vert Acts 17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple g

vert Acts 17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple g

vert Acts 17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple g

uthern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: July 24, 2019 Appearance Time: 10:00 a.m. to testify and give evidence in regard to an a

uthern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: July 24, 2019 Appearance Time: 10:00 a.m. to testify and give evidence in regard to an a

uthern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: July 24, 2019 Appearance Time: 10:00 a.m. to testify and give evidence in regard to an a

uthern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: July 24, 2019 Appearance Time: 10:00 a.m. to testify and give evidence in regard to an a

uthern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: July 24, 2019 Appearance Time: 10:00 a.m. to testify and give evidence in regard to an a

uthern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: July 24, 2019 Appearance Time: 10:00 a.m. to testify and give evidence in regard to an a

9.2 EFTA00008813 --- PAGE BREAK --- 03/29/2021 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the Southern District of New York?" A. "Yes." Q. "Generally speaking, in broader strokes, what was the lawsuit about; what was the claim that was bringing against Maxwell?" WI

9.2 EFTA00008813 --- PAGE BREAK --- 03/29/2021 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the Southern District of New York?" A. "Yes." Q. "Generally speaking, in broader strokes, what was the lawsuit about; what was the claim that was bringing against Maxwell?" WI

9.2 EFTA00008813 --- PAGE BREAK --- 03/29/2021 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the Southern District of New York?" A. "Yes." Q. "Generally speaking, in broader strokes, what was the lawsuit about; what was the claim that was bringing against Maxwell?" WI

ecific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, con

ecific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, con

ecific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, con

ce.gov/criminal/ fraud/fcpa/cases/saybolt/08- 10-98saybolt-info.pdf. 277 See Second Superseding Indictment, United States v. Kozeny, No. 05- cr-518 (S.D.NY. May 26, 2009), ECF No. 203, available at http://www. justice.gov/criminal/fraud/fcpa/cases/kozenyv/05-26-09bourke2nd- supersed-indict.pdf; Judgment,

//wwwjustice. gov/ criminal/fraud/ fcpa/ cases/sapsizianc/' 06-06-07 sapsizian- plea.pdf. ? See, 6.8, Complaint, SEC y. Tyco Int'l Ltd., 06-cv-2942 (S.D.N-Y. 2006), ECF No. 1 [hereinafter SEC v. Tyco Int'l], available at http://www.sec. gov/litigation/complaints/2006/comp 1 9657.pdf; Complaint, SEC v. Will

minal penalties, in addition to other penalties of the Law. DATED: New York, New York July 28, 2021 /s AUDREY STRAUSS United States Attorney for the Southern District of New York Assistant United States Attorney One St. Andrew's Plaza New York, New York 10007 Email: Telephone: Rev. 02.01.12 EFTA00018022

HERN DISTRICT OF NEW YORK TO: GREETINGS: WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the United States District Court for the Southern District of New York, 40 Foley Square, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and pl

red a crime victim for purposes of the CVRA until the government has filed criminal charges); United States v. Turner, 367 F. Supp. 2d 319, 326-27 (E.D.N.Y. 2005) (victims are not entitled to CVRA rights until the government has filed charges, but courts have discretion to take a more inclusive approach)

s, and opposed by the government, was rescission of the NPA and federal prosecution of Epstein. On July 2, 2019, the U.S. Attorney’s Office for the Southern District of New York obtained a federal grand jury indictment charging Epstein with one count of sex trafficking of minors and one count of conspiracy to commit sex tra

HERN DISTRICT OF NEW YORK TO: GREETINGS: WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the United States District Court for the Southern District of New York, 40 Foley Square, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and pl

iminal penalties, in addition to other penalties of the Law. DATED: New York, New York May 12, 2021 /s AUDREY STRAUSS United States Attorney for the Southern District of New York Assistant United States Attorney One St. Andrew's Plaza New York, Telephone: rev. 02.01.12 EFTA00014663

ew York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: Q.

ed by counsel in multiple ongoing civil lawsuits in the United States. As recently as in or about June 2020, attorney Laura Menninger appeared in in the Southern District of New York for oral argument before United States District Judge Loretta A. Preska on MAXWELL's behalf. 13. Based on my review of AT&T records, I have learne

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

d States v. Crowell, No. 06-CR-29IE(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v Dominguez, 783 F.2d 702 (7th Cir. 1986

ed several civil 12 EFTA00018530 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 17 of 26 cases related to Epstein in the Southern District of New York and has sat for depositions in those cases. Similarly, throughout the course of the criminal investigation of this case, which has been publicly re

ons. The Court disagrees for two independent reasons. First, under controlling Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New York. Second, it does not cover the offenses charged in the S1 superseding indictment. 3 EFTA00022093 --- PAGE BREAK --- Case 1:20-cr-00330-AJN

PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 4 of 34 A. The non-prosecution agreement does not bind the U.S. Attorney for the Southern District of New York United States Attorneys speak for the United States. When a U.S. Attorney makes a promise as part of a plea bargain, both contract principles and d

r claims against these financial sponsors of terrorism. Statement Of Subject Matter and Appellate Jurisdiction The United States District Court for the Southern District of New York had subject matter jurisdiction over these actions pursuant to 28 U.S.C. § 1330, 1331, 1332, 1350, 1367, 1407, and 1605, 18 U.S.C. §§ 1964 and 2338,

rorist activities and to be affiliated with al-Qaeda. See Wyatt, 785 F. Supp. 2d at 647-48; see also Goldberg v. UBS AG, 660 F. Supp. 2d 410, 428-29 (E.D.N.Y. 2009) (finding that plaintiffs had “sufficiently pled that the defendant consciously disregarded the fact that it was supporting a terrorist organiza

ional. by Jesse Eisinger ProPublica, March 12, 2017, 6:22 p.m. 1 Comment Print Print search Follow ProPublica reet Bharara, then U.S. attorney for the Southern District of New York, at Trump Tower in November 2016 (Drew Angerer/Getty Images) After his election in 1968, President Richard Nixon asked Robert Morgenthau, the US Att

l attitude to the world of business. He pioneered the Southern District’s approach to corporate crime. When his prosecutors

ecific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, con

ew York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7433, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: Q:

Adhering to this binding authority, this Court thus concluded (and continues to conclude) that the NPA does not bind the U.S. Attorney's Office for the Southern District of New York. It thus provides Maxwell no defense in this case even if it would otherwise cover the conduct charged in the new counts in the S2 superseding indic

ierre-Louis, No. 16 CR 541 (CM), 2018 WL 4043140, at *6 (S.D.N.Y. Aug. 9, 2018); United States v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *8 (W.D.N.Y. May 8, 2014); United States v. Sensi, No. 3:08-CR-253 (WWE), 2010 WL 2351484, at *3 (D. Conn. June 7, 2010). The sex trafficking charges are theref

ons. The Court disagrees for two independent reasons. First, under controlling Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New York. Second, it does not cover the offenses charged in the S1 superseding indictment. 3 EFTA00020263 --- PAGE BREAK --- Case 1:20-cr-00330-AJN

PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 4 of 34 A. The non-prosecution agreement does not bind the U.S. Attorney for the Southern District of New York United States Attorneys speak for the United States. When a U.S. Attorney makes a promise as part of a plea bargain, both contract principles and d

MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: Q.

ecific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, con

jurisdiction of his choosing (Le., the one to which he chose to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12

f 10 Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 2 BACKGROUND A. Overview On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 159