R. Everdell

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO

not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the

he Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the governmen

es v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 6, 7, 8 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), of 'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 8 United States v. Carboni, 204 F.3d 39 (2d Cir. 2000) 6 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Eve

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffr

ruling on the admissibility for two weeks. 15 Ms. Maxwell reiterates her re, uest to defer III. THIS COUR

-NGG-VMS, 2019 WL 2212639 (E.D.N.Y. May 22, 20, 23 Raymond, 700 F. Supp. 2d 142 (D. Me. 2010) 20, 21, 22 Rigas, 490 F.3d 208 (2d. Cir. 2007) 14 Salmonese, 352 F.3d 608 (2d Cir. 2003) 14 Schneider, No. CRIM.A. 10-29, 2010 WL 3734055 (E.D. Pa. Sept. 22, 2010) 20, Sena, No. 19-CR-01432, 2021 WL 4129247