MEMY-1805 harvest: vision-joined (part 23)

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vision-joined/court-04/83e83cc7b0fe7323c117ddcb801cf40410e6eb5bffc41cbc3e180921bc97d51c.md

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+Case 1:15-cv-07433-LAP Document 656-5 Filed 03/02/17 Page 1 of 1
+REDACTED
+EXHIBIT E
+EFTA02802333

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vision-joined/court-04/845f1d709c7bb685b7ceac6b81c485cbff83d680837a64bbdee1073a5729d589.md

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+Case 1:15-cv-07433-LAP Document 229-2 Filed 06/20/16 Page 1 of 1
+REDACTED
+EXHIBIT B
+EFTA02798399

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vision-joined/court-04/846c8fbd54769e1bd667ccd387118f12648c88e8e74084cdb45263791360e42b.md

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+CG
+Case 1:20-cr-00330-PAE Document 310
+Filed 07/02/21
+Page 1 of 3
+800 Third Avenue
+& GRESSER LLP
+New York, NY 10022
++1 212 957 7600 phone
+www.cohengresser.com
+Christian R. Everdell
++1 (212) 957-7600
+ceverdell@)cohengresser.com
+July 2, 2021
+BY ECF
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+We respectfully submit this letter to bring to the Court's attention the recent decision by
+the Supreme Court of Pennsylvania in Commonwealth of Pennsylvania v. William Henry Cosby
+Jr., J-100-2020 (Jun. 30, 2021), in which the Court vacated Mr. Cosby's conviction and sentence
+because the District Attorney's Office that prosecuted him failed to live up to its express promise
+not to prosecute Mr. Cosby for the same crimes for which he was later convicted.' Ms. Maxwell's
+case presents a similar situation. As we argued in our supplemental pretrial motions currently
+pending before the Court (Dkt. 293), the government has failed to abide by its promise not to
+prosecute Ms. Maxwell for the offenses for which she was immunized by the Epstein Non-
+Prosecution Agreement ("NPA). We submit that this decision provides support for Ms.
+Maxwell's supplemental motion to dismiss Counts One, Three, Five, and Six of the S2 Indictment
+for violation of the NPA.
+In Cosby, Andrea Constand alleged that Mr. Cosby sexually assaulted her in his residence
+in January 2004. (Op. 4-5). Ms. Constand did not immediately report the assault to law
+enforcement authorities and continued to have contact with Mr. Cosby in the following months.
+(Id. at 5-7). In January 2005, approximately one year after the assault, Ms. Constand reported Mr.
+Cosby's conduct to the police. (Id. at 6). The
+| County District Attorney's Office
+investigated the allegations, but then-District Attorney Bruce Castor determined that "there was
+insufficient credible and admissible evidence" to bring criminal charges against Mr. Cosby. (Id. at
+7-10). Among the factors weighing against bringing charges were that (i) Ms. Constand had
+waited a year to file her complaint, which diminished the reliability of Ms. Constand's
+recollections; (ii) Ms. Constand's statements about the events were inconsistent; (iii) there was a
+lack of corroborating evidence; (iv) Ms. Constand continued to speak to and meet with Mr. Cosby
+' The opinion ("Op."*) is attached to this letter as Exhibit A.
+EFTA02832728
+
+Case 1:20-cr-00330-PAE Document 310 Filed 07/02/21 Page 2 of 3
+The Honorable Alison J. Nathan
+July 2, 2021
+Page 2
+after the assault; and (v) Ms. Constand had contacted civil attorneys to pursue financial
+compensation through a lawsuit against Mr. Cosby. (Id. at 9-10).
+DA Castor issued a signed public statement declining to prosecute Mr. Cosby, which he
+viewed as, and Mr. Cosby's lawyers understood to be, an agreement that Mr. Cosby would never
+be prosecuted for the events involving Ms. Constand. (Id. at 10-13, 16-18). Believing that he no
+longer had a basis to assert his Fifth Amendment rights, Mr. Cosby testified at several depositions
+in a civil suit brought against him by Ms. Constand and made inculpatory admissions. (Id. at 13-
+15). Ten years later, the successor District Attorney, Risa Vetri Ferman, used those admissions to
+charge Mr. Cosby with the same crimes related to the sexual assault of Ms. Constand that were
+covered by DA Castor's promise. (Id. at 18). Mr. Cosby was convicted of those charges at trial.
+(ld. at 38).
+The Pennsylvania Supreme Court held that DA Castor's promise was enforceable and that
+DA Ferman's prosecution of Mr. Cosby ten years later on the same charges violated his Due
+Process rights. (Id. at 78-79). As a result, the Court vacated Mr. Cosby's conviction. (Id. at 79).
+In so holding, the Court noted the following:
+Interactions between a prosecutor and a criminal defendant, including
+circumstances where the latter seeks enforcement of some promise or
+assurance made by the former, are not immune from the dictates of due
+process and fundamental fairness.
+(ld. at 55).
+The same principle applies to Ms. Maxwell's case. As in Cosby, the government is trying
+to renege on its agreement and prosecute Ms. Maxwell over 25 years later for the exact same
+offenses for which she was granted immunity in the NPA. Indeed, the principle applies even more
+strongly in Ms. Maxwell's case because the NPA was a formal written agreement, as opposed to
+an informal promise like the one in Cosby. This is not consistent with principles of fundamental
+fairness.
+Accordingly, for the reasons already set forth in our supplemental pretrial motions, and the
+principles discussed in Cosby, the Court should hold the government to its agreement and dismiss
+Counts One, Three, Five, and Six of the S2 Indictment.
+EFTA02832729
+
+Case 1:20-cr-00330-PAE
+Document 310
+Filed 07/02/21
+Page 3 of 3
+The Honorable Alison J. Nathan
+July 2, 2021
+Page 3
+Thank you for your attention to these matters.
+Respectfully submitted,
+/s/ Christian Everdell
+Christian R. Everdell
+& GRESSER LLP
+800 Third Avenue, 21st Floor
+New York, New York 10022
+(212) 957-7600
+ce: All Counsel of Record (By ECF)
+EFTA02832730

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vision-joined/court-04/849a87887449b9045a97fb8449ea97a40cb429fd1cd8a3489c47b9ce87953654.md

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+Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 1 of 2
+U.S. Department of Justice
+United States Attorney
+Southern District of New York
+The Silvio J. Mollo Building
+One Saint Andrew's Plaza
+New York, New York 10007
+July 7, 2020
+VIA ECE
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+United States Courthouse
+40 Foley Square
+New York, New York 10007
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+The Government respectfully submits this letter in connection with the Court's Order dated
+July 6, 2020 (the "Order") (Dkt. 7) and the defendant's letter of July 6, 2020 (the "Defense Letter")
+(Dkt. 8). Pursuant to the Order, the parties have conferred regarding the scheduling of an initial
+proceeding in the above-captioned case. As set forth in the Defense Letter, the parties are available
+to proceed remotely on the morning of July 14, 2020. Additionally, the parties jointly respectfully
+propose the following briefing schedule in connection with the Government's Memorandum in
+Support of Detention, dated July 2, 2020 (Dkt. 4):
+• Defense response to be due by 3:00 p.m. on Friday, July 10, 2020
+• Government reply to be due by 5:00 p.m. on Monday, July 13, 2020
+The Government also respectfully renews and amends its request that the Court exclude
+counsel regarding the terms of a protective order and initial discovery, to facilitate the production
+EFTA02829376
+
+Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 2 of 2
+Honorable Alison J. Nathan
+July 7, 2020
+Page 2
+of discovery, which will serve the interests of justice by facilitating the timely production of
+discovery materials. See 18 U.S.C. § 3161(h)(1)(F). I have conferred with defense counsel, who
+consent to this request.
+Very truly yours,
+AUPREY STRAUSS
+Acting United States Attorney
+Alex Rossmiller / Alison Moe / Maurene Comey
+Assistant United States Attorneys
+Southern District of New York
+Tel: (212) 637-2415
+Cc:
+Christian Everdell, Esq., and Mark |
+, Esq., counsel for defendant
+EFTA02829377

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vision-joined/court-04/84a3f09d1fee66d8726a8f9fdbf160e1fb8e37692f979767c18750249a0135bb.md

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+Case 1:15-cv-07433-LAP Document 971 Filed 07/10/19 Page 1 of 1
+BSF
+| BOIES
+| SCHILLER
+FLEXNER
+Sigrid S.McCawley, Esq.
+Telephone: (954) 356-0011
+Email: smccawley@bsfllp.com
+July 10, 2019
+VIA ECF
+The Honorable Judge Loretta A. Preska
+District Court Judge
+United States District Court
+500 Pearl Street
+New York, NY 10007
+Re:
+v. Maxwell,
+Case no. 15-cv-07433-LAP
+Dear Judge Preska:
+This firms represents the plaintiff,
+We welcome a conference with the
+Court tomorrow at 2:15 as scheduled. If the Court is inclined to move the conference, we reques
+hat it be scheduled as soon as possible. We also note that on the dates proposed by Maxwell'
+Counsel in is lester to the Court, we are not available on Augus 68 ur can be available on
+Sincerely,
+Is/ Sigrid McCawley
+Sigrid S. McCawley, Esq.
+SSM/
+Cc:
+Counsel of Record
+(via ECF)
+BOIES SCHILLER FLEXNER LLP
+401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfllp.com
+EFTA02805138

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vision-joined/court-04/84ce2882db1b94d246c744f7c22c114eda4e586569bfaea35a113cef45dfd98a.md

