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From: ' (USANYS)" <1 To: Nicolas CASSART Cc: • " " )" , Nicolas BOULAY Subject: RE: SDNY Investigation Date: Mon, 08 Mar 2021 23:41:26 +0000 Attachments: 2020-07-3 L_GM,_signed_protective_orderidocketed).pdf Thank you both for your time on Friday. We very much appreciate it. As discussed, attached please find the protective order entered by the judge presiding over the case here. We are happy to speak again whenever best for you both. We look forward to hearing from you. Best, From: Nicolas CASSART • Sent: Wednesday, March 03, 2021 1:00 PM To: (USANYS) Cc: >; Subject: RE: SDNY Investigation No problem. Best. Nicolas De: (USANYS) < Envoyé : mercredi 3 mars 2021 18:56 À : Nicolas CASSART Cc : ) ": >; BOULAY Objet : RE: SDNY Investigation With apologies — are you available to speak at 17:30 instead? Alternatively, we are available before 16:00 Friday. Best, >; Nicolas BOULAY .:1 >; Nicolas From: (USANYS) Sent: Wednesday, March 03, 2021 12:37 PM To:
Persons Referenced (4)
“...Thanks very much, and looking forward to speaking with you. Best, Assistant United States Attorney United States Attorney's Office Southern District of New York One S...”
United States Attorney“...Thanks very much, and looking forward to speaking with you. Best, Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew...”
Ghislaine Maxwell“...ing the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to speak with you this week. Are you available fo...”
Jeffrey Epstein“...am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to spea...”
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EFTA DisclosureRelated Documents (6)
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF 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 Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to the defendant's letter and submission of July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today, including as recently as this morning. The Government and defense counsel have come to an agreement on much of the proposed protective order. However, the parties
Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY,
From: [=. To: ' Cc: ' Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 Date: Fri, 26 Nov 2021 19:54:50 +0000 Inline-Images: image001.png Just checking back on this. Thx! From Sent: Friday, November 26, 2021 10:34 AM To: I= '; Cc: Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL FRIDAY, NOVEMBER 26, 2021 Awesome, thanks. Are we able to provide a time if I also include the following? 9:30 a.m. — Jury charge followed by opening statements in U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). From: Sent: Friday. November 26.2021 10:26 AM To: Cc: Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 I don't think so. From
Subject:
From: To: Subject: - u is airs ews ne Ing e nes ay, u y 29, 2020 Date: Wed, 29 Jul 2020 10:25:50 +0000 c Importan e: Normal Mobile version and searchable archives available at fbi.bulletinintelligence.com. 1B1 News Briefing TO: THE DIRECTOR AND SENIOR STAFF DATE: WEDNESDAY, JULY 29, 2020 6:30 AM EDT TODAY'S TABLE OF CONTENTS LEADING THE NEWS • Barr Spars With Democrats At Contentious House Hearing. • Barr Says Democrats Have Tried To "Discredit" Him. • Barr Says Bash Investigating "High Number Of Unmaskings" During Obama Administration. PROTESTS • Memo Reveals Federal Agents Sought Role In Suppressing Protests Since Start. • New Mexico Governor Addresses Concerns About Federal Agents In Albuquerque. • Report: US, Oregon In Talks About Pulling Agents From Portland. • Portland Fines Federal Government For Unpermitted Fence Outside Courthouse. • US Park Police Head: Decision To Clear Protesters Not Linked To Trump "Photo Op." • Hundreds Of Cases Involving LAPD Off
Subject: rc
From: To: Cc: Subject: rc tA5I yu suon Date: Tue, 21 Sep 2021 22:00:22 +0000 Hi Neithe nor I could locate these exact records in discovery, so I've added them to the pending production folder. Thanks! From: Sent: Tuesday, September 21, 2021 12:14 PM To: Cc: Subjec : : ues ion Could you please double check that we've already produced the attached records in discovery? For any record you can't easily verify that we've already produced, please add it to the next production. Thanks! From: Sent: Tuesda Se •tember 21 2021 12:09 PM To: Cc: Subjec : : • •ues ion I ran travel for both Maxwell and Epstein between 1/1/1997 to 2/1/2000. After reviewing the travel details, the dates that correlate or are near the dates listed for Mre listed below. These are listed as INBOUND records. Jeffrey Epstein: • 12/11/1999 • 1/21/2000 Ghislaine Maxwell • 6/23/1997 • 8/6/1997 • 7/20/1998 • 7/24/1998 • 12/18/1999 • 1/21/2000 EFTA00075870 I included 6/23/1997 and 8/6/199
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
LBUCmaxl
120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt
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