Epstein Secrets

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 DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OB

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 DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Ever

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 EFTA00077249 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

, 7 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 5 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 6 United States v. Osorio, 801 F. Supp. 966 (D. Conn. 1992) 4 United States v. Reyes, 934 F. Supp. 553 (S.D.N.Y 1996) 3, 4 United States v. Rioux, 97 F.3d 648 (2d Cir.

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 DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OB

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 DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Ever

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 EFTA00099510 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

, 7 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 5 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 6 United States v. Osorio, 801 F. Supp. 966 (D. Conn. 1992) 4 United States v. Reyes, 934 F. Supp. 553 (S.D.N.Y 1996) 3, 4 United States v. Rioux, 97 F.3d 648 (2d Cir.

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 DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OB

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 DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Ever

olorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New Y rk NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00106017 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

, 7 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 5 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 6 United States v. Osorio, 801 F. Supp. 966 (D. Conn. 1992) 4 United States v. Reyes, 934 F. Supp. 553 (S.D.N.Y 1996) 3, 4 United States v. Rioux, 97 F.3d 648 (2d Cir.

1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderd

07433-RWS Document 135 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is gr

35 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is granted in p

d NY law." Privilege Log at 1. Defendant argues "Ms. Maxwell's communications with Mr. Barden should be const

r disclosure of otherwise confidential attorney-client communications to a third party waives the privilege absent an . . . exception. People v. Osorio, 75 N.Y.2d 80, 84, 549 N.E.2d 1183, 1185 (1989). There exists an exception, referred to as the agency privilege, when the third party facilitates t

s to maybe cross the line a little too closely (Fisten Aff. ¶ 8); • Telling Fisten that Epstein said he was very upset that Edwards had subpoenaed Ghisline Maxwell, referring to her as a good person that did nothing wrong (i.e., had done nothing wrong even though she helped procure young girls to satisfy Epstei

very upset that Edwards had subpoenaed Ghisline Maxwell, referring to her as a good person that did nothi

300 A.D.2d 169, 752 N.Y.S.2d 642 (N.Y.A.D. 2002) 11 People v. Fentress, 103 Misc.2d 179, 425 N.Y.S.2d 485, (N.Y. Co. Sup. Ct. 1980) 13 People v. Osorio, 75 N.Y.2d 80, 84, 549 N.E.2d 1183 (N.Y. 1989) 10 United States v. Jacobs, 117 F.3d 82 (2d Cir. 1997) 13 iii EFTA00728064 United States v. S