U.S. Department of Justice
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U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 11, 2021 BY ELECTRONIC MAIL Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: The Government writes to provide you with information regarding In particular, below is a verbatim English translation of an excerpt of information that the French Please note that this letter is governed by thill11.1. Minist of Justice rovided to the Government. Ms. is represented by Protective Order in this case. In particular, the letter is designated as "confidential" under the Protective Order. • "met Jeffrey Epstein and his partner Ghislaine Maxwell at the age of 16, in the south of France near They had made friends and she went to their Parisian apartment on Avenue Foch in 2000. The same year, she left for Miami with the couple[;] 6 months later, she was invited to New York by Ghislaine Maxwell,
Persons Referenced (6)
“...in to resist him. She remembered in particular that he had She had never met Jean-Luc Brunel." EFTA00094592 Page 2 Very truly yours, AUDREY STRAUSS United States Attorn...”
Audrey Strauss“...She had never met Jean-Luc Brunel." EFTA00094592 Page 2 Very truly yours, AUDREY STRAUSS United States Attorney Assistant United States Attorneys EFTA00094593”
United StatesUnited States AttorneyGhislaine MaxwellJeffrey EpsteinTags
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EFTA DisclosureRelated Documents (6)
EFTA00178386
EFTA00178386 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Fti./No. OLY-80/z SUBPOENA FOR: PERSON X DOCUMENTS OR OBJECTISI YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ROOM: Grand Jury Room DATE AND TIME: April 15, 2008 1:00pm YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s): ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED FROM JEFFREY EPSTEIN, LESLEY GROFF, AND/OR OR ANY EMPLOYEE OF JEFFREY EPST IMI L. ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, LESLEY GROFF, AND/OR ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/ORRECEIVED FR
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24 ORIGINAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. SUPERSEDING INDICTMENT S2 20 Cr. 330 (AJN) COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 2004, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victi
Subject: Fw: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
Subject: Fw: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS Date: Mon, 03 Aug 2020 15:51:10 +0000 Importance: Normal Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf; Ghislaine_Maxwell_Indictment_PR.pdf Inline-Images: image001.png Hi who should we include for this release in the monthly news bulletin? ublic Affairs Specialist FBI New York Sent: Thursday, July 2, 20201:20 PM Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS UNITED STATES ATTORNEY'S OFFICE Southern District of New York GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse Additionally Charged With Perjury in Connection With 2016 Depositions Audrey Strauss, the Acting United States Attorney for the Southern District of New York, Will
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-2413, Document 40, 08/20/2020, 2913550, Page2 of 74 Table of Contents Table of Authorities iii Introduction 1 Jurisdictional Statement 2 Issues Presented 3 Statement of the Case and the Facts 3 The defamation action and the Protective Order 3 The motion to unseal and the first appeal 6 The remand, the arrest,
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT S1 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victim
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