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+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 1 of 17
+EXHIBIT I
+EFTA02797387
+
+•
+Case 1:15-cv-07433-LAP
+Document 165-9 Filed 05/26/16 Page 2 of 17
+IN THE CIRCUIT COURT OF THE
+SEVENTEENTH JUDICIAL CIRCUIT, IN
+AND FOR BROWARD COUNTY, FLORIDA
+CASE NO.: CACE 15-000072
+and PAUL G.
+CASSELL,
+Plaintiff,
+VS.
+ALAN M. DERSHOWITZ,
+Defendant.
+DECLARATION OF
+and I was born in August, 1983.
+1. My name is
+2. 1 am currently 31 years old.
+3. 1 grew up in Palm Beach, Florida. When I was little, 1 loved animals and wanted
+to be a veterinarian. But my life took a very different turn when adults - including Jeffrey
+Epstein and his elose friend Alan Dershowitz -- began to be interested in having sex with me.
+4. In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is
+the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked
+that I come with her to Jeffrey Epstein's mansion for the purposes of teaching me how to
+perform "massages" and to train me professionally in that area. Soon after that I went to
+Epstein's home in Palm Beach on El Brillo Way.
+S. From the first time I was taken to Epstein's mansion that day, his motivations and
+actions were sexual, as were Maxwell's. My father was not allowed inside. I was brought up
+some stairs. There was a naked guy, Epstein, on the table in the room. Epstein and Maxwell
+forced me into sexual activity with Epstein. I was 15 years old at the time. He seemed to be in
+his 40s or 50s. 1 was paid $200. I was driven home by one of Epstein's employees.
+EXHIBIT
+5
+Giuffre
+AGREN BLANDO REPORTIN
+5/3/16 KAM
+GIUFFRE000383
+EFTA02797388
+
+Case 1:15-cv-07433-LAP Document 165-9
+Filed 05/26/16 Page 3 of 17
+6.1 came back for several days following and did the same sorts of sexual things for
+Epstein.
+7. After I did those things for Epstein, he and Maxwell said they were going to have me
+travel and were going to get an education for me. They were promising me the world, that I
+would travel with Epstein on his private jet and have a well-paid profession. Epstein said he
+would eventually match me up with a wealthy person so that I would be "set up" for life.
+8. So I started "working" exclusively for Epstein. He took me to New York on his big,
+private jet. We went to his mansion in New York City. I was shown to my room, a very
+luxurious room. The mansion was huge. I was very young and got scared because it was so big.
+Epstein brought me
+to a room with a massage parlor. Epstein made me engage in sexual activities with him there.
+9. You can see how young I looked in the photograph below.
+2
+GIUFFRE000384
+EFTA02797389
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 4 of 17
+10. Epstein took me on a ferry boat on one of the trips to New York City and there he
+took the picture above. 1 was approximately 15 or 16 years old at the time.
+11. Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to do
+what they wanted, including sexual activities. The training was in New York and Florida, at
+Epstein's mansions. It was basically every day and was like going to school. I also had to have
+sex with Epstein many times.
+12. 1 was trained to be "everything a man wanted me to be." It wasn't just sexual training
+- they wanted me to be able to cater to all the needs of the men they were going to send me to.
+They said that they loved that I was very compliant and knew how to keep my mouth shut about
+what they expected me to do.
+13. Epstein and Maxwell also told me that they wanted me to produce information for
+them in addition to performing sex on the men. They told to me to pay attention to the details
+about what the men wanted, so 1 could report back to them.
+14. While I had juvenile hopes of bettering my life, from very early on I was also afraid of
+Epstein. Epstein told me he was a billionaire. I told my mother that I was working for this rich
+guy, and she said "go, go far away." Epstein had promised me a lot, and 1 knew if I left I would
+be in big trouble. I was a witness to a lot of illegal and bad behavior by Epstein and his friends. If
+1 left Epstein, he knew all kinds of powerful people. He could have had me killed or abducted,
+and 1 knew he was capable of that if 1 did not obey him. He let me know that he knew many
+people in high places. Speaking about himself, he said "I can get away" with things. Even as a
+teenager, I understood what this meant and it scared me, as I believe he intended.
+15. 1 visited and traveled with Jeffrey Epstein from 1999 through the summer of
+3
+GIUFFRE000385
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+
+Case 1:15-cv-07433-LAP Document 165-9
+Filed 05/26/16 Page 5 of 17
+2002, and during that time I stayed with him for sexual activities at cach of his houses (or
+mansions) in locations including New York City, New York; the area of Santa Fe, New Mexico;
+Palm Beach, Florida; an island in the U.S. Virgin Islands; and Paris, France. I had sex with him
+often in these places and also with the various people he demanded that I have sex
+with. Epstein paid me for many of these sexual encounters. Looking back, 1 realize that my only
+purpose for Epstein, Maxwell and their friends was to be used for sex.
+16. To illustrate my connection to these places, 1 include four photographs taken of
+me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We
+had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the
+time, judging from the looks of it. At the end of the day we returned to Epstein's Zorro Ranch.
+The second picture is me on one of Epstein's horses on the ranch in New Mexico. The following
+two are from wintertime in New Mexico.
+GIUFFRE000386
+EFTA02797391
+
+Case 1:15-cv-07433-LAP
+Document 165-9
+Filed 05/26/16 Page 6 of 17
+17. When I was with him, Epstein had sex with underage girls on a daily basis. His
+interest in this kind of sex was obvious to the people around him. The activities were so obvious
+and bold that anyone spending any significant time at one of Epstein's residences would have
+clearly been aware of what was going on.
+18. Epstein's code word for sexual encounters was that it was a "massage". At times
+the interaction between Epstein and the girls would start in a massage room setting, but it was
+always a sexual encounter and never just a massage.
+19. In addition to constantly finding underage girls to satisfy their personal desires,
+Epstein and Maxwell also got girls for Epstein's friends and acquaintances. Epstein specifically
+told me that the reason for him doing this was so that they would "owe him," they would "be in
+his pocket," and he would "have something on them." I understood that Epstein thought he
+could get leniency if he was ever caught doing anything illegal, or that he could escape
+trouble altogether.
+5
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+EFTA02797392
+
+Case 1:15-cv-07433-LAP Document 165-9
+Filed 05/26/16 Page 7 of 17
+20. Harvard law professor Alan Dershowitz was around Epstein frequently. Dershowitz
+was so comfortable with the sex that was going on that on one occasion he observed me in sexua!
+activity with Epstein.
+21. I had sexual intercourse with Dershowitz at least six times. The first time was when 1
+was about 16, early on in my servitude to Epstein, and it continued until I was 19.
+22. The first time we had sex took place in New York in Epstein's home. It was in
+Epstein's room (not the massage room). I was approximately 16 years old at the time. I called
+Dershowitz "Alan." I knew he was a famous professor.
+23. The second time that I had sex with Dershowitz was at Epstein's house in Palm
+Beach.
+24. 1 also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico in the
+massage room off of the indoor pool area, which was still being painted.
+25. We also had sex at Little Saint James Island in the U.S. Virgin Islands.
+26. Another sexual encounter between me and Dershowitz happened on Epstein's
+airplane. Another girl was present on the plane with us.
+27. 1 have recently seen Alan Dershowitz on television calling me a "liar." He is lying by
+denying that he had sex with me. The man I've seen on television, described as a former law
+professor, is the same man that I had sex with at least six times. Dershowitz also knows that
+Epstein had sex with other underage girls and lent me out to other people, but he is lying and
+denying that as well.
+28. After years of abuse and being lent out, I began to look for a way to escape. I had first
+gone into Epstein's household because i wanted to be a massage therapist. Epstein had taken me
+6
+GIUFFRE000388
+EFTA02797393
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 8 of 17
+into his clutches through promises and talk and for some time 1 believed him. But once he had
+me under his control, regardless of my doubts and fears, I felt trapped.
+29.1 kept asking Epstein for my promised training and education. Epstein finally got me
+a plane ticket to Thailand to go to Chaing Mai to learn Thai massage. This sounded like my
+chance to escape. In September 2002, 1 packed my bags for good. I knew this would be my only
+opportunity to break away.
+30. On September 27, 2002, I flew from JFK in New York to Chaing Mai, Thailand. I
+arrived around September 29 for my training. But Epstein was going to get something out of this
+trip as well. I was supposed to interview a girl there and bring her back to the United States for
+Epstein.
+31.
+32. 1 did the massage training in Chiang Mai. While I was there, I met a great and special
+guy and told him honestly what I was being forced to do. He told me I should get out of it. I told
+him that the people I was working for were very powerful and that I could not walk away or
+disobey them without risking serious punishment, including my life. He told me he would protect
+me. I had confidence in him and I saw his love and help as my opportunity to
+escape and to be with someone who truly loved me and would protect me. I married him and
+flew to Australia.
+33. 1 called Epstein and told him I was not coming back. He asked why? I said "I've
+fallen in love." Epstein basically said "good luck and have a good life." I could tell he was not
+happy. I was afraid of what he was going to do to me. I thought he or one of his powerful friends
+might send someone to hurt me or have me killed.
+7
+GIUFFRE000389
+EFTA02797394
+
+Case 1:15-CV-07433-LAP Document 165-9 Filed 05/26/16 Page 9 of 17
+34. From that point onward, out of concern for my safety and general well-being, 1
+stayed in Australia with my husband. I was in Australia from late 2002 to October 2013. To be
+clear, 1 was never in the United States during these years, not even for a short trip to visit my
+mother. And my absence from the United States was not voluntary - I was hiding from Epstein
+out of fear of what he would do to me if I returned to the United States.
+35. In around 2007, after not hearing from anyone for years, out of the blue I was
+contacted by someone who identified himself with a plain sounding name and claimed he was
+with the FBI. It seemed very odd for someone doing an official criminal investigation to just call
+up on the phone like that. I hadn'i heard Epstein's name for years. I didn't know who this person
+was and what it was really about. I couldn't tell what was going on.
+36. This man said he was looking into Jeffrey Epstein. The man asked if I had been
+involved with Epstein. My first instinct was to say nothing because I wasn't sure he was really
+with the FBI or any authorities. I answered a few basic questions, telling him that I knew Jeffrey
+Epstein and had met him at a young age. But the conversation didn't feel right. This man never
+offered to come and meet with me in person. Instead, he asked me right off the bat about
+Epstein's sexual practices. I thought it would be strange for a true law enforcement officer to
+behave that way, so l became increasingly uncomfortable and suspicious about who was actualiy
+calling me.
+37. I told the man nothing more about Epstein. The conversation probably didn't even
+last three minutes, but it immediately triggered all of the fears of Epstein and his powerful
+friends that had caused me to escape in the first place. If the call accomplished anything, it only
+8
+GIUFFRE000390
+EFTA02797395
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 10 of 17
+put me back into a state of fear and told me that I could be found quite easily and had nobody
+official protecting me.
+38. I suspected that the man who called me was working for Epstein or one of Epstein's
+powerful friends. I believed that if this was really an agent who was investigating Epstein, he
+would have known who I was and how I fit into Epstein's sexual crimes in many different
+places. He would have interviewed me in a way that would have established his credentials and
+would have shown how he could provide potential protection from Epstein. That never
+happened.
+39. Getting a call from this supposed FBI Agent made me scared all over again. I had left
+that old life of sexual slavery behind me and started a new life in a new country in hopes that the
+powerful people whose illegal activities 1 knew all about would never find me.
+40. Shortly after this purported FBI call, I was contacted by telephone by someone who
+appeared clearly to be working for Epstein. The caller told me about an investigation into Epstein
+and said thai some of the girls being questioned were saying that Epstein had had sexual contact
+with them. After they made those allegations, the man said they were being discredited as drug
+addicts and prostitutes, but in my case, if I were to keep quiet, I would "be looked after." The
