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Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 1 of 161 EXHIBIT E EFTA00084366 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 2 of 161 New Jeffrey Epstein accuser says he molested her at 13, told her to wear children's underwear January 18.2020 I 12-04am I Updated Jeffrey Epstein A woman claiming she was Jeffrey Epstein's "first-known victim" says she was sexually abused by the now-dead pedophile — who called himself her "Godfather" — when she was 13 years old. Jane Doe met Epstein and his friend, Ghislaine Maxwell. in the summer of 1994 at Michigan's Interlochen Arts Camp, where she was In voice training, according to newly filed court papers suing Epstein's estate and Maxwell. The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all the while grooming her for abuse, the Manhattan federal court suit says. Epstein "started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of letting Doe pick out clothes she wanted to wear, Epstein Insisted that she pick out and wear little children's cotton underwear," the suit says. EFTA00084367 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 3 of 161 She was first allegedly abused in a pool house that same year when Epstein pulled her onto her his lap and began masturbating — claiming this was what "professionals" did. The attacks escalated, the court papers claim. The financier would regularly sexually assault her and force her to perform sex acts in Palm Beach, New York City and his New Mexico ranch, always traveling to the locations on his private plane dubbed the "Lolita Express." At 16, Epstein put Doe up in one of his apartments in New York City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had a boyfriend. Doe replied that she did not," the lawsuit reads. "Epstein responded that when she did have a boyfriend she would want the sex to be 'good' and that she should 'get it over with already; meaning lose her virginity." "Despite Doe's resistance, Epstein then pushed Doe down onto her stomach and raped her. From that point forward for several years in New York. Epstein raped Doe on multiple occasions," the papers claim, noting Maxwell was often present when the abuse took place. The court papers also claim Epstein introduced her to President Trump when she was 14 years old, allegedly elbowing Trump and saying, "This is a good one, right?" "Trump smiled and nodded in agreement." the suit states. A spokesperson for the president did not immediately return a request for comment. Doe is suing Epstein's estate, alleging sexual assault, sexual battery, false imprisonment and other charges. Her complaint joins over a dozen filed by other women claiming they were trafficked and abused by the multi-millionaire. Epstein was found dead in his jail cell in August while awaiting trial for sex trafficking. His death was officially ruled a suicide by hanging. Lawyers for Maxwell and Epstein's estate did not immediately return emails. FILED u, • COURTS. DONALD TRUMP. GHISLAINE MAXWELL JEFFREY EPSTEIN, LAWSUITS, PEDOPHILES, SEXUAL ABUSE, I/18/20 EFTA00084368 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 4 of 161 Epstein, Maxwell wanted me to have surrogate baby Oi r Hypo, Former teen "sex slave says she finally fled Jeffrey Epstein and Ghislaine Maxwell after three years, when they asked her, at age 19. to bear their surrogate baby. • Epstein's former gal pal sues his estate EFTA00084369 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 5 of 161 The latest creepy allegation bynho has also accused Epstein of pimping her out to Prince Andrew when she was just 17, was revealed by her attorney, Bradley Edwards, in his new memoir, "Relentless Pursuit." "It was the final straw," Edwards writes in an excerpt published in the Daily Mail. "She knew she had to escape." FILED UNDER GHISLAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00084370 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 6 of 161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says O dailvmaitco.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-hroped-16-vear-old-qid-naked-massaae-victims- lawyer-says.html March 28, 2020 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage while Jeffrey Epstein watched,' lawyer who dedicated his life to nailing Prince Andrew's paedophile friend claims in new book • Ghislaine Maxwell, 58, allegedly sexually assaulted i6-year-old • It reportedly happened at paedophile Epstein's 7,500-acre New Mexico ranch • A lawyer for more than 20 of Epstein's victims has made the allegation By Mark Hookham For The Mail On Sunday Published: 18:03 EDT, 28 March 2O2O I Updated: 15:59 EDT, 2 July 2O2O • • • e-mail • 713 shares Socialite Ghislaine Maxwell allegedly groped a teenage girl during a naked massage while paedophile Jeffrey Epstein watched, a new book claims. Maxwell, 58, allegedly sexually assaulted 16-year-old at Epstein's 7,500-acre ranch in New Mexico, according to the book by Bradley Edwards, a lawyer for more than 2O of Epstein's victims. The book, from which we are summarising stories in The Mail on Sunday, details Maxwell's alleged role in recruiting and grooming underage girls for Epstein. According to some accounts, she was even involved in some of the abuse herself. 1/6 EFTA00084371 EFTA00084372 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 8 of 161 It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for months, has never been charged with any wrongdoing. She has always maintained that allegations against her are abhorrent and untrue. The book also claims that: Maxwell, Epstein's ex-girlfriend, was at the wedding of former US President Bill Clinton's daughter Chelsea in July 2010, a year after Epstein was released from jail as a convicted sex offender; She loved to take nude photographs of girls and allegedly took many of the pictures displayed on the walls of Epstein's mansions. According to one witness, she felt `indebted' to Epstein for helping her following the mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell; Epstein `wasn't beyond killing someone' to keep his sex addiction alive, the witness claimed. now 4o, helped keep Epstein behind bars last July after giving evidence about her ordeal as a teenager during a bail hearing. The financier was found dead in his cell the following month. is now suing Epstein's estate and Maxwell in the New York district court for damages. According to Lestimony, detailed in the book, she was flown to the financier's vast Zorro Ranch after he offered to pay for her to attend a summer educational programme in Thailand. 316 EFTA00084373 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 9 of 161 1 Prince Andrew pictured with his arm around Queen's 'favourite son' of having sex with her who has accused the 416 EFTA00084374 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 10 of 161 5/6 EFTA00084375 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 11 of 161 616 EFTA00084376 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 12 of 161 When will feds arrest Jeffrey Epstein `fixer' Ghislaine Maxwell? May 28. 2020 I 4:l7pm I Updated Jeffrey Epstein and Ghislaine Maxwell Pattick McMullan via Getty Images Nine months after Attorney General William Barr warned that Jeffrey Epstein's co-conspirators "should not rest easy?' the pedophile's alleged madam. Ghislaine Maxwell. remains at large — and is using a potential criminal investigation to thwart civil action against her. Maxwell is currently a co-defendant in several civil cases brought by alleged Epstein sex-trafficking victims. Among them i who claims in her suit against Maxwell and the proprietors of Epstein's estate that she was lured to his New Mexico ranch as a teenager and sexually abused by the pair. According to the suit, Maxwell allegedly forcer to undress in view of Epstein after promising to give her a massage. "Maxwell touched intimate parts of body against her will for the sexual benefit of Maxwell and Epstein." the suit states. "Maxwell exposer breasts and groped her," it adds. EFTA00084377 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 13 of 161 Through her attorneeas sought to depose Maxwell and have her respond to written questions related to the alleged sexual abuse. gShislaine Maxwell Paul Brumouge:Patnck McMullan 'Pa Getty Images But the former fixer has successfully dodged a grilling in the case, citing an ongoing criminal investigation into co- conspirators of Epstein — all while not admitting she herself is being probed by the feds. An investigation into Epstein's accomplices was alluded to by Barr days after the pedophile's suicide in a Lower Manhattan lockup, and has been mentioned repeatedly by the US Attorney's Office in New York, according to court filings. A spokesperson for the Southern District of New York declined to comment on the investigation. Maxwell's attorney cited the investigation in an effort to block her testimony in theMase. SE A Ghislaine Maxwell wins questioning delay in sexual battery suit "The Southern District of New York has publicly and repeatedly announced its 'ongoing' criminal investigation into alleged Epstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investigation could impair her Fifth Amendment privilege against self-incrimination: added her attorney, Laura Menninger. attorney, David Boies, noted in his response that Maxwell has not publicly admitted she herself is the center of a federal investigation, but is nevertheless using it to shield herself. "Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators. the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation," Boies wrote. Epstein investigators contacted by 'dozens' since his death EFTA00084378 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 14 of 161 "When Plaintiff's counsel asked Maxwell's counsel for information about the criminal investigation during their meet and confer, Maxwell's counsel refused to provide any details," he added. Freeman agreed Maxwell could potentially incriminate herself by giving a deposition and ordered that she not be required to sit for one as part of the suit. the $570 single speed tokyobike Maxwell, who is apparently in hiding, has not given testimony or a public statement since Epstein's arrest and suicide. Attorneys foiMand Maxwell did not immediately respond. rut UN :u GHISLAINE MAXWELL JEFFREY EPSTEIµ LAWSUITS, SEX TRAFFICKING, WILLIAM BARR, 5/28/20 EFTA00084379 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 15 of 161 Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey Epstein, claims friend dailymail.co.uk/femailiarticle-8384165/Ghislaine-Maxwell-felt-no-guilt-procuring-aids-JeffrerEostein-claims- friend.htrnl June 3, 2020 • US_based Christina Oxenberg, 57, has spoken out in new documentary • Claims Ghislaine Maxwell felt 'no guilt' in procuring girls for Jeffrey Epstein • reveals she 'feared for her life' at the hands of Epstein and Maxwell • Who Killed Jeffrey Epstein? premieres at iipm Saturday 6th June on Quest Red and dplay • • • e-mail • 592 shares Ghislaine Maxwell felt no guilt in procuring girls for ,Jeffrey Rpsteia to satisfy his 'incredible sex drive,' Prince Andrew's distant cousin has claimed - adding that 'if anything, she was proud.' In Quest Red's new true crime documentary special Who Killed Jeffrey Epstein? it is alleged that socialite Ghislaine Maxwell - Epstein's former partner - procured girls for Epstein to 'satisfy his insatiable sex drive.' Socialite writer Christina Oxenberg, 57, from the US, who is a friend of Maxwell, notes that Maxwell felt no guilt in procuring girls for his pleasure. 