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efta-efta00078124DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x • UNITED STATES OF AMERICA, • AFFIDAVIT OF CERTIFICATION PURSUANT TO LOCAL CRIMINAL RULE 16.1 GHISLAINE MAXWELL, • 20 Cr. 330 (MN) Defendant. x • STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK ) SS.: pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: I. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's request to extend the deadline for the production of documents extracted from electronic devices seized from Jeffrey Epstein (the "Production") from November 9, 2020 to November 23, 2020, and

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00078124
Pages
2
Persons
3
Integrity

Summary

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x • UNITED STATES OF AMERICA, • AFFIDAVIT OF CERTIFICATION PURSUANT TO LOCAL CRIMINAL RULE 16.1 GHISLAINE MAXWELL, • 20 Cr. 330 (MN) Defendant. x • STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK ) SS.: pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: I. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's request to extend the deadline for the production of documents extracted from electronic devices seized from Jeffrey Epstein (the "Production") from November 9, 2020 to November 23, 2020, and

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, AFFIDAVIT OF CERTIFICATION PURSUANT TO LOCAL CRIMINAL RULE 16.1 GHISLAINE MAXWELL, 20 Cr. 330 (MN) Defendant. x STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK ) SS.: pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: I. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's request to extend the deadline for the production of documents extracted from electronic devices seized from Jeffrey Epstein (the "Production") from November 9, 2020 to November 23, 2020, and that the parties have been unable to reach agreement. 3. In particular, on November 4, 2020, the Government asked defense counsel whether they would consent to a two-week extension to allow adequate time for an outside vendor to finish bates stamping and downloading the Production. On the morning of November 6, 2020, EFTA00078124 defense counsel indicated that they would consent to the requested extension on four conditions. First, the defense asked that the motion deadlines in this case be extended by three weeks. Second, the defense asked that the Government provide the defendant with a laptop on which to review her discovery at the Metropolitan Detention Center. Third, the defense asked that the Government provide the defense with the names of the three Minor Victims listed in the Indictment by November 23, 2020. Fourth, the defense asked that the Government provide the defense with all Jencks Act material by November 23, 2020. In response, the Government agreed to the first two conditions, but did not agree to the second two conditions. Accordingly, the parties have been unable to reach agreement on the requested two-week extension of the deadline for the Production. 4. I hereby certify that the foregoing statements made by me are true. Dated: New York, New York November 6, 2020 Assistant United States Attorney Telephone :- 2 EFTA00078125

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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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