+fact that this call was made shortly after the supposed FBI call reinforced my concern that the
+man 1 had talked to earlier was not really working for the FBI but for Epstein. I didn't think that
+the FBI and Epstein would both be working together and would both get my phone number at
+almost exactly the same time. I played along and told this person that I had gotten a call from the
+"FBI" but that I didn't tell him anything. The person on the phone was pleased to hear that.
+9
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+EFTA02797396
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 11 of 17
+41. A short time later, one of Epstein lawyers (not Alan Dershowitz) called me, and then
+got Epstein on the line at the same time. Epstein and his lawyer basically asked again if 1 was
+going to say anything. The clear implication was that I should not. The way they were talking to
+me, I was afraid of what would happen if I didn't keep quiet. My thought was that if 1 didn't say
+what they wanted me to say, or not say, 1 might get hurt.
+42. 1 promised Epstein and his lawyer that I would keep quiet. They seemed happy with
+that and that seemed to me the way to keep me and my family safe. And I did what Epstein and
+his lawyer told me to do. I kept quiet.
+43. 1 now understand that Epstein reached a non-prosecution agreement with the federal
+government in 2007 and pled guilty to two state crimes in June 2008. No one told me anything
+about those events until much later. In fact, nobody called or came to see me to explain what a
+non-prosecution agreement was, what crimes Epstein could have been charged with, why he was
+not being charged with the crimes he had committed, or anything whatsoever about the case. I
+was never offered a chance to meaningfully confer with the prosecutor for the Government, and I
+was never notified of any hearing that could affect me or my rights as a crime victim to ever
+bring charges.
+44. On September 3, 2008, the FBI sent a victim notification letter to me. This was the
+first written communication I had received from the FBI. The letter was attached as Exhibit I to
+my earlier statement. This kind of written communication, on official FBI stationary, is the way
+that I thought the FBI really communicated with people that they wanted to talk to. The fact that
+I got this official letter from them made me wonder even more whether the cali I had received
+10
+GIUFFRE000392
+EFTA02797397
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 12 of 17
+earlier was really from the FBI. The letter that I got did not mention that anyone from the FBI
+had ever called me before.
+45. The letter started off with the sentence: "By virtue of this letter, the United States
+Attorney's Office for the Southern District of Florida provides you with the following notice
+because you are an identified victim of a federal offense." That sentence (among others) made it
+seem like this was the first time the FBI was officially contacting me. That was the first time i
+was told about my rights as a crime victim.
+46. 1 did not know what was happening about any criminal prosecution of Epstein at this
+time. I wanted him prosecuted. And given his constant illegal sexual behavior, I thought it was
+obvious that he should be prosecuted. But after reading the letter, I was confused. The letter did
+not explain what was actually happening or what role, if any, I could play. In fact, the letter
+thanked me for my assistance during the investigations, yet made no reference to what this
+supposed "assistance" consisted of.
+47. Also, the letter did not directly say that Epstein's crimes against me were not going to
+be prosecuted. It just said that "the United States has agreed to defer federal prosecution in favor
+of this state plea and sentence ...." I did not know what that meant. The letter did not inform me
+how it applied to me. The letter also said that there was "litigation between the United States and
+two other victims regarding the disclosure of the entire agreement between the United States and
+Mr. Epstein." Understanding more about that case now, I realize that the letter did not explain
+that the real purpose of that litigation was not to get "disclosure of the entire agreement" but
+instead to get criminal charges filed against Epstein and to seemingly uphold the rights of
+Epstein's victims. I wish that the Government had told me what was really going on.
+GIUFFRE000393
+EFTA02797398
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 13 of 17
+48. I saw on the letter that I could call a lawyer. The letter also mentioned Jack
+Goldberger, who 1 knew to be Epstein's attorney, which scared me. 1 first got in touch with the
+attorneys at the Podhurst Orseck firm. My lawyers filed a lawsuit against Epstein for me, which
+mentioned that 1 was abused by Epstein and other powerful people. I was hoping that the
+information I gave as part of my lawsuit might help to put Epstein in prison, but the lawsuit
+ended up just being about money, which Epstein paid to settle.
+49.1 continued living in Australia and, in 2011, was contacted by a journalist, who told
+me she was working for a British newspaper. She asked me if I had information about Prince
+Andrew. When I said that I did, she came out to Australia to meet with me.
+50. At this point, since nothing else seemed to be working to get Epstein and his
+associates held accountable, I wanted to try by myself to get a message out to the public about
+what Epstein and his friends had done to me and other girls. I was very disturbed that no one was
+prosecuting Epstein for these crimes. I was also very scared. It seemed that law enforcement was
+not doing anything with the information they knew about me, which left me and my family
+vulnerable and fearful.
+51. The journalist printed an article using some of the information I told her. Shortly after
+the article was published, I talked on the phone to
+Villafaña, a federal prosecutor from
+Florida. I had seen her name on the official letter from the FBI, so she seemed legitimate.
+Villafaña seemed very interested in my case and seemed as if she wanted to do something.
+52. Within a few weeks of the newspaper article being published, two FBi agents also
+called me in Australia and then came to meet me. In around March 2011, they met me at the
+U.S. Consulate in Sidney. They seemed to be very professional and hard working. I thought that
+12
+GIUFFRE000394
+EFTA02797399
+
+Case 1:15-cv-07433-LAP Document 165-9 |
+Filed 05/26/16
+Page 14 of 17
+I had finally gotten the attention of the people that I wanted and that these people would do the
+right things against Epstein and the others. I also thought that they could protect me.
+53. When I met with the agents, they mainly focused on Epstein. But while I was at the
+Consulate, 1 provided them some information about some of the others who were involved in
+illegal acts as well. I was aware that a false statement to these law enforcement officers was a
+crime and I told the truth, giving them information I could recall about the individuals they
+inquired about.
+54. The agents were clearly prepared to meet me and already knew a lot about Epstein's
+crimes. The agents appeared to be very good at investigating and seemed like they really knew
+how to piece together the whole story. But at the same time, they seemed like they were being
+blocked from doing what they wanted to do - which I thought was to arrest Epstein and his
+powerful friends for all of their illegal sexual crimes.
+55. Shortly after the FBI interview in 2011, I spoke to attorney Brad
+He told
+me he had been sued by Jeffrey Epstein and wanted to know what I knew about Epstein and his
+associates' involvement with sexually abusing underage girls. I told him about my abuse and
+trafficking by Epstein. I also told him at that time that I had been sexually abused by Ghislaine
+Maxwell, Alan Dershowitz, and other powerful people.
+56. In around April 2011, as a follow-up to my earlier call with Brad
+I got a
+telephone call from him and another attorney, Jack Scarola. He and his firm wanted general
+information about whether various people had information relevant to the lawsuit. They told me
+that they were taping the conversation, and I had no problem with that. I cooperated with them
+and gave them information about which people had information relevant about Epstein's crimes.
+13
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+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 15 of 17
+57. Because it was over the phone and we did not know each other, they were polite and
+did not ask me a lot of details about specifically who i had sex with and what explicit sexual
+activities I was forced to participate in. It was a general, background interview.
+58. As the months following the FBI meeting in Sydney passed, I was trying to be patient
+but I began wondering what was going on with regard to prosecuting Epstein. I continued to be
+confused about what was happening. I was hoping that some kind of prosecution would come out
+of these events, but when nothing came of them, I got upset. I wanted to do something to stop
+Epstein and the other people he associates with from continuing to sexually abuse girls. Law
+enforcement had taken my detailed statements, but nothing seemed to be happening. I wasn't
+sure what to do.
+59. While I wanted to do what I could to get justice for what had happened to me, it was
+very hard for me to figure out how to get something done in the United States while living in a
+foreign country, especially after 1 had already gave information to the FBl that I believed they
+were using to investigate and eventually arrest Epstein.
+60. To further my effort to Prevent Sexual Abuse and Sex Trafficking 1 founded the non-profit
+organization "Victims Refuse Silence" - www.victimsrefusesilence.org. I know that I can't stop
+abuse everywhere, but if 1 help save even a few victims from the kind of degradation I
+experienced I will have made a positive difference.
+61. 1 asked two attorneys - Brad
+and Paul Cassell - to see if they could help me
+bring Epstein and his friends to justice. They agreed to try to add me to the existing CVRA case.
+They explained to me that the lawsuit was not asking to get money from Epstein or others. I
+14
+GIUFFRE000396
+EFTA02797401
+
+Case 1:15-cv-07433-LAP Document 165-9
+Filed 05/26/16 Page 16 of 17
+understand and have always understood that the goal of the case is to enforce my rights as a
+crime victim, rights that were unfairly taken away from me.
+62. Epstein and his friends sexually and physically abused many other girls. They did this
+in many places around the world. I personally observed this. There are also many people who
+could confirm what I am saying. I hope that these people will come forward and tell the truth.
+63. The trafficking of underage girls is a major problem in the United States and
+elsewhere. I will continue to cooperate fully in the investigation and prosecution of Epstein,
+Maxwell, or any of their friends who participated in the sexual abuse of minors. I also hope that
+this information is treated in a way that will keep me safe from Epstein and others identified here
+so as to encourage more victims of similar crimes to come forward. If these crimes are not
+prosecuted, despite my volunteering this information and cooperation, other victims will be
+deterred from coming forward.
+64. In this affidavit, I have tried to focus on how I was trafficked for sexual purposes.
+I have not described all of the details of the sexual activities Epstein forced me to have. Aiso, I
+have not described all of the details of the other events discussed here. If a judge wants me to
+present my information in more detail, including specific descriptions of the sexual behaviors,
+likes and dislikes of the men Epstein sent me to, I could do so.
+65. 1 have directed my attorneys, including
+J.
+and Paul G. Cassell, to
+pursue all reasonable and legitimate means to have criminal charges brought against these
+powerful people for the crimes they have committed against me and other girls. They are
+presenting me in Jane Doe 1 and Jane Doe 2 v. United States (S.D. Fla.) pro bono.
+15
+GIUFFRE000397
+EFTA02797402
+
+Case 1:15-cv-07433-LAP Document 165-9 Filed 05/26/16 Page 17 of 17
+66. Because of how often Epstein and others were having sex with young oris, and how
+much it was a denserpicce of their thes, I doubt that they have stopped, It also sooms to mo that,
+When 1 ktiew them, they believed that they were above the law, 700 poweiful to be prostouted
+That feeling has no doubt been reinforced by the fact Epstein has escape serious pumisbment with
+his plea bargain, and the othem with whom he traveled have completely escaped the
+consoquanoes of their actions. I hope that I can bring them to justice.
+67. No one has pressured ine into identifyng Allen Dershowit as one of tipsiein's
+friends who sextally abused me, Tidentified him because he abosed me, authorized the public
+fling of my two affidavits in the Jane Dot L and Jane 2 case because those affidavits wero the
+truth,
+6 Since t filed my molor in the Jane Dee I and June 2 cast, ity credibility has boon
+stacked, including extracidinary and persistent public atbroks by Alan Dershowitz oo me and
+my ahomeys who bolioved in mo. Tam telling the truth and will not let these attacks prevent me
+from exposing the fruth of how T as trafficked for sex to many powerful people.
+69. 1 declare under penalty of penury that the foregoing is mie and corect
+Excouted this 20tay of November, 20TS. (locarion of signature left undisclosed te
+inty reasons)
+A 16
+:16
+GIUFFRE000398
+EFTA02797403

