Epstein Secrets

S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100

ame conduct. Counts Five and Six of the S2 Indictment are therefore barred by the NPA. The Court must dismiss these counts, as well as the expanded Mann Act conspiracies charged in Counts One and Three, which incorporate the same conduct charged in Counts Five and Six for which Ms. Maxwell has immunity.

FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff

greement that its own agents negotiated and agreed to with the approval of senior levels of Main Justice. • The government has concocted a federal Mann Act case against Ms. Maxwell by alleging that, on some unspecified occasion during a four-year period between 1994 and 1997, and in an unspecified mann

ENCE RELATED TO ACCUSER-3 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100

United States v. Walla, No. 14—CR-213 (MKB), 2014 WL 3734522 (S.D.N.Y. July 25, 2014) 12 Statutes 18 U.S.C. § 2422(a) 7 18 U.S.C. § 2423(a) 7 Mann Act passim Other Authorities Fed. R. Evid. 401 12 Fed. R. Evid. 402 11, 12 Fed. R. Evid. 403 passim Fed. R. Evid. 404(b) passim Fed. R. Evid

SURPLUSAGE FROM SUPERSEDING INDICTMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800

with Jeffrey Epstein that would violate N.Y. Penal Law § 130.55. Indictment¶¶ 13, 19. The indictment does not charge Ms. Maxwell with a substantive Mann Act violation as to any individual other than Accuser-1, nor does it allege that Ms. Maxwell personally enticed or caused any person other than Accuser-

ENCE RELATED TO ACCUSER-3 Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menn

United States v. Walla, No. 14—CR-213 (MKB), 2014 WL 3734522 (S.D.N.Y. July 25, 2014) 12 Statutes 18 U.S.C. § 2422(a) 7 18 U.S.C. § 2423(a) 7 Mann Act passim Other Authorities Fed. R. Evid. 401 12 Fed. R. Evid. 402 11, 12 Fed. R. Evid. 403 passim Fed. R. Evid. 404(b) passim Fed. R. Evid

EMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stem

ein intended to engage in sexual contact with her. See id. It is the government. not the defense, that apparently does not understand the law. The Mann Act conspiracies charged in the S2 Indictment each require proof that Ms. Maxwell acted with the intent that the alleged victim would "engage in sexual

k, New York Respectfully submitted, /s/ Mark S. Cohen Attorneys for Ghislaine Maxwell 32 EFTA0009938

greement that its own agents negotiated and agreed to with the approval of senior levels of Main Justice. • The government has concocted I federal Mann Act case against Ms. Maxwell by alleging that, on some unspecified occasion during I four-year period between 1994 and 1997, and in an unspecified mann