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) 11ENIORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF II E:R OB JECTIONS TO THE PRESENTENCE INVESTIGATION RE

ESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00156337 TABLE OF CONTENTS Page I. The 2003 Guidelines Apply to the Offense Conduct 1 A. A Jury Must Determine the End Date of Criminal

the More Onerous 2004 Guidelines Based Solely on Epstein's Conduct 8 II. The Five-Point Adjustment Under USSG § 4B1.5 Does Not Apply 10 A. Ms. Maxwell Does Not Present a Continuing Danger to the Public. 11 B. Applying § 4BI.5 Would Lead to Absurd Results. 14 III. Ms. Maxwell Does Not Qualif

stment Under USSG § 4B1.5 Does Not Apply 10 A. Ms. Maxwell Does Not Present a Continuing Danger to the Publi

8) 15 United States v. Cordoba-Murgas, 233 F.3d 704 (2d Cir. 2000) 7 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 15 United States v. Gigante, 94 F.3d 53 (2d Cir. 1996) 7 United States v. Harris, 79 F.3d 223 (2d Cir. 1996) 3 United States v. Julian, 427 F.3d 471 (7th Cir. 2005) 3, 4

luding below listed, please my need of help remains urgent. Please I need the motel stay extended and / or to be moved to a new motel immediately. Ghislaine Maxwell's hired power lawyer is my Stuyvesant Town Peter Cooper Village "StuyTown" neighbor who I reported in 2019 duringthe carceration of Jeffrey Epstein -

gante Vinnie the Chin and Louis - Mafia Ghislaine Maxwell StuyTown lawyer Date: Thu, 08 Oct 2020 14:57:46

] - FW: Gigante Vinnie the Chin and Louis - Mafia Ghislaine Maxwell StuyTown lawyer Date: Thu, 08 Oct 2020

ing my safety at risk by members in the tax fraud scheme including Louis Gigante and his mafia family. The planted evidence last week ties with the Gigante brothers and those in business with them who want to keep their illegal money by incarcerating me for their tax fraud crimes. Please can we immedia

From: (FBI)" To: (FBI)" Cc: (NYPD)" Subject: FW: Gigante Vinnie the Chin and Louis - Mafia Ghislaine Maxwell Date: Thu, 08 Oct 2020 15:18:03 +0000 Importance: Normal lawyer From USANYS) Sent: Thursday, October 8, 2020 10:58 AM To (NY) (FBI) NYPD) S

luding below listed, please my need of help remains urgent. Please I need the motel stay extended and / or to be moved to a new motel immediately. Ghislaine Maxwell's hired power lawyer is my neighbor who I reported in 2019 durin the incarceration of Jeffrey Epstein - when I reported the illegal use of my identit

ct: FW: Gigante Vinnie the Chin and Louis - Mafia Ghislaine Maxwell Date: Thu, 08 Oct 2020 15:18:03 +0000 I

ing my safety at risk by members in the tax fraud scheme including Louis Gigante and his mafia family. The planted evidence last week ties with the Gigante brothers and those in business with them who want to keep their illegal money by incarcerating me for their tax fraud crimes. Please can we immedia

luding below listed, please my need of help remains urgent. Please I need the motel stay extended and / or to be moved to a new motel immediately. Ghislaine Maxwell's hired power lawyer is my Stuyvesant Town Peter Cooper Village "StuyTown" neighbor who I reported in 2019 durin the incarceration of Jeffre E stein -

gante Vinnie the Chin and Louis - Mafia Ghislaine Maxwell StuyTown lawyer Date: Thu, 08 Oct 2020 15:18:03

ct: FW: Gigante Vinnie the Chin and Louis - Mafia Ghislaine Maxwell StuyTown lawyer Date: Thu, 08 Oct 2020 1

ing my safety at risk by members in the tax fraud scheme including Louis Gigante and his mafia family. The planted evidence last week ties with the Gigante brothers and those in business with them who want to keep their illegal money by incarcerating me for their tax fraud crimes. Please can we immedia