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+EXHIBIT A
+(FILED UNDER SEAL)
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vision-joined/court-04/84f64515af9d7b99633a3afe3f675a89ce5ec3974d780fc6f8832afd346e2116.md

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+Case 1:15-cv-07433-LAP Document 371 Filed 08/12/16
+Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+---X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+Declaration Of Laura A. Menninger In Support Of Defendant's Motion
+For Protective Order Regarding Personal Financial Information
+1, Laura A. Menninger, declare as follows:
+I am an attorney at law duly licensed in the State of New York and admitted to
+practice in the United States District Court for the Southern District of New York. I am a
+member of the law firm Haddon,
+_&
+P.C., counsel of record for Defendant
+Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of
+Defendant's Motion for Protective Order Regarding Personal Financial Information.
+2.
+Attached as Exhibit A is a true and correct copy of Request for Production
+Numbered 21-43 from Plaintiff's Second Request for Production of Documents to Defendant
+Ghislaine Maxwell dated April 14, 2016.
+Attached as Exhibit B is a true and correct copy of Defendant Ghislaine
+Maxwell's Responses and Objections to Requests Numbered 21-43 from Plaintiff's Second
+Request for Production of Documents dated May 16, 2016.
+Attached as Exhibit C (filed under seal) is a true and correct copy l
+EFTA02800338
+
+Case 1:15-cv-07433-LAP Document 371 Filed 08/12/16 Page 2 of 2
+Dated: August 12, 2016
+By: Is/ Laura A. Menninger
+Laura A. Menninger
+CERTIFICATE OF SERVICE
+I certify that on August 12, 2016, I electronically served this Declaration Of Laura A.
+MenningerIn Support Of Defendant's Motion for Protective Order Regarding Personal
+Financial Information via ECF on the following:
+Sigrid S. McCawley
+Meredith
+BOIES, SCHILLER & FLEXNER, LLP
+401 East Las Olas Boulevard, Ste. 1200
+Ft. Lauderdale, FL 33301
+smccawley@bsfllp.com
+mschultz@bsfllp.com
+Paul G. Cassell
+383 S. University Street
+Salt Lake City, UT 84112
+cassellp@law.utah.edu
+J. Stanley Pottinger
+49 Twin Lakes Rd.
+South Salem, NY 10590
+StanPottinger@aol.com
+JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L.
+425 North Andrews Ave., Ste. 2
+Ft. Lauderdale, FL 33301
+brad@pathtojustice.com
+Is/ Brenda Rodriguez
+2
+EFTA02800339

vision-joined/court-04/84ff8c8701b825f9598ed4fc76bffa2c81afeb8e5d2ae058d85022c1358c37b0.json

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vision-joined/court-04/84ff8c8701b825f9598ed4fc76bffa2c81afeb8e5d2ae058d85022c1358c37b0.md

@@ -0,0 +1,95 @@
+CG
+Case 1:20-cr-00330-PAE Document 230
+& GRESSER LLP
+Filed 04/21/21 Page 1 of 3
+800 Third Avenue
+New York, NY 10022
++1 212 957 7600 phone
+www.cohengresser.com
+Christian R. Everdell
++1 (212) 957-7600
+ceverdell@)cohengresser.com
+April 21, 2021
+BY ECF
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+Pursuant to the Court's Opinion and Order, dated April 16, 2021 (Dkt. 207), the parties
+have met and conferred about a schedule for the remaining pretrial disclosures and other pretrial
+motions practice. Although Ms. Maxwell maintains that a continuance of the trial date is
+necessary to ensure a fair trial for the reasons we will set forth in our letter to the Court tomorrow,
+we have discussed with the government disclosure dates assuming the trial begins on July 12,
+2021.
+The following schedule indicates the areas of agreement and disagreement between the
+parties. Areas of agreement include dates proposed by both parties (in bold). Areas of
+disagreement include dates proposed by the defense (in bold) and dates proposed by the
+government (underlined).
+Parties Agree
+Government Expert Witness Disclosure
+April 23 - Government expert disclosure
+EFTA02831765
+
+Case 1:20-cr-00330-PAE
+Document 230
+Filed 04/21/21 Page 2 of 3
+The Honorable Alison J. Nathan
+April 21, 2021
+Page 2
+Supplemental Pretrial Motions
+• May 7 - Defense supplemental motions due
+• May 21 - Government's response due
+• May 28 - Defense replies due
+Identities of the Accusers
+• May 17 - Government will disclose the identities of the accusers to the defense
+Motions in limine
+• June 14 - Simultaneous filing of motions in limine by government and defense
+• June 28 - Simultaneous responses due
+Requests to Charge. Verdict Sheet, Proposed Voir Dire
+• June 25 - Parties submit these materials to the Court
+Jury Questionnaire and Pretrial Conferences
+• June 18 - Parties submit proposed jury questionnaires to the Court
+• Week of June 28 - Prospective jurors complete jury questionnaire
+• July 1 - Pretrial conference; parties receive completed jury questionnaires
+• July 9 - Final pretrial conference; parties exercise challenges based on jury
+questionnaires
+Parties Disagree
+Government Pretrial Disclosures
+• May 17 (eight weeks before trial) - the following government pretrial disclosures due:
+• Jencks Act/3500 material
+• 404(b) notice
+• Giglio material (any Brady material should be produced immediately)
+• Co-conspirator statements
+• Government witness list
+• Government exhibit list
+• The government proposes May 28 to produce Jencks Act/3500 material, 404(b) notice,
+Giglio material, and its witness list
+• The government proposes June 11 to produce its exhibit list and marked exhibits
+Defense Expert Witness Disclosure
+• June 14 - Defense expert disclosure
+• The government proposes May 14 for the defense to provide its expert witness
+disclosure
+EFTA02831766
+
+Case 1:20-cr-00330-PAE Document 230 Filed 04/21/21 Page 3 of 3
+The Honorable Alison J. Nathan
+April 21, 2021
+Page 3
+Defense Pretrial Disclosures
+• July 1 - Preliminary disclosure of information subject to Rule 16(b)(1)(A) and
+16(b)(1)(B)
+• The government proposes June 11 for the defense to disclose this information, as well
+as its witness list and witness statements pursuant to Rule 26.2.
+Sincerely,
+/s/ Christian Everdell
+Christian R. Everdell
+& GRESSER LLP
+800 Third Avenue, 21st Floor
+New York, New York 10022
+(212) 957-7600
+ce: All Counsel of Record (By ECF)
+EFTA02831767

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vision-joined/court-04/8504d943a5e563ff8dac8e70a9c059af56b9cb316f9065f0cabd2ede698c14a2.md

@@ -0,0 +1,127 @@
+Case 1:20-cr-00330-AJN Document 47 Filed 08/21/20 Page 1 of 4
+U.S. Department of Justice
+United States Attorney
+Southern District of New York
+The Silvio J. Mollo Building
+One Saint Andrew's Plaza
+New York, New York 10007
+August 21, 2020
+TO BE FILED PARTIALLY UNDER SEAL
+BY ECF & ELECTRONIC MAIL
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+United States Courthouse
+40 Foley Square
+New York, New York 10007
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+The Government respectfully submits this letter to propose certain redactions to the
+defendant's letter of August 17, 2020 (the "Defense Letter") and to request that the exhibits
+attached to the Defense Letter be filed under seal during the pendency of an ongoing grand jury
+investigation. For the reasons set forth below, the Government respectfully requests that the Court
+permit the filing of the Defense Letter with the proposed redactions contained in Exhibit A hereto
+(which itself will be submitted to the Court under seal), and that the Court permit all of the exhibits
+to the Detense Letter to be filed under seal. The Government does not object to the public filing
+of the affidavit attached to the Defense Letter in unredacted form. Additionally, the Government
+will file a redacted version of this letter on the public docket, and separately will submit an
+unreduced version to the Court.
+As an initial matter, the proposed redactions, and the request that the exhibits be filed under
+seal, are consistent with the Government's designation of the underlying material as "Confidential"
+within the meaning of the Protective Order in this case. See Protective Order 9 15 (Dkt. 36).
+Moreover, as detailed more fully in the Government's companion submission, that designation is
+appropriate given the nature of the documents at issue, all of which pertain to the Government's
+pending grand jury investigation.' That alone strongly weighs in favor of permitting the redactions
+and sealed filings at issue: Federal Rule of Criminal Procedure 6(e)(6) provides, in relevant part,
+' To the extent it would be useful to this Court for the Government to further elaborate on the
+nature of the ongoing grand jury investigation, the Government is prepared to file a supplemental
+letter specifically on that subject ex parte and under seal should the Court request such an
+explanation.
+EFTA02829575
+
+Case 1:20-cr-00330-AJN Document 47 Filed 08/21/20 Page 2 of 4
+Honorable Alison J. Nathan
+August 21, 2020
+Page 2
+that "[r]ecords, orders, and subpoenas relating to grand-jury proceedings must be kept under seal
+to the extent and as long as necessary to prevent the unauthorized disclosure of a matter occurring
+before a grand jury."
+Relatedly, the exhibits at issue—all of which pertain to several ex parte applications made
+by the Government—have previously been ordered to kept under seal by the relevant judicial
+officers, who have made the requisite findings to warrant sealing. The requested redactions and
+sealing would thus be necessary to ensure compliance with those sealing orders and is justified
+based upon them.? Cf. Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979)
+("Since the 17th century, grand jury proceedings have been closed to the public; and records of
+such proceedings have been kept from the public eye. The rule of grand jury secrecy ... is an
+integral part of our criminal justice system.").
+Assuming without agreeing that these materials constitute "judicial documents" within the
+meaning of First Amendment right-of-access jurisprudence, such a determination would not be
+dispositive. The First Amendment presumptive right of access applies to civil and criminal
+proceedings and "protects the public against the government's arbitrary interference with access
+to important information." N.Y. Civil Liberties Union v. N.Y.C. Transit Auth. ("NYCTA"), 684
+F.3d 286, 298 (2d Cir. 2012) (internal quotation marks omitted). The Circuit has applied two
+different approaches when deciding whether the First Amendment right applies to particular
+The "experience-and-logic" approach asks "both whether the documents have
+historically been open to the press and general public and whether public access plays a significant
+positive role in the functioning of the particular process in question." Lugosch v. Pyramid Co. of
+Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (internal quotation marks omitted). The second
+approach —employed when analyzing judicial documents related to judicial proceedings covered
+by the First Amendment right—asks whether the documents at issue "are derived from or are a
+necessary corollary of the capacity to attend the relevant proceedings." Id. (internal quotation
+marks and alteration omitted).
+Even when it applies, the First Amendment right creates only a presumptive right of access,
+and the "presumption is rebuttable upon demonstration that suppression *is essential to preserve
+higher values and is narrowly tailored to serve that interest.'" Hartford Courant Co. v. Pellegrino,
+380 F.3d 83, 96 (2d Cir. 2004) (quoting Press-Enterprise Co. v. Superior Court of Cal., Riverside
+Cnty., 464 U.S. 501, 510(1984)) (internal citation omitted). "What offends the First Amendment
+is the attempt to [exelude the public] without sufficient justification," NYCTA, 684 F.3d at 296,
+not the simple act of exclusion itself. Thus, the presumptive right of access may be overcome by
+"specific, on-the-record findings that sealing is necessary to preserve higher values and only if the
+sealing order is narrowly tailored to achieve that aim." Lugosch, 435 F.3d at 124.
+2 The only exceptions to those sealing orders are the permission contained in a certain order issued
+in April 2019, namely that the order itself may be provided to the recipient of a subpoena, and,
+pursuant to separate permissions the Government has obtained in connection with its discovery
+obligations, that the entirety of the relevant filings may be provided to the defendant as discovery
+in this criminal case.
+EFTA02829576
+
+Case 1:20-cr-00330-AJN Document 47 Filed 08/21/20 Page 3 of 4
+Honorable Alison J. Nathan
+August 21, 2020
+Page 3
+Here, even assuming the materials at issue constitute judicial documents, any presumption
+in favor of access is overcome because of the nature of the documents themselves, namely
+materials related to a grand jury investigation.
+As described above, the grand jury investigation is active and ongoing, and resulted in new
+charges being brought just last month in this case.
+In sum, the Government respectfully submits that the exhibits to the Defense Letter, which
+consist entirely of filings that have been ordered sealed by other judicial officers, should similarly
+be filed under seal in this case while the grand jury investigation remains ongoing. For the same
+reasons, the Government proposes redacting any portions of the Defense Letter that
+Accordingly, the Government respectfully requests that the Court permit the redactions to
+the Defense Letter proposed in Exhibit A hereto and that both the unredacted Defense Letter and
+the exhibits thereto remain under seal until further order of the Court. Additionally, because the
+instant letter discusses the Government's ongoing investigation and references
+the Government also respectfully requests that it be permitted to
+file a redacted version of this letter on the public docket and that the unredacted version of this
+letter as well as Exhibit A to this letter be filed under seal.
+EFTA02829577
+
+Case 1:20-cr-00330-AJN Document 47 Filed 08/21/20 Page 4 of 4
+Honorable Alison J. Nathan
+August 21, 2020
+Page 4
+Finally, the Government respectfully proposes that the Court set a date approximately 180
+days from now, or as soon thereafter as the Court believes would be appropriate, for the
+Government to update the Court on its position regarding sealing in connection with this matter.
+Respectfully submitted,
+AUDREY STRAUSS
+Acting United States Attorney
+By:
+Is
+Maurene Comey / Alison Moe / Lara Pomerantz
+Assistant United States Attorneys
+Southern District of New York
+Tel: (212) 637-2324
+Cc: All counsel of record, by email
+EFTA02829578

