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From: " To: ' Cc: " Subject: Re: Ghislaine Maxwell Date: Tue, 22 Jul 2025 19:02:47 +0000 Importance: Normal See responses below. From: Sent: Tuesday, July 22, 2025 1:50 PM To: Cc: Subject: Re: Ghislaine Maxwell Thank you. How many vics complained about GM. 4 victims that testified and 1 additional victim that did not testify (5 total). Other women named GM but they weren't necessarily determined to be victims of this case. Can you down draft the proffer 302s. As discussed. SDNY kept notes. What were the statements for the perjury? Why was it not litigated? The perjury charges were separated from this trial for being prejudicial. After the conviction, the perjury charges were dropped to prevent the victims from testifying in another trial. What was the difference between count 1 and 2. Count 1 was the conspiracy and Count 2 was the physical act of enticing a minor. Counts 3 and 4 are similar in that the first is the conspiracy to commit and the following is the phys

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From: " To: ' Cc: " Subject: Re: Ghislaine Maxwell Date: Tue, 22 Jul 2025 19:02:47 +0000 Importance: Normal See responses below. From: Sent: Tuesday, July 22, 2025 1:50 PM To: Cc: Subject: Re: Ghislaine Maxwell Thank you. How many vics complained about GM. 4 victims that testified and 1 additional victim that did not testify (5 total). Other women named GM but they weren't necessarily determined to be victims of this case. Can you down draft the proffer 302s. As discussed. SDNY kept notes. What were the statements for the perjury? Why was it not litigated? The perjury charges were separated from this trial for being prejudicial. After the conviction, the perjury charges were dropped to prevent the victims from testifying in another trial. What was the difference between count 1 and 2. Count 1 was the conspiracy and Count 2 was the physical act of enticing a minor. Counts 3 and 4 are similar in that the first is the conspiracy to commit and the following is the physial act. What was the exact date her appeal exp or did she only have the option for a writ? I dont have details of appeal process prior to this from Comey: Maxwell has until April 10, 2025 to file a Writ of Certiorari with the Supreme Court. If she files a writ (which seems likely), it will remain pending until the Supreme Court either grants or denies certiorari, which could take months. If the Supreme Court denies certiorari, then that will conclude her direct appeal (though she will have the option of seeking habeas review under 28 USC 2255 within one year of the denial of certiorari). If the Supreme Court grants certiorari, then her case will be briefed and calendared for oral argument, and we'll likely have to wait about a year or so for a ruling from the Court. FBI NY Violent Crime Threat Cell: From: Sent: Tuesday, July 22, 2025 12:56:44 PM To: EFTA00161422 Cc: Subject: Ghislaine Maxwell On 12/06/2018, the FBI New York Child Exploitation and Human Trafficking Task Force (FBI-NY CEHTTF) initiated a child sex trafficking case following a request by the United States Attorney's Office, Southern District of New York (SDNY), based on several victims that had been sexually abused by JEFFREY EPSTEIN (Epstein) in the mid- 2000's. Epstein was indicted on 07/02/2019 and arrested on 07/06/2019. On 08/10/2019, FBI-NY was notified Epstein committed suicide in his jail cell. The child sex trafficking investigation continued to pursue co- conspirators, including GHISLAINE MAXWELL (Maxwell). Maxwell was first mentioned in the case file on 04/23/2019. Victim interviews revealed Maxwell groomed minor victims by befriending them first, developed a rapport with victims, then attempted to normalize sexual abuse. Maxwell was present with the minor victims while victims were undressed in front of Epstein and instructed minor victims on how to massage Epstein, to include sexual contact. Note: SONY proffered Maxwell with her Defense counsel prior to indictment. On 06/29/2020, Maxwell was indicted on five counts, as follows: Count 1: Conspiracy to entice minors Count 2: Enticement of a minor Count 3: Conspiracy to transport minors Count 4: Transportation of a minor Count 5: Two counts of Perjury On 03/29/2021, a Grand Jury in SDNY issued a superseding indictment against Maxwell with the following counts: Count 1: Conspiracy to entice minors Count 2: Enticement of a Minor to Travel to Engage in Illegal Sex Acts Count 3: Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity Count 4: Transportation of a Minor with Intent to Engage in Criminal Sexual Activity Count 5: Sex Trafficking Conspiracy Count 6: Sex Trafficking of a Minor Count 7: Perjury On 07/02/2020, pursuant to an arrest warrant issued in SDNY, FBI-NY CEHTTF and FBI Boston located and arrested Maxwell a On 11/29/2021, the trial of United States v. Ghislaine Maxwell began in the SDNY before the Honorable Alison Nathan. Maxwell did not testify during the trial. The defense alleged Maxwell was targeted for the crimes committed by Epstein, Maxwell was unaware of the abuse of minor victims by Epstein because he kept secrets from Maxwell, credibility issues among some of the victims, and victims were financially motivated by the victims' compensation fund. On 12/29/2021, a jury found Maxwell guilty on five of the six counts. The verdict was as follows: Not guilty • Count 2: Enticement of a Minor to Travel to Engage in Illegal Sex Acts Guilty • Count 1: Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts • Count 3: Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity EFTA00161423 • Count 4: Transportation of a Minor with Intent to Engage in Criminal Sexual Activity • Count 5: Sex Trafficking Conspiracy • Count 6: Sex Trafficking of a Minor Note: Count 7 (Perjury) was not litigated during this trial. On 06/28/2022, Maxwell was sentenced to 20 years in prison with 5 years of supervised release, and a $750,000 fine for participating and facilitating the sexual abuse and sex trafficking of minors for and with Jeffrey Epstein. On or about 04/10/2025, Maxwell petitioned to file a Writ of Certiorari with the Supreme Court. EFTA00161424

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From: " (NY) (FBI)" To: "Petronella. Michael A. (NY) (FBI)" •MI IMIE>, ' (FBI)" < Subject: Fw: Ghislaine Maxwell Date: Tue, 22 Jul 2025 17:13:36 +0000 Importance: Normal (NY) From: . (NY) (FBI) Sent: Tuesday, July 22, 2025 12:56:44 PM To: . (NY) (FBI) < > Cc: (NY) (FBI) < > Subject: Ghislaine Maxwell On 12/06/2018, the FBI New York Child Exploitation and Human Trafficking Task Force (FBI-NY CEHTTF) initiated a child sex trafficking case following a request by the United States Attorney's Office, Southern District of New York (SDNY), based on several victims that had been sexually abused by JEFFREY EPSTEIN (Epstein) in the mid- 2000's. Epstein was indicted on 07/02/2019 and arrested on 07/06/2019. On 08/10/2019, FBI-NY was notified Epstein committed suicide in his jail cell. The child sex trafficking investigation continued to pursue co- conspirators, including GHISLAINE MAXWELL (Maxwell). Maxwell was first mentioned in the case file on 04/23/2019. Victim interviews

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From: [=. To: ' Cc: ' Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 Date: Fri, 26 Nov 2021 19:54:50 +0000 Inline-Images: image001.png Just checking back on this. Thx! From Sent: Friday, November 26, 2021 10:34 AM To: I= '; Cc: Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL FRIDAY, NOVEMBER 26, 2021 Awesome, thanks. Are we able to provide a time if I also include the following? 9:30 a.m. — Jury charge followed by opening statements in U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). From: Sent: Friday. November 26.2021 10:26 AM To: Cc: Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 I don't think so. From

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant

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