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EFTA01731277EFTA01731282
Case File
efta-01731278DOJ Data Set 10Other

EFTA01731278

Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01731278
Pages
4
Persons
0
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
AW PAIPARCFNIFNT CFNCITIVF Tactical Intellige FBI New Yor 19 January 2022 SOD-NY-3027571-INTELPRODS (U) LAW ENFORCEMENT SENSITIVE: The information marked (UHLES) in this document is the property of the Federal Bureau of Investigation (FBI) and is for internal use within the FBI only. Distribution outside the FBI without FBI New York's authorization is prohibited. Precautions should be taken to ensure this information is stored and/or destroyed in a manner that precludes unauthorized access. Information bearing the LES caveat may not be used in legal proceedings without first receiving authorization from the originating office. Recipients are prohibited from subsequently posting the information marked LES on a website on an unclassified network. (U) Executive Summary (UHLES) FBI New York C-20 is investigating Ghislaine Maxwell in a child sex trafficking investigation based on information regarding several victims reportedly sexually abused by Jeffrey Epstein and Ghislaine Maxwell in the mid-late 1990s to the early 2000s. The trial for Ghislaine Maxwell started on 29 Novem - defense witnesses on 11 December 2021. his TIR addresses FBI New York Criminal Divisio Crimes Against Children. • (U) Substantiation UNCLASSIFIEDI/LAW ENFORCEMENT SENSITIVE EFTA01731278 (U/NOUO) association with Maxwell. (U//FOUO) Black book reference U As o December 2021 UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE 2 EFTA01731279 (U) Biographical Information (U) Investigative/Intelligence Gaps UNCLASSIFIED// FOR OFFICIAL USE ONLY (U) Source Summary Statement (U) Reporting in this Tactical Intelligence Report was derived primarily from TECS (Treasury Enforcement Communications System). All the secured information was collected between 13 December 2021 and 16 December 2021. The reporting was current as of 19 January 2022. UNCLASSIFIEDI/LAW ENFORCEMENT SENSITIVE 3 EFTA01731280 (U) Consumers: (U) Approval: telli&'ence Report. Please direct comments and queries to UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE 4 EFTA01731281

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize 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

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States for illicit purposes. Epstein and Brunel allegedly housed the models in apartments located at

States for illicit purposes. Epstein and Brunel allegedly housed the models in apartments located at 2 Larry Visoski or "Lawrence P. Visoski" is Epstein's longtime pilot. EXHIBIT: TIMELINE OF PAYMENTS TO (OR ON BEHALF OF) POTENTIAL CO-CONSPIRATORS (PAYMENTS > $10,000) 1)xli 12/4/2013 lil NI I I( I \In N kut MC Model Management' k \10( \I $25,000 BENEFICIARY B %NE TD Bank BENEFICIARY WIRING ACCOUNT ACCOUNT # Jeffrey Epstein WIRING ACCOUNT # IN IRE DETAILS/ INSTRUCTIONS N/A 12/10/2013 MC2 Model Mana • ement $29,440 SunTrust Bank Jeffrey Epstein N/A 12/11/2013 Larry Visoski $225,000 Bank of America Jeffrey Epstein N/A 12/20/2013 Visoski $16,676 Bank of America Jeffrey Epstein Petty cash 1/21/2014 MC Model Maim • ement $25,000 TD Bank Jeffrey Epstein N/A 1/21/2014 $14,000 JP Morgan Chase Jeffrey Epstein N/A 4/10/2014 301/66 owners Co ° $182,219 Citibank Jeffrey Epstein N/A 5/2/2014 301/66 Owners Corp $50,000 Citibank Jeffrey

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