Epstein Secrets

edia with the legal publication Law&Crime. (See here: lawandcrime.com.) This request is made as pan of news gathering and not for a commercial use. Ghislaine Maxwell's case is a matter of great national importance considering her involvement in the broader Jeffrey Epstein scandal. The overarching scandal has, for

d upon issues of alleged corruption by local, state and federal officials and has reportedly involved serial governmental incompetence. Furthermore, Maxwell's case is rumored to implicate several figures at the highest reaches of American government. The Freedom of Information Act would be well-served b

well as all transcripts and other metadata, physical or digital, associated with these audio-visual records. A. Any other 911 calls regarding JE or GM. B. All phone calls, interviews, or other recorded conversations with victims and possible victims of JE and/or GM. C All phone calls, interviews,

s) in your agency's possession of federal inmate Ghislaine Maxwell. The inmate is a 58-year-old woman who wa

ny and all records from the from the United States Attorney's Office for the Southern District o New York relatin to Jeffrey E stein DOB: 01/20/53 ; Ghislaine Maxwell DOB: 12/25/61 and/or any all reports relating to . New York, NY 10021-4102. Dear FOIA Officer: Pursuant to the Freedom of Information Act, 5 U.S.C. §

2019-003549, EOUSA-2019-003550, EOUSA- 2019-00355Z EOUSA-2019-003553, and EOUSA-2019-003554 directed toward the United States Attorney's Offices for the District of New Mexico, Southern District of New York, District of the Virgin Islands, Southern District of Florida, and Northern District of Georgia res ectivel . We have

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 REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATI

ISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) OMNIBUS REPLY 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

enue Denver, Colorado 80203 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Attorneys for Ghislaine Maxwell EFTA00104411 TABLE OF CONTENTS Page ARGUMENT 3 I. The Court Should Not Apply the Annabi Rule and Instead Find that the NPA Bars Ms. Maxwell'

e Annabi Rule and Instead Find that the NPA Bars Ms. Maxwell's Prosecution on Counts One, Three, Five, and Six

zalez, 93 F. App'x 268, 270 (2d Cir. 2004) (plea agreement explicitly stated that "the agreement binds only the United States Attorney's Office for the District of New Mexico"); United States v. Salameh, 152 F.3d 88, 119 (2d Cir. 1998) (plea agreement explicitly stated "[t]his agreement is limited to the United States Att

ed without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell a

e Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell and accuser Virginia Roberts Giuffre had until Nov. 5 to oppose the way their names would be redacted as well as references that might identify them

nancier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be ma

gn and the president's supporters." Opinion: Barr's Approach To Investigating Voter Fraud A "Terrible Idea." David Iglesias, former US Attorney for the District of New Mexico, writes in the Washington Post <https://www.washingtonpost.com/opinions/2020/11/11/david-iglesias-barr-dangerous-voter-fraud- investigation/> (11/11

d without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell a

ne Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell and accuser Virginia Roberts Giuffre had until Nov. 5 to oppose the way their names would be redacted as well as references that might identify the

ancier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be mad

gn and the president's supporters." Opinion: Barr's Approach To Investigating Voter Fraud A "Terrible Idea." David Iglesias, former US Attorney for the District of New Mexico, writes in the Washington Post (11/11, 14.2M) that AG Barr's letter opening the door "for federal prosecutors to launch criminal probes of election

fenses they may have committed against Jane Doe 1, 2, 3, or 4, or other similarly situated victims the following persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210522 28. As of the date of this request, the U.S. Attorney's Office for the Southern District of Florida has n

ing persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210522 28. As

the following persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210522

ion and Obscenity Section, the U.S. Attorney's Offices for the Southern District and Middle District of Florida, the Southern District of New York, the District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigrati

fenses they may have committed against Jane Doe 1, 2, 3, or 4, or other similarly situated victims the following persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210533 28. As of the date of this request, the U.S. Attorney's Office for the Southern District of Florida has n

ing persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210533 28. As

the following persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210533

ion and Obscenity Section, the U.S. Attorney's Offices for the Southern District and Middle District of Florida, the Southern District of New York, the District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigrati

fenses they may have committed against Jane Doe 1, 2, 3, or 4, or other similarly situated victims the following persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210548 28. As of the date of this request, the U.S. Attorney's Office for the Southern District of Florida has n

ing persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210548 28. As

the following persons: (a) Alan Dershowitz; (b) Ghislaine Maxwell; and (c) Jean Luc Brunel. EFTA00210548

ion and Obscenity Section, the U.S. Attorney's Offices for the Southern District and Middle District of Florida, the Southern District of New York, the District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigrati

d without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." EFTA01658793 According to McClatchy, "The two non-parties in the now-settled civil dispute bet

an Epstein accuser are set to be made public." EFTA01658793 According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell and accuser had until Nov. 5 to oppose the way their names would be redacted as well as references that might identify them," but "in a filing la

ancier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be mad

gn and the president's supporters." Opinion: Barr's Approach To Investigating Voter Fraud A "Terrible Idea." David Iglesias, former US Attorney for the District of New Mexico, writes in the Washington Post EFTA01658779 (11/11, 14.2M) that AG Barr's letter opening the door "for federal prosecutors to launch criminal pro

S Post comment NEXT: OPINION Commentary: !las GM pulled a Pinto? Post a Comment hIlp/Ay.wornweln

friends on that island, so the District of the Virgin Islands also would have jurisdiction. also reported frequent sexual activity with Epstein in the District of New Mexico and the Central District of California. In both of those Districts there is evidence (from or other witnesses) of Epstein engaging in illegal sexu