'She says he has an incredible sex drive, he has to have three orgasms a day, so I help him out by bringing in the females,' explains Christina. 'She felt no compunction about telling me this, if anything she was proud.' Christina is the daughter of a Serbian princess and sister of the Hollywood actress, Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex cult run by its leader, Keith Raniere, after an 18 month battle. India was among the women he recruited under the guise of offering them self-help courses. Her actress mother pulled her out of it in 2018 after fighting relentlessly in the press to expose Raniere and his practices. 1112 EFTA00084380 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 16 of 161 Christina Oxenberg claims that Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey Epstein to satisfy his 'incredible sex drive' in Quest Red's new true crime documentary special Who Killed Jeffrey Epstein? Jeffrey Epstein and Ghislaine Maxwell attend de Grisogono Sponsors The 2005 Wall Street Concert Series Benefitting Wall Street Rising on March 15, 2005 in New York 2/12 EFTA00084381 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 17 of 161 aged 17 at Ghislaine Maxwell's townhouse in London, Prince Andrew and Britain on March 13, 2001 The documentary dives headfirst into the Epstein story, examining the mysterious circumstances surrounding the financier's death, aiming to answer one vital question: Did Epstein take his own life, or was it something much more sinister? On loth August 2019, disgraced American financier Jeffrey Epstein was found dead in his New York prison cell as he awaited his trial on sex trafficking charges. 3112 EFTA00084382 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 18 of 161 It was a dramatic end to one of the world's most mysterious billionaires, with the coroner officially ruling the cause of death as suicide. RELATED ARTICLES • Previous • • Next The Queen's official birthday will he marked with a 'small'... flops I duel it again! Boyfriend ends up with black hands... From a luxury Hotel Chocolat hamper to personalised. . Meghan Markle detailed her experience with racism and... But it wasn't long before the circumstances surrounding Epstein's death were called into question. Having being linked with some of the world's most influential and powerful celebrity figures — including Prince Andrew, Donald Trump and Bill Clinton — some believe that Epstein may have been murdered. 4/12 EFTA00084383 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 19 of 161 5/12 EFTA00084384 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 20 of 161 6/12 EFTA00084385 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 21 of 161 7/12 EFTA00084386 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 22 of 161 8/12 EFTA00084387 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 23 of 161 9/12 EFTA00084388 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 24 of 161 10/12 EFTA00084389 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 25 of 161 11112 EFTA00084390 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 26 of 161 12112 EFTA00084391 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 27 of 161 go Washington post Democracy Dies in Darkness Ghislaine Maxwell, longtime associate of Jeffrey Epstein, charged in sex abuse case By Shayna Jacobs and Devlin Barrett July 2, 2020 at 3:14 p.m. MDT NEW YORK — Ghislaine Maxwell, a longtime confidante of sex offender Jeffrey Epstein, was arrested Thursday in New Hampshire on charges she recruited and groomed underage girls for abuse by her then-boyfriend, officials said. Support our journalism. Subscribe today. 9 A grand jury indictment unsealed Thursday charged Maxwell, daughter of the late media tycoon Robert Maxwell, with perjury and conspiring to entice minors to travel to engage in sex acts. Maxwell has been under investigation for months as a possible accomplice to Epstein's history of sexual abuse of underage girls. Epstein, who committed suicide while in federal custody last summer, dated Maxwell for years, and the indictment charges she played a key role in grooming girls for him to abuse. AD EFTA00084392 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 28 of 161 Beginning in at least 1994, the indictment alleges, Maxwell "enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods." Acting U.S. Attorney Audrey Strauss called the sex abuse described in the Maxwell case "the prequel" to the charges they lodged last year against Epstein covering alleged acts of abuse in the early 2OOOS. "Maxwell played a critical role in helping Epstein to identify, befriend, and groom minor victims for abuse," said Strauss, who oversees the federal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, said their clients were elated by the development. "It's just an enormous step," he said. AD EFTA00084393 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 29 of 161 Boies said he thinks Maxwell will be under "tremendous pressure to cooperate" as she looks for ways to shave time off what may be a significant prison sentence. Maxwell could potentially help prosecutors shed light on Epstein's dealings with other wealthy and influential people who may have had encounters with underage victims, he said, adding, "There were a lot of people with a lot of public stature ... who were involved with Epstein." "The pain [Maxwell] has caused will never go away but today is a step toward healing," McCawley added in a statement, praising prosecutors on the case for their "unrelenting courage." U.S. Magistrate Judge Andrea Johnstone ordered Maxwell to remain in custody at a brief hearing via videoconference in federal court in New Hampshire, where another of her attorneys, Lawrence Vogelman, did not seek an immediate bail hearing because her lawyers plan to make those arguments after she is transferred to New York. AD EFTA00084394 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 30 of 161 In a court filing, prosecutors said Maxwell should stay behind bars pending trial because she might flee given her "extensive international ties," noting she has citizenship in two countries and three passports in her name. Maxwell, 58, faces the possibility of 85 years in prison if convicted and has "absolutely no reason to stay in the United States," prosecutors argued in the filing. Prosecutors also said the Epstein investigation is not over and asked any victims or witnesses to Epstein's abuse of minors to contact the FBI. William Sweeney, head of the FBI's New York office, called Maxwell "one of the villains" of the Epstein saga and said that agents kept close tabs on her after she "slithered away to a gorgeous property in New Hampshire." AD The indictment charged that Maxwell "would try to normalize sexual abuse for a minor victim by, among other things, discussing sexual topics, undressing in front EFTA00084395 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 31 of 161 of the victim, being present when a minor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein." One of the victims was 14 years old when Epstein and Maxwell began grooming her for sex acts with Epstein, according to the indictment. The victims were groomed or abused at a number of Epstein's luxurious homes, including his sprawling Upper East Side townhouse in Manhattan, an estate in Palm Beach, Fla., a ranch in Santa Fe, N.M., and Maxwell's home in London, according to the charges. "Minor Victim-2," according to the indictment, was under 18 when she was flown to New Mexico at Epstein's invitation. "In New Mexico, Maxwell began her efforts to groom Minor Victim-2 for abuse by Epstein by, among other things, providing an unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless," the indictment charged. Maxwell is also accused of grooming and befriending a third victim, whom she met in London between 1994 and 1995. She allegedly encouraged that victim to give Epstein massages "knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages." The indictment also accuses Maxwell of lying in a deposition in 2016 when asked about these activities by a lawyer for one of Epstein's alleged victims, when she denied any knowledge of him engaging in sex acts with minors. When asked if Epstein had a scheme to recruit underage girls for sexual massages, Maxwell replied, "I don't know what you're talking about," the indictment says. EFTA00084396 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 32 of 161 AD Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and others in the deposition because the truth "was almost unspeakable — Maxwell enticed minor girls, got them to trust her, then delivered them into the trap that she and Epstein had set for them. She pretended to be a woman they could trust, all the while she was setting them up to be sexually abused by Epstein." Maxwell's arrest was first reported Thursday by NBC News. Epstein, 66, was a registered sex offender who was arrested last year on federal sex trafficking charges for alleged abuses of underage girls in New York and Florida. His suicide in a Manhattan federal detention center led to charges against two of his guards who were accused of failing to check on him in his cell in the hours before he was found hanging from a bedsheet. Epstein's ability to avoid a lengthy prison sentence has raised questions about whether the wealthy, politically connected sex offender — with ties to both President Trump and former president Bill Clinton — was able to manipulate state and federal officials to go easy on him. Years before his 2019 arrest, Epstein had resolved similar allegations with a plea deal involving state charges in Florida that allowed him to spend a little more than a year in jail and leave daily for work — an arrangement widely criticized as too lenient. As part of that deal, prosecutors agreed not to pursue cases against Epstein's associates who might have recruited girls for him. EFTA00084397 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 33 of 161 AD Gloria Allred, a lawyer representing more than a dozen of Epstein's alleged victims, said her clients hope Maxwell "will be accountable if the evidence presented in court proves beyond a reasonable doubt that she had a role in assisting and recruiting young girls to be sex trafficked and sexually victimized by Jeffrey Epstein." The investigation into Epstein's conduct continued after his jailhouse death and has ensnared Britain's Prince Andrew, another old friend of the late financier. Federal prosecutors complained earlier this year that Andrew has provided "zero cooperation" to authorities. One of Epstein's accusers, claims she was paid by Epstein for sexual encounters with the prince when she was 17. The prince has denied any wrongdoing. On Thursday, Strauss made clear prosecutors still want to talk to him. "We would welcome Prince Andrew coming in to talk to us," she said. "We would like to have the benefit of his statement." Epstein's alleged victims continue to pursue lawsuits against his estate, which is valued at hundreds of millions of dollars. EFTA00084398 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 34 of 161 METRO Ghislaine Maxwell leaves luxe life behind for tiny jail cell in Brooklyn Jory 7.2020 8 iliam I Jpdated . 1 1 i r ,—,--• .- -c" ,r--.---/ _ •---"--. .—^ ,--c ' ir_—•---/ ----- .----- .......--, ,—r— .---'—' .--.----" .--, ---- .- -c- ' -r - ` __,_. Y- ..---•--" .-- - 4,_-.--• *---' r - ^ •--- ..--e- - • .-- - _ ..---,- ..--.---' -.-^ _-.--. ...-...---• -,-- ....--.-- ...