Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) OMNIBUS MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO

RN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) OMNIBUS MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Av

lorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00103758 TABLE OF CONTENTS Page PRELIMINARY STATEMENT SUMMARY OF NEW ALLEGATIONS IN THE S2 INDICTMENT 4 ARGUMENT 5 I. The NPA Bars Ms.

E S2 INDICTMENT 4 ARGUMENT 5 I. The NPA Bars Ms. Maxwell's Prosecution on Counts One, Three, Five, and Six

District of New York with related, but distinct weapons possession offense). The Court should not apply them here. Instead, the Court should follow the Third Circuit's approach in United States v. Gebbie, 294 F.3d 540 (3nd Cir. 2002), which involved a situation like this one where the charges in the second prosecu

ity." Section 1594(a) makes it a crime for any person to attempt to violate Section 1591. FlOn one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and i

(a) makes it a crime for any person to attempt to violate Section 1591. FlOn one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears

occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Rob

e is under twenty-one. United States v. Pruitt , 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra : There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohi

y." E Section 1594(a) makes it a crime for any person to attempt to violate Section 1591. F On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and i

(a) makes it a crime for any person to attempt to violate Section 1591. F On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears

occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Rob

e is under twenty-one. United States v. Pruitt , 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra : There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohi

e not in Florida, 'Some of the entries relate to girls we have identified; others do not. 2sOn one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and i

'Some of the entries relate to girls we have identified; others do not. 2sOn one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears

occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Rob

made is under twenty-one. United Stalest Pruitt, 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra: There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohib

ed arguments that purely intrastate conduct could not be prosecuted under the federal Child Pornography Prevention Act of 1996 ("CPPA"). First, in Maxwell, we held that 18 U.S.C. § 2252A(a)(5)(B) was not unconstitutional as applied to a defen- dant's intrastate possession of child por- nography, even

ll Dulien Steel Prod- ucts, 5 Cir., 1957, 40 F.2d 414 (tempo- rary restraining order i ued after notice) differs from Sims Greene, I believe that the Third Circuit's interpre- tation better follows the words and in- tent of the Rule.' Follow' g the type of relief granted in in Sims Greene, I would hold that th

e is under twenty-one. United States v. Pruitt, 763 F.2d 1256, 1261 (1 1 th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra: There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohib

t he insisted that 'Some of the entries relate to girls we have identified; others do not. 'On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and i

'Some of the entries relate to girls we have identified; others do not. 'On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears

occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Rob

e is under twenty-one. United States v. Pruitt , 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra : There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohi

vity with young girls dating back several years. In the early 1990's, Epstein flew a young high school girl to his ranch in New Mexico. Epstein and Ghislaine Maxwell (mentioned above) fondled the girl and encouraged her to engage in additional sexual activity, which she refused. The girl was from a "well-to-do" f

to avoid getting into legal trouble. iF e This girl and her family are terrified of speaking up about Epstein. One of them reported to the FBI that Ghislaine Maxwell had told her that she "could just disappear" if she told anyone what happened. When Vanity Fair found out about this and wrote a story abou

etting into legal trouble. iF e This girl and her family are terrified of speaking up about Epstein. One of them reported to the FBI that Ghislaine Maxwell had told her that she "could just disappear" if she told anyone what happened. When Vanity Fair found out about this and wrote a story about it, the

e is under twenty-one. United States v. Pruitt , 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra : There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohi

vity with young girls dating back several years. In the early 1990's, Epstein flew a young high school girl to his ranch in New Mexico. Epstein and Ghislaine Maxwell (mentioned above) fondled the girl and encouraged her to engage in additional sexual activity, which she refused. The girl was from a "well-to-do" f

o to avoid getting into legal trouble. F36 This girl and her family are terrified of speaking up about Epstein. One of them reported to the FBI that Ghislaine Maxwell had told her that she "could just disappear" if she told anyone what happened. When Vanity Fair found out about this and wrote a story abou

getting into legal trouble. F36 This girl and her family are terrified of speaking up about Epstein. One of them reported to the FBI that Ghislaine Maxwell had told her that she "could just disappear" if she told anyone what happened. When Vanity Fair found out about this and wrote a story about it, the

e is under twenty-one. United States v. Pruitt , 763 F.2d 1256, 1261 (11th Cir. 1985). In reaching this decision, the Eleventh Circuit relied upon the Third Circuit's Hamilton decision, supra : There is, however, a precise analogue to this statute, 18 U.S.C.A. § 2421 et seq. (White Slave Traffic Act), which prohi

." F Section 1594(a) makes it a crime for any person to attempt to violate Section 1591. Ft On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and i

a) makes it a crime for any person to attempt to violate Section 1591. Ft On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into high society, and it appears

occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the daughter of the late Rob