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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
profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find the conditions that were listed under 3142(
Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magistrate Juda jOrder On or about April 9, 201
on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. n. Maxwell, No.20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma
eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://www.nydailynews.corninew-york/ny-jeffrey-epstein-maxwell-case-20201013- jmzh17zdr
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
er assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot 3 at 2) (emphasis in orig
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
T SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: New York, N.Y. 20 Cr. 330 (AJN) x Teleconference Arraignment Bail Hearing July 14, 2020 3:05 p.m. HON. ALISON
S, P.C. (212) 805-0300 EFTA00066216 k7e2MaxC kjc THE COURT: Good afternoon, everyone. This is Judge Nathan presiding. This is United States v. Ghislaine Maxwell, 20 Cr. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 330. I will take appearances from counsel, beginning with
I will take appearances from counsel, beginning with counsel for the defendant. : Good afternoon, your Honor. Mark Cohen, Cohen & Gresser, for Ms. Maxwell. Also appearing with me today is my partner Chris Everdell of Cohen & Gresser and Jeff Pagliuca and Laura Menninger of the Haddon Morgan firm. Good
on, your Honor. Mark Cohen, Cohen & Gresser, for Ms. Maxwell. Also appearing with me today is my partner Chri
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
profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find the conditions that were listed under 3142(
heduled for next month. Dershowitz has filed a motion to dismiss. Lolita Express Another person who appears hundreds of times in the flight logs is Ghislaine Maxwell, a close friend of Epstein. In depositions related to ivil lawsuit against Maxwell, which were recently unsealed by a federal court judge in Manhat
son who appears hundreds of times in the flight logs is Ghislaine Maxwell, a close friend of Epstein. In depositions related to ivil lawsuit against Maxwell, which were recently unsealed by a federal court judge in Manhattan, several women alleged that Maxwell served as a recruiter and manager of Epstein
that ends in Epstein's initials, JE. Other planes that appear in ogs include a twin-engine Cessna with a tail number ending in Maxwell's initials, GM. Both planes spent days on the tarmac at Teterboro when not in flight, according to the logs. EFTA00078268 The logs also appear to document chang
pilots included according to a statement of ac Ghislaine Maxwell. In that suit athgeb, Gary Roxburgh and
just one of at least six pilots employed by Epstein at various times, court documents show. The other pilots included according to a statement of ac Ghislaine Maxwell. In that suit athgeb, Gary Roxburgh and Bill Murphy, in her 2015 lawsuit against Epstein associate alleges Epstein lent her out as a minor for sex
er Mathenge 8/16/19 A US court has sentence self-confessed international drug trafficker Baktash Akasha to 25 years in prison. The Presiding Judge Victor Marrero also imposed a US$100,000 (Sh10.3 million) fine on Baktash. Baktash and his younger brother Ibrahim Akasha were charged for exporting tonnes of hero
provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge Netburn
eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, hftps://www.nydailynews.cominew-yorlc/ny-j effrey-epstein-maxwel I-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge
eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge
eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma
as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
her assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
at various times, court documents show. The other pilots included according to a statement of fact n her 2015 lawsuit against Epstein associate Ghislaine Maxwell. In that suit, a eges pstern ent er out as a minor for sex with his friends. Logs from the other pilots have not surfaced in court records. Rodgers
son who appears hundreds of times in the flight logs is Ghislaine Maxwell, a close friend of Epstein. In depositions related acivil lawsuit against Maxwell, which were recently unsealed by a federal court judge in Manhattan, several women alleged that Maxwell served as a recruiter and manager of Epstein
s in Epstein's initials, JE. Other planes that appear in Rodgers' logs include a twin-engine Cessna with a tail number ending in Maxwell's initials, GM. Both planes spent days on the tarmac at Teterboro when not in flight, according to the logs. 7 EFTA00078288 SDNY News Clips, Friday, August 16,
ct n her 2015 lawsuit against Epstein associate Ghislaine Maxwell. In that suit, a eges pstern ent er out
er Mathenge 8/16/19 A US court has sentence self-confessed international drug trafficker Baktash Akasha to 25 years in prison. The Presiding Judge Victor Marrero also imposed a US$100,000 (Sh10.3 million) fine on Baktash. Baktash and his younger brother Ibrahim Akasha were charged for exporting tonnes of hero
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
of the few involved do not define the professionalism of the entire agency. Additional reporting was provided by Tampa Bay Times (10/27, Sullivan, Marrero), Bay News 9 (10/27, Cole, Lewis), WFLA (NBC-8) (10/27, Suter), Tampa Free Press (10/27, Shultz), and Hoodline Tampa (10/27, Rodriguez). Continued
Entities connected to both Ghislaine Maxwell and Victor Marrero

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONDoug Band
PERSON