-,-^ --1 --- ti l l i i i gra LUC Stephen Yang From beef bourguignon to beef jerky: Ghislaine Maxwell has traded in her palatial New Hampshire cabin for stripped-down confinement at Brooklyn's Metropolitan Detention Center. The Oxford-educated British socialite had been lying low in a million-dollar New Hampshire hideaway featuring a cathedral ceiling, a massive floor-to-ceiling stone fireplace and a gourmet kitchen, according to the home's listing. Jeffrey Epstein's alleged right-hand woman cooked stews for herself in a kitchen with two ovens, a six-burner stove and a luxury refrigerator. Maxwell, 58, on Monday was transferred to the city's largest federal jail, where she is expected to be kept in a 1O-foot-by-12- foot cell. The notorious facility is in the midst of a lawsuit that has sounded the alarm over its potential to foster a dangerous coronavirus outbreak. It's the same facility where officers last month pepper-sprayed inmate Jamel Floyd to death. EFTA00084399 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 35 of 161 In January 2019, inmates went freezing for weeks when an electrical fire knocked out power in the building, an environment described as a "humanitarian crisis." The Interior of the Metropolitan Detention Center Doi Maxwell will be given a T-shirt and other basic clothing at the MDC along with a thin mattress, pillow and blanket. She may be allowed to have an approved religious medallion or book, such as the Bible — but cannot have any other personal possessions. After schmoozing among the global elite, Maxwell has apparently had a difficult time socializing with her fellow inmates. One inmate at a New Hampshire jail where she was briefly held reportedly called her a "snooty b—h." Injuring a high-profile inmate like Maxwell "would be a badge of honor." former MDC warden Cameron Lindsay said. "You go from living a life like Maxwell to all of a sudden being in a situation where you're being strip-searched and having people look into your body cavities," Lindsay added. FIlf I) (1,4:11-;1 BROOKLYN. GNISLAINE MAXWELL, JAIL JEFFREY EPSTEIN, 7/7/20 EFTA00084400 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 36 of 161 VIDEO LIVE SHOWS 2020 ELECTIONS CORONAVIRUS • • For Ghislaine Maxwell, Epstein's alleged recruiter, a private battle has become a public reckoning She has been charged with conspiring with the Infamous sex offender. By Jams mu and Pelt Nbadta My 10.2020.2:06AM • mm rrad 11 ir • Obtains Maxwal behind bars as now details emerge Jeffrey Epstein's ex-girlfriend Ghatoine Maxwell is accused of facilitating Epstein's sex crimes by ',sting him Mafia, groom and ultimately abuse three unnamed teens between 2994 and 1997. Ghislaine Maxwell, a British socialite and longtime companion of disgraced financier Jeffrey Epstein, is facing a reckoning for her alleged role in facilitating Epstein's sexual abuse of young women. Federal prosecutors say Maxwell played a "key role" in a multi-state sex trafficking scheme, in which she not only allegedly "befriended" and later 'enticed and groomed multiple minor girls to engage in sex acts with Epstein, through a variety of means and methods," but was also, at times, "present for and involved' in the abuse herself. Maxwell is scheduled to appear before a federal judge in New York on Tuesday, where she Is expected to publicly address those allegations for the first time. But court filings make clear that Tuesday's hearing is only the latest chapter in long-running legal battles waged mostly out of public view. Maxwell has been named as a defendant in five lawsuits from alleged Epstein victims, and in at least three others, alleged victims identify her as Top Stories For Ghislaine Maxwell, Ep,stein's alleged recrulter.a private battle has become a public reckoning All 10 106AM Ex-officials say Trump administration didn't use pandemic 'playbooks Jul 29, 216 AM Congressman who refused to wmar a mask tests positive for COVID-I9 d Woman dead after attack by great white shark off Maine ()Oast M 18 2.08 PM Contentious S-hour House hearing with AG William Barr concludes F128, 2.12 PM • ■ EFTA00084401 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 37 of 161 la Jeffrey Epstein and Ghisking 'Worrell attend de Gosoyano Sponsors The 2005 Wail Street Concert Series Bersefitting Wall Street Rising. airh a Performance by Rod Stessort at Cipriani Wall Street on. more Patrick Mcmulan/Patfxk McMullan eta Getty Image. FILE But in lawsuits several of Epstein's alleged victims tell an entirely different story, one that often places Maxwell in a role that was central to their abuse. One anonymous victim, identified only as Jane Doe, alleged that Epstein and Maxwell "attempted to groom and mentor" her when she was just 13 years old. "They took her to movies, went shopping with her and lounged around Epstein's estate with her," Doe alleged in her complaint. "Epstein and Maxwell then started to make sexual references when they were with her." Ultimately, according to Doe's complaint, Maxwell "regularly facilitated Epstein's abuse of Doe and was frequently present when it occurred? + MORE: Ghislaine Maxwell given paper clothes at correctional center to avoid suicide attempt: Sources nd another anonymous alleged victim identified only as Doe 1000, have alleged that Maxwell not only recruited girls for Epstein but, in their cases, even participated in their abuse. alleged Epstein and Maxwell sexually abused her between 2000 and 2002 and claims that she was directed to have sex with some of their prominent friends alleged that Maxwell "groped her" and "touched intimate parts oflheri body against her will for the sexual benefit of Maxwell and Epstein"; Doe alleged "Epstein and Maxwell proceeded to sexually assault Jane Doe simultaneously and by forcible compulsion" and that Maxwell "forcibly penetrated Jane Doe with a sex toy." Maxwell has, in court filings, strenuously denied any such misconduct. "She absolutely denies that she participated in this or any other sexual abuse or trafficking or assault," her lawyer wrote in response a allegations, "and no court, judge or jury has ever determined that she has." EFTA00084402 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 38 of 161 o Jeffrey Epstein and Gensktine Maxwell mend on event in New York CS June 13,199S Patrick McMullan via GanY ;mars. ALE Following Epstein's arrest last July and his death in prison a month later, Maxwell's whereabouts became the subject of intense scrutiny. She sold her former residences In New York and London and shuttered her non-profit ocean conservation organization. Various press reports placed her in Massachusetts, California, France and Israel, and attorneys for several of Epstein's alleged victims struggled to locate her in order to serve their lawsuits. She was ultimately arrested by the FBI in Bradford. New Hampshire, where prosecutors say she was living at a 156-acre property, nicknamed "Tucked Away? Prosecutors are now arguing that Maxwell poses an "extreme" flight risk, citing her "three passports, large sums of money, extensive international connections." Maxwell is a citizen of the United States, United Kingdom and France, prosecutors said, and she has traveled abroad frequently within the last three years. Prosecutors also believe she possesses "significant sums of money," citing a government Investigation that identified "more than 15 different bank accounts held by or associated with the defendant from 2016 to the present, and during that same period, the total balances of those accounts have ranged from a total of hundreds of thousands of dollars to more than $20 million." + MORE: 'Truth and Lies: Jeffrey Epstein' Podcast As with Epstein, however, prosecutors have found the full extent of Maxwell's wealth difficult to determine. EFTA00084403 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 39 of 161 one of Epstein's primary "recruiters." claims that Maxwell, through her u ABC News Live attorneys, has repeatedly denied. 'Maxwell had no involvement in or knowledge of Epstein's alleged misconduct," one lawyer for Maxwell wrote earlier this year in her own lawsuit against the Epstein estate. + MORE: As feds continue to seek interview with Prince Andrew, Attorney General William Barr says Jeffrey Epstein probe marches on In court filings related to that lawsuit, in which she claimed that Epstein had "promised that he would indemnify, defend, and advance any expenses incurred by reason of my prior employment relationship with him and his affiliated businesses," Maxwell contended that she had "incurred substantial expenses defending myself against false accusations and investigations." She claimed to owe more than $318,000 to a criminal defense firm, more than $101,000 to a civil litigation firm, and more than $194,000 in security and relocation costs. The estate, according to court records, declined to reimburse the costs. 24/7 coverage of reeking news and trrc events According to Joshua Schiller of Boies, Schiller, Flexner, LLP, a firm that represents three Epstein's alleged victims who have filed civil suits against her. Maxwell has been at the forefront of the fight with Epstein's alleged victims long before her recent arrest. "(Maxwell' has been using this Court as a sword and a shield for many years." Schiller wrote in a filing earlier this year, "and she, Jeffrey Epstein, and their other co-conspirators have attempted to thwart their victims from obtaining justice for decades." ita Gn,ibine Mcomen of Soong Sodom in New Yak Ca% OK 18, 2016. Patnck McMullan via Getty Images. file Maxwell, 58, is the Oxford-educated daughter of Robert Maxwell, the larger than life publishing baron whose rags-to-riches story captivated England. She lived an extravagant life among the British elite until her father's business empire collapsed in the wake of his death. She fled to New York looking for a fresh start and was soon seen in the company of the mysterious multimillionaire Epstein. EFTA00084404 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 40 of 161 The defendant's financial resources appear to be substantial," prosecutors wrote, "and her numerous accounts and substantial money movements render her total financial picture opaque and indeterminate, even upon a review of bank records available to the Government." Brad Edwards, an attorney who represents several of Epstein's alleged victims, believes that there is still much more to learn about Maxwell. "I think that's the tip of the iceberg," Edwards told ABC News. "And I would expect the same thing that happened after Jeffrey Epstein was arrested. There's going to be a flood of calls and more information coming in' But her role in Epstein's story, he said, is already clear. "Ghislaine Maxwell created Jeffrey Epstein,' Edwards told ABC News. "She helped to create the monster that we later understood him to be." e Comments (89) Before You Go ONEWS ri 11 ■ These New Assisted Living Apartments Near Denver Are A Dream Come Truel You Should Research Assisted Living Communities Denver Seri& LotingtAssisted Living I Sponsored Find Out How Much Your Home is Worth in Denver Orchard I Sponsored These SUVs Are So Cool Ifs Hard to Believe They Cost Less Than $25K! Research Best New Crossover SUVs suvi Sponsored Signs of Ankylosing Spondylitis Could Be Easy to Ignore. Research Ankylosing Spondylitis Treatment Ankylosang Spondylies I Sponsored If You Like to Play, this Strategy Game is a Must-Have. No Install. 