Epstein Secrets

t's response to, and that is the contention that Ms. Maxwell, through counsel, kept in touch with the governm

URT: there is one assertion in the defense papers that I don't think I have seen the government's response to, and that is the contention that Ms. Maxwell, through counsel, kept in touch with the government since the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00093148 Case 21-770, Docume

ay in order to protect her privacy. The following are the words of Jane Doe which I will read from her written statement. Jane Doe wrote: "I knew Ghislaine Maxwell for over ten years. It was her calculating and sadistic manipulation that anesthetized me, in order to deliver me, with full knowledge of the heino

n order to deliver me, with full knowledge of the heinous and dehumanizing abuse that awaited me, straight to the hands of Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done what he did. She was in charge. She egged him on and encouraged him. She told me of others she recruited and she thou

man Loera, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 6000 6.000 6 too° 3 2.000 1000 0 GM IS LAIN E MAXWELL •la ray Weinst•in Erri"nrEME‘rantrrrIMMTI. . Bill Catty JC•ClUll% Guzman Leera Keith Raffle's 21 EFTA00093242 C6set1211-Z7

o had introduced herself as Janet Marshall, who had toured the house and participated in these conversations about the purchase, was the defendant, Ghislaine Maxwell. That series of facts, which I just learned about this morning, your Honor, are concerning for two reasons. First, additionally, it appears that t

at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her

LAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00084370 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 6 of 161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says O dailvmaitco.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-hroped-16-

ummer of 1994 at Michigan's Interlochen Arts Camp, where she was In voice training, according to newly filed court papers suing Epstein's estate and Maxwell. The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all the while grooming her

City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had a boyfriend

By Jams mu and Pelt Nbadta My 10.2020.2:06AM • mm rrad 11 ir • Obtains Maxwal behind bars as now details emerge Jeffrey Epstein's ex-girlfriend Ghatoine Maxwell is accused of facilitating Epstein's sex crimes by ',sting him Mafia, groom and ultimately abuse three unnamed teens between 2994 and 1997. Ghislai

case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal inv

Audrey Strauss called the sex abuse described in the Maxwell case "the prequel" to the charges they lodged la

and sister of the Hollywood actress, Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex cult run by its leader, Keith Raniere, after an 18 month battle. India was among the women he recruited under the guise of offering them self-help courses. Her actress mother pulled her

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 HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. E

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 HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDO

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00065716 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. Reconsideration of the Court's Bail Decision is Appropriate Under

is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict

ra, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000 IJ moo 2.000 1.000 0 GIIISLAINE MAXWELL Hanmy Weirismo, rin*Trifirrnr,77.S 166171MITTETaUll Bill Cathy Jo Quln Gungn Lon Kolth Ramiro 21 EFTA00065742 2. Ms. Maxwell's Counsel Was i

at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her

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 HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. E

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 HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDO

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00154512 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. Reconsideration of the Court's Bail Decision is Appropriate Under

is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict

ra, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000 IJ moo 2.000 1.000 0 GIIISLAINE MAXWELL Hanmy Weirismo, rin*Trifirrnr,77.S 166171MITTETaUll Bill Cathy Jo Quln Gungn Lon Kolth Ramiro 21 EFTA00154538 2. Ms. Maxwell's Counsel Was i

at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her

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 HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. E

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 HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuc

DDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under

is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict

e to an August 14, 2019 news report that Ms. Maxwell might be living in Massachusetts, one person wrote: SHE'S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who #SexTrafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HER

at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her

MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00075107 Casgastetal14331atitilmetbdOnttit7187.82412CF 057g9/28gEFEeigef 6208161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-1

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

rated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblog,/transcripts/announcement-transcript-of-c

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

and sister of the Hollywood actress, Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex cult run by its leader, Keith Raniere, after an 18 month battle. India was among the women he recruited under the guise of offering them self-help courses. Her actress mother pulled her

berattack. • Report: Russian Scientists Were In Contact With Military Science Institute Developing Novichok Nerve Agent. Criminal Investigations • Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence. • Teenager Sentenced To Time In Juvenile Facility, Probation For Plotting Attac

g.com/news/articles/2020-10-24/maxwell-claims-u-s-reneging-on-promise- to-turn-over-evidence?srnd-premium> (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneging on a promise to provide her with the evidence they've collected in her sex- trafficking case." According t

emium> (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneg

"Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare

lletinintelligence.corn/c3330a4e79584b29b30fdd472I3e1225? pubid=fbi> (10/23, story 10, 2:54, Holt, I.82M) reported on an interview with NXIVM leader Keith Raniere to "Dateline" from jail "for the first time since his arrest." Correspondent Stephanie Gosk referred to NXIVM as "a shadowy self help organization

erattack. • Report: Russian Scientists Were In Contact With Military Science Institute Developing Novichok Nerve Agent. CRIMINAL INVESTIGATIONS • Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence. • Teenager Sentenced To Time In Juvenile Facility, Probation For Plotting Attac

AL INVESTIGATIONS Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence. Bloomberg (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneging on a promise to provide her with the evidence they've collected in her sex-trafficking case." According t

omberg (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers say U.S. prosecutors are reneg

"Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare

eader Speaks Ahead Of Sentencing. EFTA00148511 NBC Nightly NewsVi (10/23, story 10, 2:54, Holt, 1.82M) reported on an interview with NXIVM leader Keith Raniere to "Dateline" from jail "for the first time since his arrest." Correspondent Stephanie Gosk referred to NXIVM as "a shadowy self help organization d

ins Lashing Jamaica as 'Catastrophic' Category 5 Storm • China Pushes to Silence Victims of African Mining Disaster • Prince Andrew Hosted Epstein, Maxwell and Weinstein at Royal Lodge • The 92-Year-Old President Who Never Loses • Iranian Women Flout Law on Mandatory Veiling as Police Curtail Arrests

niere Sex Cult Abuse Conviction Courthouse News Service (10/27, Stapley) reported that the Second Circuit Court of Appeals upheld NXIVM cult leader Keith Raniere's conviction and 120-year prison sentence, rejecting his claims that federal investigators and the FBI tampered with digital evidence used to convic