Epstein Secrets

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00100024 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

pril 22, 2016 Deposition Transcript of July 22, 2016 Deposition Affidavit of Dr. Bernard R. Siskin iv EFTA00099945 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. ofPlayers Computer Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080 (2

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00077610 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00039425 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080

Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights On Maxwell 17 C. The Defendant Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's nefarious reasons for d

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

55737 (S.D.N.Y. Mar. 10, 2016) 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 2020 WL 3483702 (S.D.N.Y. June 26, 2020) 2021 WL 78235 (January 11, 2021) Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080 (2d Cir. 1989)

aw 52 2. Discussion 54 IV. The Court Should Deny the Defendant's Motions to Suppress 59 A. Factual Background 61 1. The Civil Lawsuit against Maxwell 61 2. February 2016 Meeting 62 3. The April and July 2016 Depositions of Maxwell 64 4. The USAO-SDNY Commences the Instant Investigation in 201

v. Maxwell. 57 EFTA00103082 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00103003 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer; Inc. v. Statistical Tabulating Corp., Page(s) 152 876 F.2d 1080

iler, seeking big financial penalties, for the role its pharmacies may have played in the opioid crisis. (AP) • Jeffrey Epstein's' onetime partner, Ghislaine Maxwell, insisted in a newly unsealed 2016 deposition that she had no knowledge of the deceased financier having sexual contact with minors. Maxwell was c

slaine Maxwell, insisted in a newly unsealed 2016 deposition that she had no knowledge of the deceased financier having sexual contact with minors. Maxwell was charged earlier this year with trafficking minors in concert with Epstein and with lying under oath. (Rosalind Helderman, Shayna Jacobs, Beth

isis. (AP) • Jeffrey Epstein's' onetime partner, Ghislaine Maxwell, insisted in a newly unsealed 2016 depos

ior: President Gerald Ford drank martinis on Air Force One after surviving an assassination attempt. As part of her weekly video series, Mary Beth Albright shows how you can make one after your next bad day: Gr We think you'll like this newsletter Check out Post Most for the most popular and interesti

EFTA00073262 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff Virginia L. Giuffr

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The 1 EFTA00073260 C

F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

ould be Granted. The First Amendment and federal common law each establish a presumption in favor of access to certain judicial documents. Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *9 (S.D.N.Y. Nov. 16, 2018); see Gambale v. Deutsche Bank AG, 377 F.3d 133, 140 (2d Cir. 20

EFTA00077313 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff opposition to Def

ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The EFTA00077311 Case

T SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP

ould be Granted. The First Amendment and federal common law each establish a presumption in favor of access to certain judicial documents. Guzik v. Albright, No. 16-CV-2257 (JPO), 2018 U.S. Dist. LEXIS 196006, at *9 (S.D.N.Y. Nov. 16, 2018); see Gambale v. Deutsche Bank AG, 377 F.3d 133, 140 (2d Cir. 20

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would have "lie is absolutely adorable," she been lying face-down on the said." floor," said Haupert. "I was ready AREA DEATHS Palm Beach County Albright, Edna Foster, 89, of Juno Beach, died Wednesday Edgley Cremation Services, West Palm Reach. Allen, Sylvester, 84, of Boynton Beach. (lied Friday

EXCLUSIVE: Bill Clinton pictured with Jeffrey Epstein's social fixer at Chelsea's wedding AFTER severing links with disgraced pedophile e Ghislaine Maxwell is accused in court papers of procuring girls for her former boyfriend Jeffrey Epstein which she vehemently denies e Bill Clinton had ties to Epstei

llegations were made e Epstein was arrested in 2006 and was sentenced to 18 months in jail in 2008, serving 13 months e Clinton did not cut ties to Maxwell and she was a guest at Chelsea Clinton's wedding in 2010 e Rarely-pictured Jeffrey Epstein has kept a low profile and eschewed public events e But

RSIGHT_019468 --- PAGE BREAK --- Washington D.C. Described as feeling like a ‘family wedding’, guests included former Secretary of State Madeleine Albright, Terry McAuliffe, Governor of Virginia, and leading figure in the civil rights movement Vernon Jordan. For Maxwell to remain a Clinton chum is an in

ched an investigation into his abuse of underage girls ‘Td have been about 17 at the time,’ she said: ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. ‘She'd always wanted to fly and Jeffrey paid for her to take le