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People Adopt, Foster Pets as They Shelter in Place AARP I Sc0nsAced ABC News Network Privacy Policy I Your CA Privacy Rights ChIldren's Online Privacy Policy I Interest•Based Ads I About NI Ise Measurement Terms of Use Do Not Sell My Info Contact Us EFTA00084406 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 42 of 161 In a letter to a Florida state prosecutor related to Epstein's 2008 guilty plea, Epstein's attorneys describe his relationship with Maxwell as one of two "long-term intimate relationships" Epstein had in adulthood. They met through mutual friends in 1991. his attorneys said, and parted "amicably" in 2000 because "the demands of his work ... precluded a good married life with children." The same letter contains what purports to be a quote from Maxwell. in which she describes Epstein as a "thoughtful, kind, generous, loving man." Maxwell has asserted in court filings that she entered Epstein's employ in 1999, where she remained, despite the end of their romantic relationship. until at least 2006. Maxwell's only sworn testimony on the nature of her work for Epstein can be found in excerpts -- unsealed by a federal court last year -- of two 2016 depositions related to a defamation lawsuit filed a one of Epstein's alleged victims, who has accused Maxwell of recruiting her into Epstein's alleged child trafficking scheme, an accusation Maxwell denied. • O Truth and Lies: Jerre n a decade ago. mystenous I raT According to Maxwell's testimony, she was responsible for the staffing and management of Epstein's various properties. 'There were six homes," Maxwell said. "I hired assistants, I hired architects, I hired decorators, I hired cooks, I hired cleaners, I hired gardeners, I hired pool people, I hired pilots, I hired all sorts of people." "A very small part of my job," she added, "was from time to time to find adult professional massage therapists for Jeffrey." She denied, under oath, that she had ever hired underage girls to work for Epstein, assertions that are now the subject of perjury charges. "As far as I'm concerned, everyone who came to his house was an adult, professional person," Maxwell said. "I am not aware of teenagers who worked in his home.' EFTA00084407 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 43 of 161 'I'm no Cruella de Vil': Ghislaine Maxwell insists she is not an 'evil villain' O dailymail.co.uk/news/article-8513675/Im-no-Cruella-Vil-Ghislaine-Maxwell-insists-not-evil-villain.html July 11, 2020 • Maxwell says she is not the 'cartoon caricature of a villain' she is portrayed as • The 58-year-old is scheduled to appear before a judge in New York on Tuesday • She will be charged with procuring girls as young as 14 for Jeffrey Epstein • • • e-mail • 635 shares Defiant Ghislaine Maxwell has rounded on her accusers, insisting that her portrayal as a 'cartoon caricature of a villain' is utterly false. Friends say that the 58-year-old socialite, who is scheduled to appear before a judge in New York on Tuesday to be formally charged with procuring girls as young as 14 for Jeffrey Epstein — the serial paedophile and her former boyfriend — 'is no Cruella de Vil'. Referring to the glamorous but evil character from the Disney film One Hundred And One Dalmatians, one friend told The Mail on Sunday: 'This cartoon caricature of a villain she is being painted as is utterly untrue and false. 'This is a real human being with real feelings.' 1113 EFTA00084408 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 44 of 161 Ghislaine Maxwell, 58, has rounded on her accusers, insisting that her portrayal as a `cartoon caricature of a villain' is utterly false Breaking a year-long silence since Epstein's death, sources dose to Maxwell have gone on the offensive to put her side of the story. After a year during which she was neither seen nor heard, her allies now reveal how she intends to salvage her liberty and reputation against claims that she supplied depraved Epstein with young girls. Maxwell's allies have told The Mail on Sunday that she: • Is not the person who introduced billionaire Epstein to Prince Andrew; • Fears dying of Covid-19 while in prison; • Insists she and Epstein had not met in person for 15 years; • Weeps over friends who have lost jobs because of their association with her; • Has not had a haircut in a year and is being moved `from cell-to-cell' for her own safety. 2113 EFTA00084409 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 45 of 161 Maxwell is scheduled to appear before a judge in New York on Tuesday to be formally charged with procuring girls as young as 14 for Jeffrey Epstein — the serial paedophile and her former boyfriend The daughter of the late newspaper tycoon Robert Maxwell will make global headlines on Tuesday when she appears in court via remote link from her New York jail cell. She will be formally charged with sex offences between 1994 and 1997 and will plead not guilty to them all. Her lawyers will argue for her release from the high-security Metropolitan Detention Center in Brooklyn on £4 million bail, arguing that her life is in danger from coronavirus and 'multiple and credible' death threats. Maxwell, who is a long-time friend of Prince Andrew and who saw him most recently in 2019, was arrested at her £800,000 New Hampshire hideaway on July 2. Prosecutor Audrey Strauss condemned her as 'playing a critical role in finding and grooming victims', while scores of Epstein's victims claim that she acted as his 'madam', often driving from his £20 million mansion in Palm Beach, Florida, to nearby trailer parks to 'procure' vulnerable young girls for the paedophile. But last night a source close to Maxwell hit back, saying: 'Ghislaine is no Cruella de Vil. She is being portrayed as this evil character and a cartoon-like villain but she is nothing like that. She is a real person and is determined to prove her innocence despite the fact that she has been characterised as some sort of monster.' Maxwell insists that her romance with Epstein ended in 2001 and that she did not see him in person after 2005 when she was photographed with him at a party. At the time, she was dating billionaire Gateway computer founder Ted Waitt. 3/13 EFTA00084410 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 46 of 161 @Clive CooteAVaft Disney/Cob:it REX Shutte rs took A source close to Maxwell hit back, saying: 'Ghislaine is no Cruella de Vil'. Pictured: The character played by Glenn Close in the 1996 film 101 Dalmatians 'The reality is that Ghislaine's relationship with Epstein ended in 2001,' says the friend. 'Starting in late 2002, early 2003, she was dating Ted and she loved him deeply. Epstein kept trying to woo her back but she wasn't interested.' However, the friend adds, Maxwell continued to work for the twisted tycoon. 'She hired Epstein's pool guys, the IT guys. 'She managed his household. They weren't that close. It was a professional relationship.' When Epstein negotiated an infamous plea deal, pleading guilty to two child sex nrneitntinn rharcres in 9nnR and cervincr just 12 mnnths in nrisnn — mnct nn day refract:, — 4113 EFTA00084411 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 47 of 161 513 EFTA00084412 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 48 of 161 613 EFTA00084413 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 49 of 161 7/13 EFTA00084414 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 50 of 161 813 EFTA00084415 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 51 of 161 9,13 EFTA00084416 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 52 of 161 10,13 EFTA00084417 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 53 of 161 11113 EFTA00084418 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 54 of 161 12'13 EFTA00084419 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 55 of 161 13/13 EFTA00084420 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 56 of 161 Four more women accused of supplying young girls for Epstein to abuse dailymail.co.uldnews/article-8513823/Four-women-accused-supplyina-youne-girls-Eostein-abuse.html July 12, 2020 Epstein's other 'recruiters': Four more women accused of supplying young girls for him to abuse face probe as it's revealed Ghislaine Maxwell moved house 36 times in a year before she was caught • ktre under investigation for their role in Epstein's sex-trafficking ring, according to reports • The four women are accused of helping to procure and groom the girls • In one case a previous victim went on to help groom other young women • dubbed Maxwell's 'lieutenant', 'flew on the lolita express almost as many times as the disgraced couple' • Reports suggest that Ms Maxwell moved 36 times before her arrest last week By Ryan Fahey For Mailonline Published: 20:46 EDT, 11 July 2O2O I Updated: 09:08 EDT, 12 July 2O2O • • • e-mail • 21k shares Four more women accused of supplying young girls for billionaire paedophile Jeffrey Epstein to abuse are facing investigation as it's revealed Ghislaine Maxwell moved house 36 times in a year before she was caught by the FBI. re being investigated for their alleged role in Epstein's sex-trafficking ring, according to a report in the Sunday Telegraph. dubbed Ghislaine Maxwell's 'lieutenant' by Epstein's victims, is said to have flown on the paedophile's 'lolita express' almost as many times as the disgraced couple. 1111 EFTA00084421 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 57 of 161 who is said to have taken a leading role in the sex ring, and the other three women, have previously been accused of recruiting and grooming underage girls for Epstein to sleep with. One was also said to have been involved in a sexual relationship with the financier. 2/11 EFTA00084422 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 58 of 161 worked as an assistant for Jefferey Epstein and was named in his 2008 plea agreement as 'potential co-conspirators' who now goes b=, was allegedly one of Epstein's victims according to interviews with victims back in 2005, before she began procuring girls for the paedophile herself 3111 EFTA00084423 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 59 of 161 EFTA00084424 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 60 of 161 5/11 EFTA00084425 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 61 of 161 6/11 EFTA00084426 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 62 of 161 7111 EFTA00084427 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 63 of 161 8111 EFTA00084428 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 64 of 161 9111 EFTA00084429 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 65 of 161 10111 EFTA00084430 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 66 of 161 11111 EFTA00084431 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 67 of 161 Ghislaine Maxwell breaks down in tears as she is DENIED bail and must stay locked up until her July 2021 trial as judge rules Epstein's 'madam' has shown 'sophistication in hiding her finances AND herself and poses significant flight risk' • Ghislaine Maxwell cried as she was denied bail on Tuesday, with a judge ruling she must stay locked up until her trial in July of 2021 • The British socialite, 58, pleaded not guilty to the sex trafficking charges brought against her • She hung her head as she learned her fate, wearing a prison-issued brown top and with her normally short hair now long and swept back into a bun • Judge Alison Nathan ruled Maxwell was a significant flight risk, citing her 'substantial international' ties and 'extraordinary financial resources' • Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey Epstein to abuse between 1994 and 1997 • She had offered a $5 million bond co-signed by two of her sisters and backed up by more than $3.75 million in property in the UK • Prosecutors fought for no bail, presenting evidence that she is 'skilled at living in hiding', citing her three passports and claimed she is worth more than $10M • They said Maxwell refused to open the front door to the FBI and tried to flee to another room when they raided her $1 million home on July 2 • A victim also argued she was a flight risk and wrote: 'Without Ghislaine, Jeffrey couldn't have done what he did. She is a predator and a monster' By CHEYENNE ROUNDTREE FOR DAILYMAIL.COM and DANIEL BATES FOR DAILYMAIL.COM PUBLISHED: 13:21 EDT. 14 July 2020 UPDATED: 17:20 EDT. 14 July 2020 Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay locked up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not guilty to the sex trafficking charges brought against her. EFTA00084432 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 68 of 161 The 58-year-old wiped tears away and hung her head as she learned her fate, wearing a prison-issued brown top and with her normally short hair now long and swept back into a bun, appearing via video link. U.S. District Judge Alison Nathan denied Maxwell's proposal of a $5 million bond co- signed by two of her sisters and backed up by more than $3.75 million in property in the UK. Maxwell's legal team had argued she would be confined to a 'luxury hotel' in the New York area, surrender all her travel documents and be subject to GPS monitoring. But Judge Nathan ruled the British socialite was a significant flight risk, citing her 'substantial international' ties and 'extraordinary financial resources', setting an anticipated trial date for July 12, 2021. Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994 and 1997, a period when she was his girlfriend. She faces up to 35 years in prison if found guilty of the charges, as prosecutors successfully argued that along with her three passports, connections to some of the world's most powerful people and her own fortune of more than $10 million - Maxwell had every incentive to try and flee. Maxwell will now return to the fortress-like Metropolitan Detention Center in Brooklyn where she has been given paper clothes to ensure she doesn't kill herself. EFTA00084433 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 69 of 161 Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay locked up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not guilty to the sex trafficking charges brought against her But Judge Nathan ruled the British socialite was a significant flight risk, citing her 'substantial international' ties and 'extraordinary financial resources', setting an anticipated trial date for July 12, 2021 EFTA00084434 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 70 of 161 Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994 and 1997, a period when she was his girlfriend. She faces up to 35 years in prison if found guilty of the charges, as prosecutors successfully argued that along with her three passports, connections to some of the world's most powerful people and her own fortune of more than S10 million - Maxwell had every incentive to try and flee Maxwell is currently in custody in the Metropolitan Detention Center in Brooklyn (pictured) where she is wearing paper clothes to ensure she doesn't kill herself EFTA00084435 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 71 of 161 Maxwell is being closely watched as the Department of Justice wants to ensure she does not kill herself like Epstein, who hanged himself last August while awaiting trial on sex trafficking charges. During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell appeared via video from the Metropolitan Detention Center in Brooklyn. The small room she was in had white walls, a white bed, a window with frosted glass and a door at the back. She was wearing a dark brown prison issued top and her dark hair was far longer than in the past - she reportedly has not had a haircut in a year - and was swept behind her head in a bun. At the start of the hearing, Maxwell rested her elbows on a table in front of the camera and put her head on her hands. She appeared nervous and pensive and kept looking from side to side, as she leaned into the camera. Maxwell briefly spoke and only to confirm she could hear the judge and to enter her plea by saying: 'Not guilty, your honor'. Her demeanor changed when prosecutor began outlining the allegations against her, sitting back in her chair and bowing her head when Moe accused her of 'sexual abuse of minors'. With every allegation, Maxwell either scratched her face or moved her hair, but was emotionless as victim impact statements were read aloud. It wasn't until Judge Nathan started reading her decision that Maxwell finally broke down. She began moving uneasily in her chair as the judge said the evidence against her was 'strong'. When Judge Nathan said a 'combination of factors' showed she had the 'motive and opportunity' to flee before her trial, Maxwell wiped a tear away. The second tear fell as the judge said Maxwell was 'sophisticated at hiding her financial resources'. EFTA00084436 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 72 of 161 During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell appeared via video from the Metropolitan Detention Center in Brooklyn. She was wearing a dark brown prison issue top and her dark hair was far longer than in the past - she reportedly has not had a haircut in a year - and was swept behind her head in a bun It wasn't until Judge Nathan began reading her decision that Maxwell finally broke down. She began moving uneasily in her chair as the judge said the evidence against her was 'strong'. When Judge Nathan said a 'combination of factors' showed she had the 'motive and opportunity' to flee before her trial, Maxwell wiped a tear away EFTA00084437 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 73 of 161 For the rest of the decision, Maxwell rested her head in her hands as she had done at the start of the hearing. Maxwell sat though prosecutors detailing how she was 'skilled at living in hiding' and as two victims argued she was a flight risk, with one writing: 'Without Ghislaine, Jeffrey couldn't have done what he did. She is a predator and a monster.' Prosecutors argued against Maxwell being granted bail, citing that due to holding both French and British passports, she has the ability to 'live beyond the reach of extradition indefinitely'. Prosecutor argued: 'She is good at living under an assumed identity. There really can be no question that she can live in hiding.' She revealed when Maxwell bought her $1 million home in Bradford, New Hampshire last December, she toured the property with a real estate agent using an alias. said: 'The real estate agent told the FBI agent the buyers for the house introduced themselves as Scott and Janet Marshall. Both had British accents. 'Scott Marshall told her he was retired from the British military and was currently working on a book. Janet Marshall described herself as a journalist.' Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea, living at a home owned by her tech CEO lover Scott Borgerson. It is unclear if the man who toured the New Hampshire home with Maxwell was Borgerson. also read out a victim impact statement from a woman identified as Jane Doe, who also made the case that Maxwell was a flight risk. The victim said she knew Maxwell for 10 years and the socialite intended to 'deliver' her to Epstein, all the while knowing the 'heinous dehumanization that awaited me'. The woman claimed Maxwell 'was in charge' and 'egged' Epstein on. She described Maxwell as 'sociopathic' and said she would 'have done anything to get what she wanted - to satisfy Jeffrey Epstein'. EFTA00084438 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 74 of 161 (pictured) also spoke at the hearing, detailing how she met Maxwell when she was 16 years old. has previously gone on record with her claims against Maxwell NNW Prosecutors said when Maxwell bought her S1 million Bradford, New Hampshire home (pictured), she toured the home back in November of 2019 using the alias of Janet Marshall and claimed to the real estate agent that she worked as a journalist The victim added that 'if [Maxwell] is out, I need to be protected', citing a phone call she received in the middle of the night threatening her two-year-old child. EFTA00084439 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 75 of 161 also spoke at the hearing, detailing how she met Maxwell when she was 16 years old. has previously gone on record with her claims against Maxwell. She said Maxwell 'has never shown any remorse [andj tormented her survivors... She has associates across the globe, some of great means.' Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she has community ties and is 'part of a very large and close family'. He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media spin', leading prosecuto to later shoot back: 'These are the facts. It is not dirt, it is not spin, it is evidence to the court.' Cohen claimed Maxwell had received numerous threats and denied she had refused to open her front door to the FBI when they raided her home on July 2. He claimed her front door was unlocked, the windows were open and she had 'surrendered' to the agents. Addressing reports that Maxwell had wrapped her mobile phone in tin foil, which prosecutors called a 'seemingly misguided effort to evade detection' by law enforcement, Cohen claimed her phone had been hacked and she had to preserve the phone as evidence. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk of catching the coronavirus whilst in prison. They claim that the restrictions EFTA00084440 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 76 of 161 on access to her lawyers caused by the pandemic would mean it was impossible for her to get a fair trial Also on the case is (l-r) and • II you 'wat vtoms ar4Itti no may be avian., Sate cal the bAton4 tWITibte: Pictured: Acting United States Attorney for the Southern District of New York Audrey Strauss speaks during a news conference to announce charges against Ghislaine Maxwell EFTA00084441 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 77 of 161 Cohen went above the issue of Maxwell being a flight risk to complain that the charges against her are from 25 years ago, calling the indictment 'an effort to dance around' the controversial non-prosecution sweetheart deal Epstein and his associates received in Florida in 2007. With her bail now denied, Maxwell will return to the Metropolitan Detention Center in Brooklyn. Journalists had started lining up outside the federal court in downtown Manhattan at 6am to get a seat inside the courtroom. They were allowed in at 11.45am and had to stand 6ft apart while they waited to ensure social distancing. The hearing took place in the jury assembly room which normally has space for hundreds of people but had a dramatically reduced capacity of just 60 due to the coronavirus. A dial-in phone line allowed 1,000 more people to listen in - the capacity was increased from 500 due to world-wide interest. Inside the room there were two projector screens, which showed the proceedings live. All parties, including the judge, appeared remotely and no one was physically in court. Maxwell's lawyer was visible at all times in a box on the screen. Maxwell had her own box, the judge had one and the prosecutors had another. Maxwell's mugshot has not been released by the federal authorities and the hearing offered the first chance to see her in at least a year. Maxwell's whereabouts had largely been unknown since Epstein's arrest last July. Although DailyMail.com tracked her down to the New England coast last summer, she vanished again, later popping up in a photo at an In-N-Out in Los Angeles. The FBI managed to finally trace her down in the quiet and rural town of Bradford, New Hampshire earlier this month, where she had been living since December. EFTA00084442 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 78 of 161 hrprise Women: Inspiratiot Maxwell's mugshot has not been released by the federal authorities and the hearing offered the first chance to see her in at least a year. Maxwell's whereabouts had largely been unknown since Epstein's arrest last July. Although DailyMail.com tracked her down to the New England EFTA00084443 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 79 of 161 coast last summer, she vanished again, later popping up in a photo at an In-N-Out in Los Angeles IC Palm k Mc Mullen en cety Images Maxwell was romantically involved with Jeffrey Epstein from around 1992, but then became his 'right-hand woman', managing his property empire and, it is alleged, his trafficking of minors Officials said her conduct during the 8.30am raid at the property called 'Tuckedaway' was 'troubling'. They wrote that when the FBI arrived they were confronted by a locked gate which they forced their way through. The filing said: 'As the agents approached the front door to the main house, they announced themselves as FBI agents and directed the defendant to open the door. 