EFTA01653769

EFTA Document EFTA01653769

Maxwell AUSA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------x UNITED STATES OF AMERICA : -v.- : S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, : Defendant. : ---------------------------------------------------------------x THE GOVERNMENT’S SENTENCING MEMORANDUM DAMIAN WILLIAMS United States Attorney Southern District of New York Attorney for the United States of America Maurene Comey Alison Moe Lara Pomerantz Andrew Rohr

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 14, 2021 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully submit this joint letter to provide the Court with a list of names, places, and relevant entities, for purposes of examining prospective jurors during voir dire. This letter is respectfully requested to be filed under seal to protect the privacy of witnesses and third parties. I. List of Names The following is a list of names that jurors may hear at trial: • Juan Alessi • Maria Alessi • • Janusz Banasiak • • Daniel Besselsen • • • • Michael Buscemi EFTA00040231 Page 2 • • Tracy Chappell • • Dr. Park Dietz

Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 1 of 45

Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 1 of 45 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC //: DATE FILED: 4/29/22 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, Circuit Judge, sitting by designation: In 2020, the Defendant Ghislaine Maxwell was indicted for her participation in a scheme to entice, transport, and traffic underage girls for sexual abuse by and with Jeffrey Epstein, her longtime companion. The Government at trial presented extensive witness testimony from multiple victim witnesses and others, as well as corroborating documentary and physical evidence. The testimony and other trial evidence established the Defendant's role in grooming and recruiting underage girls and using the cover of massage to perpetrate sexual abuse. Following the thirteen-day trial, the Court submitted to the jury the six counts in the Indict

Extensive FBI & Palm Beach Police Investigation Links Jeffrey Epstein to Underage Sexual Abuse, Payments, and High‑Profile Associates

The compiled documents provide a wealth of actionable intelligence: detailed victim and witness statements describing under‑age massages and sexual assaults; financial transaction records (cash paymen Victims (girls aged 14‑17) were recruited with promises of $200‑$300 per massage and were repeatedly Trash pulls from 358 El Brillo Way yielded message books containing names, dates, phone numbers, a

Maxwell 4.29.22

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, –v– Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) OPINION & ORDER ALISON J. NATHAN, Circuit Judge, sitting by designation: In 2020, the Defendant Ghislaine Maxwell was indicted for her participation in a scheme to entice, transport, and traffic underage girls for sexual abuse by and with Jeffrey Epstein, her longtime companion. The Government at trial presented extensive witness testimony from multiple victim