• 4b Cab 9:08,cv-80804-KAM
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• 4b Cab 9:08,cv-80804-KAM Deent 12-2 Entered on FLSD DIN 08/21/2008 Page 1 of 8 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA STATE OF FLORIDA CASE NO.: 2006CF009454AXX DIVISON: "W" vs. b y 20* nr> JEFFREY EPSTEIN, 55 =rrlz nizo xi Defendant. =tr.?"' iv 0=co Ca pan a0R -u DEFENDANT'S MOTION FOR RETURN OF PROPERTYF:14p :Cm ry COMES NOW the Defendant, JEFFREY EPSTEIN, by and through hisiiiindecigned -n C attorney, and moves this Honorable Court to enter an Order for return of property seized on October 20, 2005 during execution of a search warrant at the Defendant's residence. In support thereof the Defendant states as follows: 1. On October 20, 2005, the Palm Beach Police Department executed a search warrant at the Defendant's residence. During the execution of the warrant, numerous items of the Defendant's personal property were seized and impounded by the Palm Beach Police Department. A copy of the sea
Persons Referenced (3)
“...ve inven pry:con e true.arc.de account of a the roperty taken by me, under the authority . of this warrant . Sat to end .subscribed before me this 2iday of. October-2005. • • . - • Wig %...”
Jeffrey Epstein“...STATE OF FLORIDA CASE NO.: 2006CF009454AXX DIVISON: "W" vs. b y 20* nr> JEFFREY EPSTEIN, 55 =rrlz nizo xi Defendant. =tr.?"' iv 0=co Ca pan a0R -u DEFENDANT'S MOTION FOR RETURN OF PROP...”
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EFTA DisclosureRelated Documents (6)
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,
SDNY News Clips, Wednesday, August 14, 2019
SDNY News Clips, Wednesday, August 14, 2019 SDNY News Clips Wednesday, August 14, 2019 Contents Public Corruption 2 Epstein 2 General Crimes 14 Sprecher 14 Violent and Organized Crime 20 Walter 20 Civil Division 22 NYCHA 22 Securities and Commodities Fraud 24 Margulies 24 Sharma and Farkas 26 Matters of Interest 28 Obama-era counsel Greg Craig's trial postponed; new jury to be selected 28 Epstein Saga Puts Spotlight on Crime Victim's Rights Act 30 Donziger Faces Criminal Contempt Prosecution Team at Seward & Kissel 34 Jail Where Epstein Died Has Record of Security Blunders 36 2nd Circuit's Decision Could Embolden Federal Anti-Corruption Prosecutors 38 1 EFTA00094388 SDNY News Clips, Wednesday, August 14, 2019 Public Corruption Epstein Jeffrey Epstein Raped Me When I Was 15 NYT By Jennifer Araoz 8/14/19 The first time I stepped into Jeffrey Epstein's mansion on the Upper East Side in the fall of 2001, I noticed his security cameras. They w
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
Bee: "Berman Geoffrey (USANYS
From: Cc: Bee: "Berman Geoffrey (USANYS Subject: SDNY News Clips Wednesday, August 14, 2019 Date: Wed, 14 Aug 2019 21:15:07 +0000 Attachments: 2019 8-14.pdf SDNY News Clips Wednesday, August 14, 2019 EFTA00094360 Contents Public Corruption Epstein General Crimes Sprecher Violent and Organized Crime Walter Civil Division NYCHA Securities and Commodities Fraud Margulies Sharma and Farkas Matters of Interest Obama-era counsel Greg Craig's trial postponed; new jiLD, to be selected Epstein Saga Puts Spotlight on Crime Victim's Rights Act Donziger Faces Criminal Contempt Prosecution Team at Seward & Kissel Jail Where Epstein Died Has Record of Security Blunders 2nd Circuit's Decision Could Embolden Federal Anti-Corruption Prosecutors Public Corruption Epstein Jeffrey Epstein Raped Me When I Was 15 NYT By Jennifer Araoz 8/14/19 The first time I stepped into Jeffrey Epstein's mansion on the Upper East Side in the fall of 2001, I noticed his security cameras.
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th
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