U.S. Department of Justice
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U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 4, 2021 VIA CERTIFIED MAIL Ghislaine Maxwell (Reg. No. 02879-509) MDC Brooklyn Metropolitan Detention Center P.O. Box 329002 Brooklyn, NY 11232 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) The password for the disc containing discovery materials pertinent to Ghislaine Maxwell (02879-509) is Very truly yours, AUDREY STRAUSS United States Attorney by: sl Assistant United States Attorneys EFTA00077346
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Subject: Fw: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
Subject: Fw: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS Date: Mon, 03 Aug 2020 15:51:10 +0000 Importance: Normal Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf; Ghislaine_Maxwell_Indictment_PR.pdf Inline-Images: image001.png Hi who should we include for this release in the monthly news bulletin? ublic Affairs Specialist FBI New York Sent: Thursday, July 2, 20201:20 PM Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS UNITED STATES ATTORNEY'S OFFICE Southern District of New York GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse Additionally Charged With Perjury in Connection With 2016 Depositions Audrey Strauss, the Acting United States Attorney for the Southern District of New York, Will
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mono Building January 28, 2021 BY ECF & ELECTRONIC MAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's order dated January 26, 2021 providing the Government with an opportunity to respond to the defendant's proposed redactions to its pre-trial motions filed on January 25, 2021. The Government notes at the outset that the defendant has not proposed any redactions to certain motions filed on the docket. (Motions 5, 8, 9, & 12; Dkts. 119-126). The Government agrees that no redactions are necessary as to those particular motions. The Government agrees with the defendant's proposed redactions to the remaining pre-trial motions for the following reasons: EFTA000658
UNITED STATES DISTRICT COURT
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
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Moll° Building One Saint Andrew's Plaza New York. New York 10007 December 17, 2020 BY FEDERAL EXPRESS MDC—Metropolitan Detention Center Legal Department 80 29th Street Brooklyn, NY 11232 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Enclosed is discovery pertinent to the following inmate: • Ghislaine Maxwell: 02879-509 Please allow her access to the materials enclosed. by: Enclosure Very truly yours, AUDREY STRAUSS Acting United States Attorney Assistant United States Attorneys EFTA00078333
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-2413, Document 40, 08/20/2020, 2913550, Page2 of 74 Table of Contents Table of Authorities iii Introduction 1 Jurisdictional Statement 2 Issues Presented 3 Statement of the Case and the Facts 3 The defamation action and the Protective Order 3 The motion to unseal and the first appeal 6 The remand, the arrest,
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 2, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York, N Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Mor an and Foreman, P.C. Denver, CO Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM 000174967 through SDNY_GM_ 00328863. The password for the drive is The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case.' This letter is itself designated as "confidential," because it includes i
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