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vision-joined/court-04/85bbe4ad76b02f9d0d412d020a9031252ecb55a6e50f09b6efad0c0ff85cdd42.md

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+Case 1:20-Cr-00330-PAE Document 527 Filed 12/05/21 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:_
+DATE FILED: 12/5/21
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+ORDER
+Defendant.
+ALISON J. NATHAN, District Judge:
+The Court is in receipt of the Government's letter motion regarding the limiting
+instruction for Witness-3's anticipated testimony. The Government is hereby ORDERED to file
+an additional letter explaining what details regarding the alleged sexual activity the Government
+would seek to elicit absent instruction from the Court and in light of the Defense's opening. The
+Government's letter must be submitted no later than today, December 5, 2021, at 4:00 p.m.
+With that information, the Defense can respond to and the Court can analyze the Government's
+requested addition in the limiting instruction. Accordingly, the Defense is ORDERED to
+respond to the Government's letter motion and further response letter no later than today,
+December 5, 2021, at 7:00 p.m.
+In their letter responses the parties shall be mindful of Rule 412's requirement
+regarding sealing.
+SO ORDERED.
+Dated: December 5, 2021
+New York, New York
+Ali So Notor
+ALISON J. NATHAN
+United States District Judge
+EFTA02836074

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vision-joined/court-04/85bc0ccd2da0154de0dc2ba4ce02eacefe81a8b29e77c43c96ee926ad10a91d9.md

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+Case 1:15-cv-07433-LAP Document 992
+Filed 10/02/19
+Page 1 of 5
+RICHARD D. EMERY
+ANDREW G. CELLI, JR.
+MATTHEW D. BRINCKERHOFF
+JONATHAN S. ABADY
+ILANN M. MAAZEL
+HAL R.
+DANIEL J. KORNSTEIN
+O. ANDREW F. WILSON
+ELIZABETH S. SAYLOR
+KATHERINE ROSENFELD
+DEBRA L. GREENBERGER
+ZOE SALZMAN
+SHAPIRO
+EMERy CellI BRINCKERHOFF & ABady LLP
+ATTORNEYS AT LAW
+600 FIFTH AVENUE AT ROCKEFELLER CENTER
+10™ FLOOR
+NEW YORK, NEW YORK 10020
+TEL: (212) 763-5000
+FAX: (212) 763-5001
+www.ecbalaw.com
+DIANE L. HOUK
+EM•L. FREEMAN
+DAVID BERMAN
+ASHOK CHANDRAN
+HARVEY PRAGER
+SCOUT KATOVICH
+October 2, 2019
+Via ECF
+Hon. Loretta A. Preska
+United States District Judge
+Daniel
+Moynihan United States Courthouse
+500 Pearl St.
+New York, NY 10007-1312
+Re:
+v. Maxwell, No. 15 Civ. 07433
+Dear Judge Preska:
+We represent Intervenor Alan M. Dershowitz. We write pursuant to Your Honor's
+September 5, 2019 Order (ECF No. 982) to oppose Defendant Ghislaine Maxwell's proposal to
+maintain various parts of the record under seal. That proposal contravenes the Second Circuit's
+clear mandate in
+v. Maxwell, 929 F.3d 41 (2019), and should be rejected out of hand.
+This submission addresses the categories of filings set forth in Maxwell's brief (ECF No. 991).
+Categories 1 and 7: Motions to Compel and Related Discovery Motions. Maxwell
+overstates the law in contending that discovery motions categorically "are not judicial documents
+and therefore are not afforded a presumption of access," ECF No. 991 at 5. As courts in this
+Circuit had repeatedly held even before
+"[where, as here, the disputed documents are
+filed in support of or in opposition to a discovery motion other than a motion as to the
+discoverability or confidentiality of the disputed documents themselves, they are properly
+EFTA02805391
+
+Case 1:15-cv-07433-LAP Document 992
+Filed 10/02/19 Page 2 of 5
+EMERY CellI BRINCKERHOFF & ABADY LLP
+Page 2
+deemed 'judicial documents,' requiring the court to balance the public access presumption
+against the competing considerations identified by the party seeking to seal them."
+Park
+Investments SA/NV v. Deutsch Bank Nat'I Trust Co., No. 14 Civ. 04394, 2016 WL 7188795, at
+*2 (S.D.N.Y. Dec. 7, 2016) (collecting authorities). In
+the Second Circuit specifically
+recognized that "erroneous decision-making with respect to such evidentiary and discovery
+matters can cause substantial harm" and that such motions are therefore of value to those
+monitoring the federal court," rendering them "subject to at least some presumption of public
+access." 929 F.3d at 50. This Court should heed the Second Circuit's teaching that "a court
+must still articulate specific and substantial reasons for sealing such material," id., and decline to
+seal these documents without a particularized showing that satisfies the First Amendment.
+To the extent Maxwell contends that documents concerning third parties who "were
+compelled to participate in the discovery process" are presumptively entitled to sealing, see ECF
+No. 991 at 19, she is wrong. Compelling testimony is a quintessential exercise of coercive
+judicial power that the public is entitled to monitor. See United States v. Bryan, 339 U.S. 323,
+331-32 (1950) (elaborating the importance of balancing "the great power of testimonial
+compulsion" against exemptions "grounded in a substantial individual interest which has been
+found, through centuries of experience, to outweigh the public interest in the search for truth").
+Judicial decisions compelling disclosure—which "carry the threat of coercive sanctions and seek
+to enforce the court's own orders," Newsday LLC v. Cnty. of Nassau, 730 F.3d 156, 164 (2d Cir.
+2013)—are no less subject to public monitoring than other exercises of government power.
+Categories 2, 3, 4 and 5: Motions in Limine, Deposition Designations, and
+Objections to Deposition Designations. As with discovery motions, the Second Circuit made
+clear in
+that "a court's authority to ... control the evidence introduced at trial surely
+EFTA02805392
+
+Case 1:15-cv-07433-LAP Document 992
+Filed 10/02/19 Page 3 of 5
+EMERY CellI BRINCKERHOFF & ABADY LLP
+Page 3
+constitutes an exercise of judicial power" and therefore held that motions relating to the
+presentation of trial evidence are subject to the presumption of access, albeit in a somewhat
+weaker form than would apply to trial evidence itself or to dispositive motion filings. Id. The
+Second Circuit specifically concluded that "insofar as the District Court held that privacy
+interests outweigh the presumption of public access in each of the thousands of pages at issue,
+that decision —which appears to have been made without particularized review—amounts to an
+abuse of discretion." Id. at 50-51. The Circuit's conclusion that "specific and substantial
+reasons" are required to seal such documents, id. at 50, is irreconcilable with Maxwell's claim
+that the presumption of access to them is "negligible," ECF No. 991 at 7, 12.
+Likewise, Maxwell's assertions that the presumption of access is overcome by the fact
+that the documents were covered by a protective order or because they relate to third parties are
+shopworn red herrings that the Second Circuit has repeatedly rejected and are exactly the type of
+non-particularized boilerplate that cannot justify sealing of judicial documents. "[T]he mere
+existence of a confidentiality order says nothing" about whether particular judicial documents
+should be sealed, Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2016),
+because judicial documents are immune from the general presumption against disclosure that
+applies to documents subject to a protective order; they "deserve a presumption in favor of
+access" irrespective of any protective order. S.E.C. v. TheStreet.com, 273 F.3d 222, 231 (2d Cir.
+2001). Thus, "the facts necessary to show good cause for a protective order [for non-judicial
+discovery documents] will not necessarily meet the threshold imposed by the First Amendment
+with respect to judicial documents." Newsday, 730 F.3d at 166 (finding it was error to rely
+"solely on the prior finding of good cause to determine that the First Amendment right did not
+apply or was outweighed by countervailing factors").
+EFTA02805393
+
+Case 1:15-cv-07433-LAP Document 992
+Filed 10/02/19 Page 4 of 5
+EMERY CellI BRINCKERHOFF & ABADY LLP
+Page 4
+Nor can Maxwell defend sealing on the basis that the district court never ruled on certain
+pretrial disputes. The Second Circuit rejected this precise premise in
+holding that "the
+proper inquiry is whether the documents are relevant to the performance of the judicial function,
+not whether they were relied upon." 929 F.3d at 50 (Indeed, decision-makers often find that a
+great deal of relevant material does not ultimately sway their decision."). The Court cannot, as
+Maxwell suggests, retroactively rule on the in limine motions by determining that the matters
+they concern would not ultimately have been admissible at trial and then seal the filings on that
+ground. See Lugosch, 435 F.3d at 123 ("If the rationale behind access is to allow the public an
+opportunity to assess the correctness of the judge's decision, documents that the judge should
+have considered or relied upon, but did not, are just as deserving of disclosure as those that
+actually entered into the judge's decision." (internal quotation marks and ellipsis omitted)).
+Particularized review and unsealing are required.
+Category 6: Filings Related to Intervention Motions. Dershowitz specifically waives
+and disclaims any privacy interest in any of these documents- most of which were sealed as a
+result of confidentiality designations applied by Plaintiff
+-and urges the Court
+to unseal them. In general, intervention motions—whose purpose is to determine parties' rights
+to participate in an actionare clearly judicial documents to which the presumption of access
+attaches.
+"There is a strong presumption of access to such materials, as they 'directly affect'
+courts' adjudication of issues." Wells Fargo Bank, N.A. v. Wales LLC, 994 F. Supp. 2d 409, 413
+(S.D.N.Y. 2014) (holding that exhibits submitted in connection with motion to intervene are
+"clearly" judicial documents). That presumption applies here with full force.
+Category 8: Case Management Documents. It is unclear why documents relating to
+routine case management issues were ever sealed at all, or what facts could possibly justify their
+EFTA02805394
+
+Case 1:15-cv-07433-LAP Document 992
+Filed 10/02/19 Page 5 of 5
+EMERY CellI BRINCKERHOFF & ABADY LLP
+Page 5
+continued sealing at this juncture. Although the precise nature of these documents is unknown,
+the law by no means dictates that case management documents are categorically entitled to no
+presumption of access. This Second Circuit has recognized that a district court's case
+management decisions may "affect a party's substantial rights." Long Island Lighting Co. v.
+Barbash, 779 F.2d 793, 795 (2d Cir. 1985). Accordingly, courts in this Circuit have repeatedly
+recognized that filings submitted in connection with a motion to alter the pace or schedule of
+litigation are subject to public access. See, e.g., Lenart v. Coach Inc., 131 F. Supp. 3d 61, 72
+(S.D.N.Y. 2015) (applying presumption of public access to "papers filed in connection with [a]
+motion to stay"); accord Skyline Steel, LLC v. PilePro, LLC, No. 13 Civ. 8171, 2015 WL
+556545, at *4 (S.D.N.Y. Feb. 9, 2015). Case management documents should not remain sealed
+absent a particularized showing justifying continued confidentiality as to individual documents.
+Category 9: Motions for Adverse Inferences or Sanctions and Motions to Strike or
+Exclude Evidence. Documents in this category indisputably merit a presumption of public
+access. As the Second Circuit observed in holding that the presumption of access applies to civil
+contempt proceedings, judicial documents relating to a court's power to impose "coercive
+sanctions" are crucial to the governmental accountability that the First Amendment exists to
+bolster. Newsday, 730 F.3d at 164. There is no basis for the presumption urged by Maxwell that
+this category contains only non-judicial and negligibly judicial documents.
+We thank the Court for its attention to this matter.
+Respectfully submitted,
+/s/
+Andrew G. Celli, Jr.
+David A. Lebowitz
+C.
+All Counsel of Record (via ECF)
+EFTA02805395

vision-joined/court-04/85bcc0fba163e9ca788011392abb48282b8806f8ddc694263544f2b23696446d.json