'Through a window, the agents saw the defendant ignore the direction to open the door and, instead, try to flee to another room in the house, quickly shutting a door behind her. Agents were ultimately forced to breach the door in order to enter the house to arrest the defendant, who was found in an interior room in the house. 'Moreover, as the agents conducted a security sweep of the house, they also noticed a cell phone wrapped in tin foil on top of a desk, a seemingly misguided effort to evade detection, not by the press or public, which of course would have no ability to trace her phone or intercept her communications, but by law enforcement'. EFTA00084444 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 80 of 161 After Maxwell, the daughter of late newspaper tycoon Robert Maxwell, was arrested the FBI spoke to a security guard who worked on the property who said that her brother had hired him from a company staffed with former British military soldiers. The filing states: 'The guard informed the FBI that the defendant had not left the property during his time working there, and that instead, the guard was sent to make purchases for the property using the credit card. As these facts make plain, there should be no question that the defendant is skilled at living in hiding'. In their filings to the court Maxwell's lawyers had argued that she is at increased risk of catching the coronavirus whilst in prison. So far there have only been five cases and no deaths at the prison. They claim that the restrictions on access to her lawyers caused by the pandemic would mean it was impossible for her to get a fair trial. The prosecutors said that in fact the prison had made substantial efforts to accommodate her and keep her safe. EFTA00084445 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 81 of 161 Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 2 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x TILE GOVERNMENT'S REPLY MEMORANDUM IN FURTHER SUPPORT OF DETENTION The Government respecttblly submits this reply memorandum in further support of its motion for detention, dated July 2, 2020 (the "Detention Memorandum") (Dkt. 4), and in response to the defendant's memorandum in opposition (the "Opposition Memorandum") (Dkt. 18). The charges against Ghislaine Maxwell arise from her essential role in sexual exploitation that caused deep and lasting harm to vulnerable victims. At the heart of this case are brave women who are victims of serious crimes that demand justice. The defendant's motion wholly fails to appreciate the driving force behind this case: the defendant's victims were sexually abused as minors as a direct result of Ghislaine Maxwell's actions, and they have carried the trauma from these events for their entire adult lives. They deserve to see her brought to justice at a trial. There will be no trial for the victims if the defendant is afforded the opportunity to flee the jurisdiction, and there is every reason to think that is exactly what she will do if she is released. For the reasons detailed in the Detention Memorandum, and as further discussed below, the defendant poses a clear risk of flight, and no conditions of bail could reasonably assure her continued appearance in this case. Among other concerns: (1) she is a citizen of a country that does not extradite its own citizens; (2) she appears to have access to considerable wealth EFTA00084446 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 82 of 161 EFTA00084447 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 83 of 161 Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 3 of 19 domestically and abroad; (3) her finances are completely opaque, as her memorandum pointedly declines to provide the Court with information about her financial resources; and (4) she appears to be skilled at living in hiding. These are glaring red flags, even before the Court considers the gravity of the charges in this case and the serious penalties the defendant faces if convicted at trial. Instead of attempting to address the risks of releasing a defendant with apparent access to extraordinary financial resources, who has the ability to live beyond the reach of extradition in France, and who has already demonstrated a willingness and ability to live in hiding, the defendant instead proposes a bail package that amounts to little more than an unsecured bond. Among other things, the proposed bail package contemplates the defendant pledging as the sole security a property that is beyond the territory and judicial reach of the United States, and which therefore is of no value as collateral. She proposes six unidentified co-signers, an unknown number of whom even reside in the United States, and stone of whose assets are identified. The Court and the Government have no information whatsoever regarding whether these co-signers would be able to able to pay the proposed $5 million bond should the defendant flee — or if, of equal concern, the co-signers are themselves so wealthy that it would be no financial burden whatsoever to do so. The defendant does not identify what residence she proposes to live at in the Southern District of New York, nor does she identify any meaningful ties to the area. And most importantly, the defendant's memorandum provides the Court with no information whatsoever about her own finances or her access to the wealth of others, declining to provide the Court the very information that would inform any decision about whether a bond is even meaningful to the defendant — and which the Government submits would reveal the defendant's financial means to flee and live comfortably abroad for the rest of her life. 2 EFTA00084448 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 84 of 161 EFTA00084449 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 85 of 161 Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 4 of 19 Finally, the Government recognizes that the COVID-19 pandemic is — and should be — a relevant factor for the Court and the parties in this case. However, the Bureau of Prisons ("BOP") is taking very significant steps to address that concern, and the defendant has offered no reason why she should be treated any differently from the many defendants who are currently detained at the Metropolitan Detention Center ("MDC") pending trial, including defendants who have medical conditions that place them at heightened risk. Inmates at the MDC are able to assist in their own defense, especially long before trial, through established policies and procedures applicable to every pretrial detainee. This defendant should not be granted the special treatment she requests. The defendant faces a presumption of detention, she has significant assets and foreign ties, she has demonstrated her ability to evade detection, and the victims of the defendant's crimes seek her detention. Because there is no set of conditions short of incarceration that can reasonably assure the defendant's appearance, the Government urges the Court to detain her. ARGUMENT Each of the relevant factors to be considered as to flight risk — the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant — weigh strongly in favor of detention, and the defendant's proposed package would do absolutely nothing to mitigate those risks. I. The Defendant's Victims Seek Detention As the Court is aware, pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving release. 18 U.S.C. § 377 I (a)(4). Consistent with that requirement, the Government has been in contact with victims and their counsel in connection with its application for detention. Counsel for one victim has already conveyed to the Government that 3 EFTA00084450 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 86 of 161 EFTA00084451 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 87 of 161 Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 5 of 19 their client opposes bail for the defendant, and has asked the Government to convey that view to the Court. The Government also expects that one or more victims will exercise their right to be heard at the July 14, 2020 hearing in this matter, and will urge the Court not to grant bail. More generally, as noted above, the Government is deeply concerned that if the defendant is bailed, the victims will be denied justice in this case. That outcome is unacceptable to both the victims and the Government. U. The Government's Case Is Strong The defendant's motion argues, in a conclusory fashion, that the Government's case must be weak because the conduct charged occurred in the 1990s. That argument, which ignores the many specific allegations in the Indictment, could not be more wrong. As the superseding indictment (the "Indictment") makes plain, multiple victims have provided detailed, credible evidence of the defendant's criminal conduct. And while that conduct did take place a number of years ago, it is unsurprising that the victims have been unable to forget the defendant's predatory conduct after all this time, as traumatic childhood experiences often leave indelible marks. The recollections of the victims bear striking resemblances that corroborate each other and provide compelling proof of the defendant's active participation in a disturbing scheme to groom and sexually abuse minor girls. In addition to compelling victim accounts, as the Government has explained, the victims' accounts are corroborated by documentary evidence and other witnesses. In particular, the victims' accounts are supported by contemporaneous documents and records, such as flight records, diary entries, and business records. The powerful testimony of these victims, who had strikingly similar experiences with Maxwell, together with documentary 4 EFTA00084452 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 88 of 161 EFTA00084453 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 89 of 161 Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 6 of 19 evidence and witness testimony, will conclusively establish that the defendant groomed the victims for sexual abuse by Jeffrey Epstein.' The defendant's motion alludes to defenses in this case, all of which are legal or procedural in nature, and none of which pass muster, let alone counsel in favor of bail. To begin with, the notion that the defendant is protected from prosecution by the Non-Prosecution Agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District of Florida ("SDFL") is absurd. That agreement affords her no protection in this District, for at least three reasons. First, the defendant was not a party to that agreement nor named in it as a third-party beneficiary, and the defendant offers no basis to think she would have standing to claim any rights under the NPA. Tellingly, the defendant cites no authority for the proposition that an agreement she was not a party to and that does not even identity her by name could possibly be invoked to bar her prosecution. Second, and equally important, the NPA does not bind the Southern District of New York, which was not a party to the agreement. See (Med Stales v, Annabl, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam) ("A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); Unbed Stales v. Mica), 391 F. App'x 920, 921 (2d Cir. 2010). This rule applies even when the text of the agreement refers to the signing party as the "Government." Annab1,771 F.2d at 672. Third, and perhaps most important, even assuming the NPA could be read to protect this defendant and bind this Office, which are both legally unsound propositions, the Indictment Additionally, and beyond the strong evidence set forth in the Indictment, in just the past week, and in response to the charges against the defendant being made public, the Federal Bureau of Investigation ("FBI") and the U.S. Attorney's Office have been in touch with additional individuals who have expressed a willingness to provide information regarding the defendant. The Government is in the process of receiving and reviewing this additional evidence, which has the potential to make the Government's case even stronger. 