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vision-joined/court-04/85bcc0fba163e9ca788011392abb48282b8806f8ddc694263544f2b23696446d.md

@@ -0,0 +1,34 @@
+Case 1:20-cr-00330-PAE Document 215
+Filed 04/19/21 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:_
+DATE FILED: 4/19/21
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+ORDER
+Defendant.
+ALISON J. NATHAN, District Judge:
+On April 2, 2021, the Defendant filed her response to Boies Schiller Flexner LLP's
+objections to the Defendant's proposed Rule 17(c) subpoena by email, in order to allow the
+parties to confer on appropriate redactions. Boies Schiller Flexner LLP filed its reply on April 5,
+2021, also by email. On April 5, 2021, the Government filed on the public docket a letter motion
+requesting that the Court order the Defendant to provide the Government with a copy of the
+proposed subpoena and that any productions made pursuant to any Rule 17(c) subpoenas be
+produced to the opposing party. Dkt. No. 193. On April 15, 2021, the Defendant submitted her
+response by email in order to allow the parties to confer on any appropriate redactions.
+IT IS ORDERED that any redaction requests for documents not already filed on the
+public docket must be made by April 21, 2021. Alternatively, the parties may file the unredacted
+versions by that date.
+SO ORDERED.
+Dated: April 19, 2021
+New York, New York
+Ali O. Notor
+ALISON J. NATHAN
+United States District Judge
+EFTA02831682

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vision-joined/court-04/85c10cdd009cf575e5f50a61bb57bdf2adcfba660c7a89fb81321886052581a1.md

@@ -0,0 +1,204 @@
+Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 Page 1 of 5
+EXHIBIT 1
+(File Under Seal)
+EFTA02794498
+
+Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 Page 2 of 5
+Page 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+CASE NO. 15-CV-07433-RWS
+- X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+- X
+June 1, 2016
+9:12 a.m.
+CONFIDENTIAL
+Deposition of JOHN ALESSI, pursuant
+to notice, taken by Plaintiff, at the
+offices of Boies Schiller & Flexner, 401
+Las Olas Boulevard, Fort Lauderdale, Florida,
+before Kelli Ann Willis, a Registered
+Professional Reporter, Certified Realtime
+Reporter and Notary Public within and
+for the
+State of Florida.
+MAGNAO
+LEGAL SERVICES
+EFTA02794499
+
+Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 Page 3 of 5
+Page 223
+1
+JOHN ALESSI
+2
+l. You never received emails from either of
+3
+them?
+4
+A. No, sir.
+5
+Q. So when there would be a message from one
+6
+of them while they were out of town, they would call
+7
+you, call you on the telephone?
+8
+A. I haven't spoken to Ghislaine in 12 years.
+9
+10
+l. Sorry. I'm talking about when you worked
+there and you would receive a message that they were
+11
+coming into town, would that be by way of telephone?
+12
+13
+A. Telephone, and also, there was a system at
+the house, that it was Mindspring, MindSpring I
+14
+think it's called, that it was like a message system
+15
+that would come from the office.
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. What is MindSpring?
+A. It was a server. I think it was -- the
+office would have, like, a message system between
+him, the houses, the employees, his friends. They
+would write a message on the computer. There was no
+email at that time.
+l. Okay. So what computer would you use?
+A. My computer in my office.
+Q. And so was part of your daily routine to
+go to your computer and check to see if you had
+MAGNAO
+LEGAL SERVICES
+EFTA02794500
+
+Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 |
+Page 4 of 5
+Page 224
+1
+JOHN ALESSI
+2
+3
+5
+Mindspring messages?
+A.
+No. That was at the end of my stay. That
+was the very end of my stay. I didn't get involved
+with that too much. But it was a message system
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+6
+that Jeffrey received every two, three hours, with
+7
+all the messages that would have to go to the office
+8
+in New York, and they will print it and send it
+9 faxed to the house, and I would hand it to him.
+l. Did it look like the message pads that
+we've been looking at?
+A. No, no, nothing like that.
+Q. Was it typed-out messages?
+A. Yes, typed-out messages.
+l. Just explain one example of how it would
+work. Let's say that Ghislaine wanted to send him a
+message on Mindspring.
+How would that work?
+A. An example?
+Sure.
+A. It got so ridiculous at the end of my
+stay, okay? That Mr. Epstein, instead of talking to
+me that he wants a cup of coffee, he will call the
+office; the office would type it; they would send it
+to me, Jeffrey wants a cup of coffee, or Jeffrey
+wants an orange juice out by the pool.
+MAGNAO
+LEGAL SERVICES
+EFTA02794501
+
+Case 1:15-cv-07433-LAP
+Document 1330-13 Filed 01/05/24
+Page 5 of 5
+Page 225
+1
+2
+3
+4
+JOHN ALESSI
+l. He would call the office in New York.
+They would then type it in Mindspring?
+A. Send it to me.
+5
+6
+7
+e. How would you know to check for it? How
+would you know to look for this MindSpring?
+A. Because I was in the office. I was there.
+8
+I was there. And we have a signal when it come on
+9
+and says, Hey, you've got mail.
+10
+e. Okay.
+11
+A. Every day. Every day it was new things
+12
+put in. That's why I left, too.
+13
+e. Do you know who set up the mind spring
+14
+system?
+15
+A.
+It was a computer guy. It was a computer
+16
+guy who worked only for Jeffrey. Mark. Mark
+17
+Lumber.
+18
+l.
+Was he local to Palm Beach?
+19
+A. No. He was in New York. Everything was
+20
+set up from New York. And Mark Lumber, I remember
+21
+he came to Palm Beach to set up the system at the
+22
+house.
+23
+2. Did you become aware at some point in time
+24
+that there was a bag or a briefcase of cash that was
+25
+in the house?
+MAGNAO
+LEGAL SERVICES
+EFTA02794502

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vision-joined/court-04/85eb9ede462e3cb5c35902f0fb191a7b5e963ebb4bdb3c41c1eb1b284fb7d58d.md

@@ -0,0 +1,80 @@
+Case 1:15-cv-07433-LAP Document 878
+Filed 04/28/17 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+-----X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+:
+-----X
+Defendant's Motion to Exclude Undisclosed Witnesses and Exhibits
+Pursuant to Fed. R. Civ. P. 37(c)
+Laura A. Menninger
+Jeffrey S. Pagliuca
+Ty Gee
+HADDON, [
+AND
+150 East 10" Avenue
+Denver, CO 80203
+303.831.7364
+,, P.C.
+EFTA02804457
+
+Case 1:15-cv-07433-LAP Document 878 Filed 04/28/17 Page 2 of 4
+TABLE OF CONTENTS
+and
+PAGES 1-13
+REDACTED
+EFTA02804458
+
+Case 1:15-cv-07433-LAP Document 878 Filed 04/28/17 Page 3 of 4
+Dated: April 28, 2017
+Respectfully submitted,
+/s/ Laura A. Menninger
+Laura A. Menninger (LM-1374)
+Jeffrey S. Pagliuca (pro hac vice)
+Ty Gee (pro hac vice)
+HADDON,
+AND
+150 East 10" Avenue
+Denver, CO 80203
+Phone: 303.831.7364
+Fax:
+303.832.2628
+Imenninger@hmflaw.com
+Attorneys for Ghislaine Maxwell
+P.C.
+14
+EFTA02804459
+
+Case 1:15-cv-07433-LAP Document 878 Filed 04/28/17 Page 4 of 4
+CERTIFICATE OF SERVICE
+I certify that on April 28, 2017, I electronically served this Defendant's Motion to Exclude
+Undisclosed Witnesses and Exhibits Pursuant to Fed. R. Civ. P. 37(c) via ECF on the following:
+Sigrid S. McCawley
+Meredith
+BOIES, SCHILLER & FLEXNER, LLP
+401 East Las Olas Boulevard, Ste. 1200
+Ft. Lauderdale, FL 33301
+smccawley@bsfllp.com
+mschultz@bsfllp.com
+L. JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L
+425 North Andrews Ave., Ste. 2
+Ft. Lauderdale. FL 33301
+brad@pathtojustice.com
+Paul G. Cassell
+383 S. University Street
+Salt Lake City, UT 84112
+cassellp@law.utah.edu
+J. Stanley Pottinger
+49 Twin Lakes Rd.
+South Salem, NY 10590
+StanPottinger@aol.com
+/s/ Nicole
+Nicole
+15
+EFTA02804460

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vision-joined/court-04/8661a60d417226554144964ca207ff64d3fbcb06d502edbaab0ecc73e136319c.md

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+Case 1:20-cr-00330-PAE |
+Document 657 Filed 04/29/22 Page 1 of 45
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:_
+DATE FILED: 4/29/22
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+OPINION & ORDER
+Defendant.
+ALISON J. NATHAN, Circuit Judge, sitting by designation:
+In 2020, the Defendant Ghislaine Maxwell was indicted for her participation in a scheme
+to entice, transport, and traffic underage girls for sexual abuse by and with Jeffrey Epstein, her
+longtime companion. The Government at trial presented extensive witness testimony from
+multiple victim witnesses and others, as well as corroborating documentary and physical
+evidence. The testimony and other trial evidence established the Defendant's role in grooming
+and recruiting underage girls and using the cover of massage to perpetrate sexual abuse.
+Following the thirteen-day trial, the Court submitted to the jury the six counts in the
+Indictment. The jury deliberated for over five days and returned a verdict of guilty on five of the
+six counts. Two of these counts of conviction charged the Defendant with substantive violations
+of federal statutes that target sexual abuse of minors-the
+Act as to Count Four and the
+Trafficking Victims Protection Act as to Count Six. The other three counts of conviction,
+Counts One, Three, and Five, charged the Defendant with conspiring with Jeffrey Epstein to
+violate those same statutes from 1994 to 2004.
+Before the Court are the Defendant's post-trial motions making four alternative
+arguments for vacating some or all of her five counts of conviction. First, the Defendant argues
+that judgment may be imposed on only one of the three conspiracy counts (i.e., Counts One,
+EFTA02838205
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 2 of 45
+Three, and Five) because they are "multiplicitous"— meaning that they all charge the same
+offense-and therefore entry of judgment on all three counts would violate the Fifth
+Amendment's Double Jeopardy Clause. Second, she requests under Rule 29 of the Federal Rules
+of Criminal Procedure that the Court acquit her of all counts because there is insufficient
+evidence for any rational juror to find her guilty beyond a reasonable doubt. Third, the
+Defendant moves to vacate Counts One, Three, and Four under Rule 33 because, she claims, the
+convictions were based on a constructive amendment of, or variance from, the Indictment. And
+fourth, she requests that the Court vacate all five convictions because the Government
+intentionally and prejudicially delayed its prosecution.
+With one exception, the motions are denied. The Rule 29 motion challenging all counts
+of conviction is denied because the jury's guilty verdicts were readily supported by the extensive
+witness testimony and documentary evidence admitted at trial. Further, those counts of
+conviction matched the core of criminality charged in the Indictment, presented by the
+Government at trial, and on which the jury was accurately instructed. The Defendant's contrary
+claim of a constructive amendment of or variance from the Indictment rests on an implausible
+and speculative interpretation of a single ambiguous jury note. In addition, the Court concludes
+that the Government did not intentionally delay its prosecution and, in any event, the
+Defendant's ability to prepare a defense was not prejudiced by any delay.
+The Court does conclude, however, that the three conspiracy counts charge the same
+offense, and, accordingly, are multiplicitous. The Government concedes that Count One is
+multiplicitous with Count Three but argues that Count Three and Count Five nevertheless
+involve distinct conspiracies. The Court concludes that Count Five, like Counts One and Three,
+charges the Defendant's participation in the same decade-long unlawful agreement with the
+2
+EFTA02838206
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 3 of 45
+Defendant's continuous coconspirator, Jeffrey Epstein. The overarching conspiracy—which, as
+the Government argued and proved at trial, employed a single "playbook" to groom and sexually
+abuse underage girls—-constitutes a single conspiracy offense with multiple victims. Because the
+Double Jeopardy Clause prohibits the Court from imposing multiple punishments for the same
+offense, the Court will enter judgment on Count Three alone among the conspiracy counts. This
+legal conclusion in no way calls into question the factual findings made by the jury. Rather, it
+underscores that the jury unanimously found-three times over—that the Defendant is guilty of
+conspiring with Epstein to entice, transport, and traffic underage girls for sexual abuse.
+1.
+The Court grants the Defendant's multiplicity claim.
+The Defendant was indicted on six counts: (1) conspiracy to entice individuals under the
+age of seventeen to travel in interstate commerce with intent to engage in sexual activity illegal
+under New York law, in violation of 18 U.S.C. § 371; (2) enticement of individuals under the
+age of seventeen to travel in interstate commerce with intent to engage in sexual activity illegal
+under New York law, and aiding and abetting the same, in violation of 18 U.S.C. §§ 2422, 2; (3)
+conspiracy to transport individuals under the age of seventeen to travel in interstate commerce
+with intent to engage in sexual activity illegal under New York law, in violation of 18 U.S.C.
+§ 371; (4) transportation of an individual under the age of seventeen with intent to engage in
+sexual activity illegal under New York law, and aiding and abetting the same, in violation of 18
+U.S.C. §§ 2423(a), 2; (5) conspiracy to commit sex trafficking of individuals under the age of
+eighteen, in violation of 18 U.S.C. § 371; and (6) sex trafficking of an individual under the age of
+3
+EFTA02838207
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 4 of 45
+eighteen, and aiding and abetting the same, in violation of 18 U.S.C. §§ 1591, 2. S2 Indictment,
+Dkt. No. 187.'
+In two prior pretrial motions, the Defendant requested that the Court dismiss two of the
+three conspiracy counts that is, Counts One, Three, and Five-as multiplicitous, given that all
+three were premised on the Defendant's participation in a single criminal conspiracy with
+Epstein. To punish her for all three counts, she argued, would violate the Double Jeopardy
+Clause. In opinions dated April 16, 2021, and August 13, 2021, the Court denied those motions
+as premature because the Double Jeopardy Clause would prohibit only multiple punishments for
+the same offense, but not indictments for the same offense. United States v. Maxwell, 534 F.
+Supp. 3d 299, 322 (S.D.N.Y. 2021) (citing United States v. Josephberg, 459 F.3d 350, 355 (2d
+Cir. 2006)); United States v. Maxwell, No. 20-CR-330 (AJN), 2021 WL 3591801, at *5
+(S.D.N.Y. Aug. 13, 2021).
+Because the jury convicted the Defendant on all three conspiracy counts, the Defendant
+now requests that the Court impose judgment on only one of these counts. Maxwell Br. at 19,
+Dkt. No. 600. The Government concedes that Counts One and Three are multiplicitous and
+agrees that the Court should not impose judgment on Count One, but it argues that Counts Three
+and Five are distinet offenses premised on distinct criminal conspiracies, and so the Court should
+impose judgment on both. Gov. Br. at 24, Dkt. No. 621.
+On consent of both parties, the Court will not impose judgment on Count One because it
+is multiplicitous. For the reasons that follow, the Court further grants the Defendant's motion to
+also not enter judgment on Count Count Five because it is also multiplicitous with Count Three.
+' The original and S2 Indictments also included two counts of perjury. See S2 Indictment 11 28-31. The Court
+granted the Defendant's motion to sever those counts for a separate trial. United States v. Maxwell, 534 F. Supp. 3d
+299, 321 (S.D.N.Y. 2021).
+4
+EFTA02838208
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 5 of 45
+A. Applicable law
+The Double Jeopardy Clause of the Fifth Amendment guarantees that no person shall "be
+subject for the same offence to be twice put in jeopardy of life or limb." U.S. Const. amend. V.
+That guarantee "serves principally as a restraint on courts and prosecutors," ensuring that a court
+does not "exceed its legislative authorization by imposing multiple punishments for the same
+offense."
+v. Ohio, 432 U.S. 161, 165 (1977); see also Morris v.
+, 264 F.3d 38,
+48 (2d Cir. 2001). An indictment is multiplicitous, and therefore implicates double jeopardy,
+"when it charges a single offense as an offense multiple times, in separate counts, when, in law
+and fact, only one crime has been committed." Maxwell, 534 F. Supp. 3d at 322 (quoting United
+States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999)). "A claim of multiplicity cannot succeed,
+however, 'unless the charged offenses are the same in fact and in law.'" United States v.
+482 F.3d 60, 72 (2d Cir. 2006) (quoting United States v.
+320 F.3d 173, 180 (2d Cir.
+2003)).
+If the two offenses at issue are both conspiracies charged under the same statute, then the
+multiplicity inquiry turns on whether the two conspiracies are the same "in fact," meaning they
+involve the same agreement. United States v. Araujo, No. 17-CR-438 (VEC), 2018 WL
+3222527, at *3 (S.D.N.Y. July 2, 2018) (citing United States v. Ansaldi, 372 F.3d 118, 124-25
+(2d Cir. 2004)); United States v. Gaskin, 364 F.3d 438, 454 (2d Cir. 2004) ("IT]o survive a
+double jeopardy attack, the government would have to show that the two schemes involved
+'distinct' agreements."). Yet "whether the evidence shows a single conspiracy or more than one
+conspiracy is often not determinable as a matter of law or subject to bright-line formulations."
+1, 482 F.3d at 72. Rather, the parties agree that the Court's inquiry is guided by the Second
+Circuit's Korfant factors. See, e.g., United States v. Diallo, 507 F. App'x 89, 91 (2d Cir. 2013)
+5
+EFTA02838209
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 6 of 45
+(summary order) (citing United States v. Korfant, 771 F.2d 660, 662 (2d Cir. 1985) (per
+curiam)); United States v. Villa, 744 F. App'x 716, 720 (2d Cir. 2018) (summary order). Those
+factors include:
+(1) the criminal offenses charged in successive indictments; (2) the overlap of
+participants; (3) the overlap of time; (4) similarity of operation; (5) the existence
+of common overt acts; (6) the geographic scope of the alleged conspiracies or
+location where overt acts occurred; (7) common objectives; and (8) the degree of
+interdependence between alleged distinct conspiracies.
+United States v. Macchia, 35 F.3d 662, 667 (2d Cir. 1994) (quoting Korfant, 771 F.2d at 662). In
+applying the Korfant factors, "no dominant factor or single touchstone" determines whether two
+allegedly distinct conspiracies "appear in fact and in law the same.'" Id. at 668 (quoting United
+States v. Reiter, 848 F.2d 336, 340 (2d Cir. 1988)). Moreover, "the Korfant list is not
+exhaustive, and every case must be assessed on its own terms ... based on the entire record."
+United States v. Maslin, 356 F.3d 191, 196 (2d Cir. 2004).
+In assessing the evidence, the Second Circuit applies a burden-shifting framework. The
+defendant carries the initial burden of making a non-frivolous showing that the two counts in fact
+charge only one conspiracy. If met, the burden then shifts to the Government to show, "by a
+preponderance of the evidence, that there are in fact two distinct conspiracies and that the
+defendant is not being placed in jeopardy twice for the same crime." United States v.
+, 356
+F.3d 463, 467 (2d Cir. 2004) (per curiam) (citing United States v. DelVecchio, 800 F.2d 21, 22
+(2d Cir. 1986)); see also United States v. Mallah, 503 F.2d 971, 986 (2d Cir. 1974) (applying this
+burden-shifting approach post-conviction); United States v.
+No. 09-CR-625 (HB),
+2009 WL 3169226, at *9 (S.D.N.Y. Oct. 1, 2009).
+6
+EFTA02838210
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 7 of 45
+B. Analysis
+A further summary of the two counts at issue is required. As briefly outlined above,
+Count Three of the Indictment charged the Defendant under 18 U.S.C. § 371, the general federal
+conspiracy statute, with conspiring to violate 18 U.S.C. § 2423(a) (the
+Act), by
+transporting minors across state lines with the intent to engage in sexual activity criminalized by
+state law. S2 Indictment 11 16-18. In this case, the relevant state offense was New York Penal
+Law Section 130.55, which criminalizes sexual contact with an individual known to be under the
+age of seventeen. Trial Tr. 3034-35. The Count Three conspiracy spanned from 1994 to 2004.
+S2 Indictment 9 17. As the Government explained in its summation, the jury could convict the
+Defendant under Count Three based on evidence related to Jane, Carolyn, and
+three victims who testified at trial. Trial Tr. at 2895.2
+Count Five of the Indictment also charged the Defendant under 18 U.S.C. § 371, but for
+conspiring to violate 18 U.S.C. §§ 1591(a) & (b) (the Trafficking Victims Protection Act), by
+trafficking individuals under the age of eighteen for commercial sex acts that affect interstate