5 EFTA00084454 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 90 of 161 New York prosecutors said in a filing Monday this was evidence that Maxwell was 'skilled at living in hiding' and should be denied bail Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analogous situations: I i I a S5 million personal recognizance bond, co-signed by six financially responsible people, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United Kingdom worth over 53.75 million; (ii) travel restricted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic CPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's office, except upon application to Pretrial Services and the government; and (viii) such other tenris as the Court may deem appropriate under Section 3142 Her bail request (pictured) was filed in the US District Court in Manhattan and claims she was not 'hiding' from authorities, is not a flight risk and is at risk of contracting COVID-19 if she continues to be held in the Brooklyn jail The case against her is 'strong' and multiple victims have provided 'detailed, credible evidence of the defendant's criminal conduct' - with more women coming forward in the past week. The victims have made clear they want Maxwell remanded in custody and say they were 'directly abused as a result of Ghislaine Maxwell's actions'. The document states: 'While that conduct did take place a number of years ago, it is unsurprising that the victims have been unable to forget the defendant's predatory conduct after all this time, as traumatic childhood experiences often leave indelible marks. EFTA00084455 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 91 of 161 'The recollections of the victims bear striking resemblances that corroborate each other and provide compelling proof of the defendant's active participation in a disturbing scheme to groom and sexually abuse minor girls'. The prosecutors said that it was 'curious' that Maxwell claimed to have access to millions of dollars had not offered 'a single dime' as collateral for her bond. They claimed that Maxwell's finances were 'completely opaque' and she had not even indicated which properties she would use for her bond. Some of the co-signers are 'themselves so wealthy that it would be no financial burden whatsoever' if they lost their $5 million by Maxwell skipping bail, the document states. Epstein's victims have long demanded Maxwell's arrest and lawyers for them say that a slew of new accusers have come forward since she was apprehended. Prosecutors will likely be looking to do a plea deal with Maxwell to lighten some of the six charges against her, two of which are perjury for allegedly lying during depositions. They will be questioning her about powerful men in Epstein's orbit including Bill Clinton with whom she flew on Epstein's private jet, called the 'Lolita Express', on a tour of Africa in 2002. Maxwell was also good friends with Prince Andrew and one of Epstein's victimsM claims she was loaned out to the Duke three times for sex when she was 17. EFTA00084456 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 92 of 161 Ghislaine Maxwell's attack-the-victim strategy may backfire a, bnnbloombera.cakThislaine-maxwell•mav-olav-the-victim-card-in-trial-defense-1.1465631 July 15, 2020 Ghislaine Maxwell Photographer: Laura Cavanaugh/Getty Images , Photographer: Laura Cavanaugh/Getty Images The bail hearing for Ghislaine Maxwell ended with a judge ruling that she must spend the next year behind bars awaiting trial on sex-trafficking charges tied to her former boyfriend Jeffrey Epstein. But it also offered hints at her defense strategy. During the two-hour video-conference hearing Tuesday, Maxwell's lawyers questioned the credibility of her accusers as well as the strength of the government's case. While the arguments were designed to win bail, they'll likely be the same ones used at the 58-year-old's trial, which is scheduled to start next July. The federal charges stem from events that are more than two decades old, Maxwell's lawyer, Mark Cohen, said, noting that the government doesn't have "tapes or video" or other such evidence to support the allegations. "Absolutely, the defense is telegraphing where they're going," said David Weinstein, a former federal prosecutor who listened in on Maxwell's hearing. "While the defense isn't putting all of their cards on the table, they showed they're going to argue that she was as irs EFTA00084457 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 93 of 161 much a victim of Epstein -- much in the same way as these girls were -- and that she didn't know what was going on behind closed doors." Cohen briefly took aim at one of Maxwell's accusers. He said she has sued Maxwell and is seeking a payout from a fund set up for Epstein's victims, Cohen said. Established in May, Epstein's victims can be compensated by the financier's estate, valued at more than US$600 million. That's a dangerous tactic that might backfire at trial, said David Boies, who represents and several other women who say they were sexually abused by Epstein and Maxwell. It's "a tone-deaf argument" that cost Maxwell her credibility, said Boies, who listened to the hearing remotely. "To mount a 'blame the victim' defense, particularly in today's world and trying to blame these girls for what happened is so contrary to the evidence, is so contrary to people's normal sense of morality," Boies said. "I think that's just going to enrage a jury if she goes to trial -- which I would not do if I were representing her." Boies said he was confidennould stand up to cross-examination if there's a trial. who addressed the court by telephone, urged the judge not to grant Maxwell bail, calling her a "sexual predator who groomed and abused me." Maxwell "lied under oath and tormented her survivors," said. Boies said that Maxwell. was a 16-year-old who "wanted to go to college" when she met "Maxwell and Epstein tel and her mother 'we're having a group of hi school students to this ranch to help them get into college,"' Boies said. "But when gets there, there are no high school students, all these claims are fraudulent and she's in this isolated place in New Mexico." Remote Hearing Because of the pandemic, Maxwell's hearing was held remotely with press and the public permitted to hear arguments over the phone. About 6o members of the press were allowed to watch the proceeding on monitors in a jury room in the Manhattan courthouse, with the judge, lawyers and Maxwell all in different locations. Prosecutors also offered detail on their evidence, saying they have travel records, photographs and other documents that will support the charges. 213 EFTA00084458 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 94 of 161 Along witl remarks, Assistant U.S. Attorney read from a letter written by another of Maxwell's alleged victims, who asked to be identified only as Jane Doe. It's possible that the woman may testify at the trial as well. "Without Ghislaine Maxwell, Jeffrey Epstein could not have done what he did; she egged him on," the woman said in the letter. She called Maxwell "a monster." The judge scheduled the trial for July 12. The defense must file its pretrial motions by Dec. 21. --With assistance from Bob Van Voris. 313 EFTA00084459 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 95 of 161 Ghislaine Maxwell's neighbours tried to make her leave town ID dailvmail.co.uk/news/article-8525759/Neighbors-Ghislaine•Maxwell-lover-tried•ostracize-couple-make-leave- town.html July 16, 2020 • Ghislaine Maxwell had been living with her tech CEO lover Scott Borgerson at his home in Manchester-by-the-Sea outside of Boston until last December • In February 2019 neighbors learned the quiet, well-dressed woman in their midst had been accused of procuring young girls for pedophile Jeffrey Epstein • 'They were absolutely appalled to learn who they were allowing to have the run of their property,' one resident exclusively told DailyMail.com • Neighbors tried to harass and 'ostracize' Maxwell into leaving, and make her and Borgerson 'feel they weren't welcome on Sharksmouth or in Manchester' • It led to a court case where Borgerson successfully fought the neighbors' decision to stop them from using paths and a beach near the home that were part of a 4o-acre estate with other homes • A judge only made his ruling on March ii this year, three months after Maxwell had left Sharksmouth for good, moving to her hideaway in Bradford, NH • Borgerson is believed to have met Maxwell six years ago through speaking engagements connected to ocean preservation • They were both pictured speaking at the Arctic Circle Assembly in Reykjavik, Iceland, in 2014 Ghislaine Maxwell's neighbors were so disgusted when they discovered an accused sex trafficker was living among them that they tried to harass her into leaving, DailyMail.com has learned exclusively. It led to a court case where Maxwell's 14-years-younger lover Scott Borgerson successfully fought the neighbors' decision to prevent them from using paths and a beach near their Massachusetts oceanfront property, part of the 40-acre estate shared by other owners. But the decision was not handed down until after Maxwell, 58, had already left for her new life of seclusion in neighboring New Hampshire. The small-town dispute involving the woman who was among the most-wanted in America, all played out in quaint Manchester-by-the-Sea, a well-to-do town 30 miles north of Boston where Maxwell was holed up with wealthy tech CEO Borgerson. 1178 EFTA00084460 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 96 of 161 But in February 2019 neighbors learned the quiet, well-dressed woman in their midst had been accused of procuring young girls for pedophile Jeffrey Epstein — and they decided to act. 'They were absolutely appalled to learn who they were allowing to have the run of their property,' one resident told DailyMail.com. 'The second they learned she was involved with Epstein they decided to try to limit how much they could use their land.' Ghislaine Maxwell and Scott Borgerson's neighbors were so disgusted when they discovered an accused sex trafficker was living among them that they tried to harass her into leaving. Borgerson is believed to have met Maxwell six years ago through speaking engagements connected to ocean preservation, a subject on which they share a passion. They were both pictured speaking at the Arctic Circle Assembly in Reykjavik, Iceland, in 2014 (left and right) 2118 EFTA00084461 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 97 of 161 k.C. Arctic Circle Sec retariatNimeo 3/18 EFTA00084462 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 98 of 161 It led to a court case where Maxwell's lover Scott Borgerson successfully fought the neighbors' decision to prevent them from using paths and a beach near their Massachusetts oceanfront property. Borgerson, 44, bought the Phippin House (pictured), a 7-bedroom property, for $2.4M in June 24)16, using a limited liability company called Tidewood 4118 EFTA00084463 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 99 of 161 5/18 EFTA00084464 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 100 of 161 618 EFTA00084465 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 101 of 161 7118 EFTA00084466 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 102 of 161 818 EFTA00084467 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 103 of 161 918 EFTA00084468 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 104 of 161 1018 EFTA00084469 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 105 of 161 11118 EFTA00084470 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 106 of 161 12;18 EFTA00084471 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 107 of 161 1118 EFTA00084472 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 108 of 161 14;18 EFTA00084473 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 109 of 161 1518 EFTA00084474 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 110 of 161 16,18 EFTA00084475 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 111 of 161 17118 EFTA00084476 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 112 of 161 18+18 EFTA00084477 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 113 of 161 Jeffrey Epstein's victim claims it was the British socialite who always se e rap O dailvmail.co.uk/news/article-8535303/Jeffrev-Eosteins-victim-Maria-Farmer-claims-British-socialite-set-trap.html July 17. 2020 'Ghislaine Maxwell was the mastermind': Jeffrey Epstein's victim who was the first to blow the whistle on him claims it was the British socialite who always set the trap By Tom Leonard for the Daily Mail Published: 17:25 EDT, 17 July 2020 I Updated: 17:25 EDT, 17 July 2020 • • • e-mail • 337 shares For talented young artist it was the night she'd been working towards for months — her graduation show at the prestigious New York Academy of Art. then 25, was ecstatic, having sold all three of her exhibited paintings for five-figure sums. Then a senior staff member appeared at her shoulder, took her arm and pointed out two people she'd never seen before. 1/13 EFTA00084478 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 114 of 161 outside New York court on July 15, 2019 `This couple here are going to buy your art . . . they're very important benefactors of the academy,' she was told. It was Jeffrey Epstein and Ghislaine Maxwell, and they got the painting they wanted — a semi-naked man observing a sleeping girl, inspired by Edgar Degas's The Rape — for $6,000, half the prier had been offered earlier. Fast-forward 25 years and this week younger sister gave an emotional statement to a Manhattan court about why Maxwell should not be granted bail. Speaking via an audio feed from her home in Texas, psychotherapist- one of three women whose claims are the basis for the criminal case against the British socialite, said Maxwell was a `sexual predator' who had `never shown any remorse for her heinous crimes or the devastating, lasting effects her actions caused'. who says she feels guilty for unwittingly bringing her then teenage sister into the orbit of Maxwell and Epstein, was the first person to report the pair's alleged sexual abuse of underage girls in 1996. But her attempts to get the police and FBI to investigate the attack on= then 16, were ignored, leaving Epstein free to pursue his depravity. The sisters' story is shocking and their determination to get justice remarkable. Now, at last, their voices are being heard estimony was a key factor in the judge's decision to deny Maxwell bail and keep her in a New York jail cell before her trial next year — which is as it should be, Mold the Mail yesterday. For her, Epstein — who was found dead in his remand jail cell last year — isn't the worst villain in this scandal. 2113 EFTA00084479 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 115 of 161 `That woman was much more sinister than Epstein, and to me, much more dangerous,' she says. `She was definitely the mastermind. She was in charge.' w orked for Epstein, a financial guru, for a year, during which time she says she saw first hand Maxwell's astonishing charm and her terrifying viciousness. 3113 EFTA00084480 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 116 of 161 EFTA00084481 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 117 of 161 5,13 EFTA00084482 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 118 of 161 6,13 EFTA00084483 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 119 of 161 7113 EFTA00084484 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 120 of 161 813 EFTA00084485 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 121 of 161 9113 EFTA00084486 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 122 of 161 10,13 EFTA00084487 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 123 of 161 11113 EFTA00084488 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 124 of 161 12,'13 EFTA00084489 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 125 of 161 13,13 EFTA00084490 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 126 of 161 Ghislaine Maxwell was `a sexual predator,' alleged victim says in new testimony By Isabel Vincent July18.2020 I 6:32pm Ghislaine Maxwell Patrick McMullan via Gen imageS Ghislaine Maxwell had to find three girls a day to be sexually abused by her longtime associate, convicted pedophile Jeffrey Epstein, according to blockbuster new testimony by an alleged victim who has waived her anonymity In the case. "She was a sexual predator who abused me and countless other children and young women. old a federal Judge who denied Maxwell, 58, ball Tuesday and ordered her to spend a year awaiting trial at the Brooklyn Detention Center, where she has been held since shortly after her July 2 arrest in New Hampshire. now 41, Is believed to be one of three victims — all of them minors at the time of the alleged abuse between 1994 and 1997 — in the case against Maxwell. She is is charged with helping Epstein sexually abuse girls as young as 14. If convicted, Maxwell faces up to 35 years in prison. Maxwell has denied any wrongdoing. EFTA00084491 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 127 of 161 Although prosecutors have not revealed all Sevidence, details of her abuse, which began when she was 16 and flown to Epstein's ranch in New Mexico, were contained in a civil lawsuit filed last December. Papers filed in Maxwell's case on Saturday allege that "Maxwell spent years overseeing and managing Epstein's sex- trafficking network ... Epstein's preference was to have three different girls a day for his sexual pleasure and Maxwell was in charge of recruiting the girls," according to a report in the Sunday Times of London. The documents say thatM parents divorced when she was young and her "mother struggled financially to support and her siblings". "Maxwell appeared charming and friendly to "Upon arriving, Maxwell and E stein too hopping and lavished her with gifts, including beauty products and a pair of brand new cowboy boots. older sister Man artist, also claims that she was abused by Epstein. Maxwell and Epstein also too' to see a movie while she was in New Mexico. While they were standing in line, Maxwell "pulled down Epstein's sweatpants, exposing part of his buttocks. Both Epstein and Maxwell repeatedly fondled each other in front al-trying to normalize sexual behavior to a child." "Upon returning [to the ranch] from the movie, Maxwell repeatedly told =hat she wanted to give her a massage ... Maxwell directed to take off all of her clothes and lay on the massage table. a Ghislaine Maxwell's 'lieutenan may be arres nea parents fear "Maxwell touched intimate parts o body against her will for the sexual benefit of Maxwell and Epstein. Maxwell exposeareasts and groped her. was extremely distressed and afraid. She was a child in a massive ranch, away from her family, and isolated from any source of help." The following morning, the court papers say, Epstein went tcaedroom got into bed demanding a "cuddle" and sexually assaulted her. lawyers claim that she decided to go public with her allegations only after Epstein's apparent suicide in a Manhattan federal lockup in August: "Until his death, the plaintiff feared that Epstein and his co-conspirators, including Maxwell, would harm her or her family, or ruin her life, if she came forward? Maxwell, who has claimed that she only has $1 million left in her bank accounts, used to keep a "sex swing" and would hang upside down "like a bat" on another device in an attempt to look younger, the newspaper reported. FILED UNDER GNISIAINE MAXWELL JEFFREY EPSTEIN, NEW MEXICO, SEXUAL ABUSE, 7/18/20 EFTA00084492 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 128 of 161 Ghislaine Maxwell paid $25k to Jacob Wohl to 'smear victims' CO dailymail.co.ukThews/article-8531293/Ghislaine-Maxwell-Daid-25K-Jacob-Wohl-smear-victims-AG-fired.html July 21, 2020 EXCLUSIVE: Ghislaine Maxwell paid $25K to fake news purveyor Jacob Wohl to 'smear Epstein victims and to get prosecutor Geoffrey Berman fired in attempt to stall sex trafficking investigation against her' • Ghislaine Maxwell hired Jacob Wohl to smear alleged victims of Jeffrey Epstein and her, a former friend told DailyMail.com in an exclusive interview • As part of a $25k deal, Wohl and his lobbyist colleague Jack Burkman also allegedly pushed to get former New York US Attorney Geoffrey Berman fired • Wohl and Burkman are far-right lobbyists who have become a laughing stock in DC after several failed attempts to smear top political figures • Maryland paralegal Kristin Spealman claims she was initially contacted by the duo to use her in a smear campaign against Nancy Pelosi and Ted Cruz • Spealman told DailyMail.com they bragged to her they had been hired in early June for $25,000 to dig up dirt on Maxwell's alleged sex trafficking victims • Federal documents filed this month show a company linked to Maxwell had hired Wohl and Burkman to lobby on `issues relating to US DOJ, Senate Judiciary, House Judiciary,' DailyMail.com can exclusively reveal • Berman's removal was intended to stall or stop the criminal investigation into Maxwell, Spealman said • Berman was ultimately pushed out by Barr in June, but two weeks later Maxwell was charged as part of Epstein's sex trafficking ring By Josh Boswell For Dailymail.corn Published: 09:15 EDT, 21 July 2O2O I Updated: O2:55 EDT, 22 July 2O2O • • • e-mail • 1/21 EFTA00084493 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 129 of 161 6.7k shares Ghislaine Maxwell hired fake news purveyor Jacob Wohl to smear her and Jeffrey Epstein's alleged victims, a former friend has told DailyMail.com in an exclusive interview. As part of a $25,000 deal made in June, Wohl and his lobbyist colleague Jack Burkman also allegedly pushed to get New York US Attorney Geoffrey Ber