+commerce. S2 Indictment 1 22-24. Count Five's conspiracy spanned from 2001 to 2004. Id.
+123. The Government explained to the jury that it could convict the Defendant on Count Five
+based on evidence related to Carolyn and
+Trial Tr. at 2896.
+The Defendant primarily contends that Count Five is a subset of, is subsumed in, or is
+otherwise too similar to Count Three under the Korfant factors. The Court agrees. Although
+some Korfant factors favor the Government, the weight of the factors-supplemented by a
+review of the Government's case presented at trial-demonstrates that the Government has not
+2 The Court permitted certain victim witnesses to testify using a pseudonym or first name. See Nov. 1, 2021 Tr. at
+7
+EFTA02838211
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 8 of 45
+met its burden of proving by a preponderance of the evidence that the counts are not
+multiplicitous.
+The offenses charged and common objectives. Both Counts Three and Five are charged
+under the same statute, 18 U.S.C. § 371, for conspiracy to commit an offense against the United
+States. But going beyond this "general level" of similarity, the statutory objectives of the two
+counts differ. Macchia, 35 F.3d at 669. Count Three is a conspiracy to violate § 2423(a) and
+Count Five a conspiracy to violate § 1591. These differing statutory objectives entail legal
+differences. Count Three, for example, charges unlawful sexual activity (defined as sexual
+touching of a minor) while Count Five charges commercial sexual activity with a minor. And
+each provision defines "minor" differently: under seventeen years old for Count Three but under
+eighteen years old for Count Five. Further, Count Three requires an agreement with intent to
+transport across state lines, while Count Five's agreement requires only intent of sexual activity
+that affects interstate commerce. These differences push the first Korfant factor in the
+Government's favor. See
+320 F.3d at 182 (distinguishing between a conspiracy to
+distribute cocaine and one to distribute crack); United States v. Villa, No. 3:12-CR-40 (JBA),
+2014 WL 252013, at *4 (D. Conn. Jan. 22, 2014), aff'd, 744 F. App'x 716 (2d Cir. 2018)
+(summary order) (distinguishing between a § 371 conspiracy to "commit theft from an interstate
+shipment and to transport stolen property across state lines" and one to "sell stolen property").
+The Government, however, errs in suggesting that this factor alone is "fatal" to the
+Defendant's multiplicity claim. Gov. Br. at 29. To the contrary, no single Korfant factor is
+dominant or dispositive. Macchia, 35 F.3d at 668. And courts in this district have found two
+conspiracy counts to be the same offense even when they have different statutory objectives
+because both counts can arise from the same agreement. E.g.,
+, 2009 WL 3169226, at
+8
+EFTA02838212
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 9 of 45
+*11 (concluding that conspiracies to defraud the United States and to commit mail and wire
+fraud were the same conspiracy as earlier conspiracy to use or transfer false IDs). After all, "[a]
+single agreement to commit several crimes constitutes one conspiracy." United States v. Broce,
+488 U.S. 563, 570-71 (1989). The Government implicitly conceded this point of law when it
+agreed that Counts One and Three were multiplicitous. Count One charges a conspiracy to
+entice minors to travel across state lines in violation of 18 U.S.C. § 2422 while Count Three
+charges a conspiracy to transport minors across state lines in violation of 18 U.S.C. § 2423(a).
+Despite distinct statutory predicates for these two § 371 conspiracies, the Government did not
+contest that they were the same offense. Though Count Five is unquestionably less similar to
+Count Three than is Count One, the difference in statutory predicates does not end the matter. It
+is well established that a single conspiracy can contain multiple objectives, particularly if the
+objectives share important similarities, as they do here. United States v. Salameh, 152 F.3d 88,
+148 (2d Cir. 1998) (citing United States v. Aracri, 968 F.2d 1512, 1518 (2d Cir. 1992)).
+Overlap of participants. The participants in the two conspiracies in Counts Three and
+Five substantially overlap with one another. Of course, the defendant will always overlap
+between two allegedly multiplicitous conspiracies, so their participation in both conspiracies has
+negligible significance. Villa, 2014 WL 252013, at *5. More importantly here, Epstein was the
+Defendant's primary coconspirator in both conspiracies, and the Government argued that in both
+conspiracies the Defendant played the same role of acquiring underage girls for Epstein to
+sexually abuse. They were, the Government explained, "partners in crime" over the decade
+alleged in the Indictment. E.g., Trial Tr. at 34, 2842, 2885; see also id. at 41 ("For a decade, the
+defendant played an essential role in this scheme."). This overlap in key participants, and in core
+9
+EFTA02838213
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 10 of 45
+roles played by those participants, significantly favors the Defendant as to the second Korfant
+factor. See Macchia, 35 F.3d at 669;
+, 2009 WL 3169226, at *11.
+The Government responds that the Count Five conspiracy included |
+, who
+was not involved in Count Three. Yet
+received far less attention than other conspirators
+in the Government's case, being mentioned only briefly in the Government's opening statement
+and closing arguments. E.g., Trial Tr. at 2876 (noting, "and sometimes
+would call,
+too"). Conspiracies often change membership without forming a new, distinct conspiracy,
+particularly if key members of the conspiracy remain over the course of a decade. See United
+States v. Eppolito, 543 F.3d 25, 48 (2d Cir. 2008).
+participation beginning in 2001
+therefore does not shift the import of the second Korfant factor.
+Overlap of time. The time periods of the two counts overlap completely. Namely, Count
+Five's period of 2001 to 2004 is "wholly within the time frame" of Count Three from 1994 to
+2004, which substantially favors the Defendant on this Korfant factor. United States v.
+Calderone, 982 F.2d 42, 47 (2d Cir. 1992). The Government's attempt to minimize this factor
+by noting that most overt acts for Count Three occurred in the 1990s is simply not reflected in
+this circuit's case law. See, e.g., Macchia, 35 F.3d at 669 (focusing on the overlap in time frame
+alleged in the indictment). The overlap in time here raises the inference that one conspiracy
+wholly encompasses the other, and that inference tips in the Defendant's favor. See Araujo,
+2018 WL 3222527, at *6.
+Similarity of operations. Counts Three and Five involve significant similarities in
+operations. The methods by which the Defendant groomed and facilitated the sexual abuse of
+minor victims was a central focus of both parties' cases at trial. The Government called as an
+expert witness Dr. Lisa Rocchio, who identified the typical steps in sexual abusers' grooming of
+10
+EFTA02838214
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 11 of 45
+minors for sexual abuse. Trial Tr. at 714-19. Applying that expert testimony to the witnesses'
+testimony, the Government argued that the Defendant's conduct as to each victim followed a
+uniform "playbook." E.g., id. at 2184 ("She ran the same playbook again and again and again.
+She manipulated her victims and she groomed them for sexual abuse."), 2853 ("The patterns you
+saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways
+that you know that Maxwell is guilty."). And the Government emphasized the many similarities
+in the Defendant's conduct as recounted by all four witnesses. Id. at 2848 ("The similarities
+between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful
+evidence of the defendant's guilt. So I want to talk to you about the playbook that Maxwell ran
+again and again and again."), 2901 ("Four women have testified at this trial about Maxwell.
+They all describe the same woman, the same playbook."). Carolyn was the only witness who
+testified regarding Count Five. The Government argued that her testimony "was corroborated by
+what Annie and Kate and Jane told [the jury] about Maxwell and how she operated for years."
+Id. at 2880; see also id. at 2895-96 ("Maxwell groomed both Annie and Carolyn as part of a
+broader agreement with Epstein to provide him with underage girls for abuse."). The
+Government, in short, argued that the Defendant engaged in substantially the same operations for
+a decade as to all victims under both Counts Three and Five.
+The Government responds that while the Defendant and Epstein continuously conspired
+to sexually abuse minor victims, their conduct beginning in 2001 evolved from developing one-
+on-one relationships with their vietims to include a "pyramid scheme of abuse," by which they
+acquired underage girls by paying them for so-called "massage" appointments. Gov. Br. at 32
+(quoting Trial Tr. at 40). To be sure, the Government in both its opening statement and its
+closing arguments explained that the Defendant and Epstein's abuse "evolved over the course of'
+11
+EFTA02838215
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 12 of 45
+a decade," having both the "earlier phase" and the later "pyramid scheme." Trial Tr. at 40; see
+also, e.g., id. at 2886 (describing 2001 as "the beginning of the pyramid scheme of abuse"). But
+a single conspiracy can enter "two or more phases or spheres of operation" without creating a
+discontinuity in the underlying unlawful agreement, particularly if the same people are serving
+the same roles in each phase. United States v. Pena, 846 F. App'x 49, 51 (2d Cir. 2021)
+(summary order) (quoting United States v. Berger, 224 F.3d 107, 114-15 (2d Cir. 2000)); see
+also United States v. Maldonado-
+1. 922 F.2d 934, 963 (2d Cir. 1990). Notably, the
+Government, after distinguishing between earlier and later phases in the pattern of abuse,
+immediately emphasized that "[f]or a decade, the defendant played an essential role in this
+scheme," blurring any difference between the two phases. Trial Tr. at 41.
+Moreover, though these phases did involve some differing means to acquire minor
+victims, the differences presented at trial were not as great as the Government suggests in its
+brief. As to both counts, both before and after 2001, the Government emphasized that massage
+was a primary means by which the Defendant and Epstein normalized bodily contact and also the
+means by which the Defendant and Epstein commonly instigated instances of sexual abuse.
+Compare id. at 40 ("You will learn that in the 1990s, they used the cover of mentoring young
+girls... to introduce massage... and that you will learn that they used these so called massages
+as a way to sexually abuse the victims."), with id. at 41 ("Under this pyramid scheme of abuse,
+the defendant could just call girls to schedule massage appointments and hand them cash
+afterwards …..."); e.g., id. at 35 (You will learn that the cover of massage was the primary way
+the defendant and Epstein lured girls into sexual abuse."), 2852 ("Again and again throughout
+this trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey
+Epstein.").
+12
+EFTA02838216
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 13 of 45
+Further, in both counts, the witnesses testified that they received financial gifts and
+payments as a means by which the Defendant and Epstein acquired their victims' trust and
+extended the period of sexual abuse. E.g., id. at 302 (Jane testified that she was given money
+"[a]lmost every visit" and that Epstein paid for things like voice lessons and clothes). The
+Government emphasized such financial gifts as one step in the Defendant's playbook of
+grooming. E.g., id. at 2851 ("Then came the next step in the playbook: Making these girls feel
+special, giving them gifts, making friends, giving them money, promising to help with their
+futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane's voice
+lessons and tuition."), 2890 ("[Jane] told you that Epstein gave her money and gifts and paid for
+school. That money wasn't free ... That is inducement, that is enticement, that is coercion.").
+The financial quid pro quo may have become more explicit beginning in 2001, but that shift in
+approach is not nearly so dramatic as to suggest that the Defendant and Epstein at that time
+entered "a wholly new agreement" with a new "conspiratorial objective." Haji v.
+584 F.
+Supp. 2d 498, 519 (E.D.N.Y. 2008). The similarity-of-operations factor therefore favors the
+Defendant.
+Overlap of geographic scope. There is some, albeit incomplete, geographic overlap
+between the two counts. Count Three focused on travel to New York because the ultimate
+objective of the conspiracy was to transport minors to New York to engage in criminal sexual
+activity in violation of New York law. Count Five, by contrast, focused on Epstein's residence
+in Florida, where Carolyn and
+were paid to give Epstein sexualized massages.
+Nevertheless, some geographic overlap between the two counts remained. All four witnesses
+testified about sexual conduct by the Defendant or Epstein in locations other than New York,
+whether Florida, New Mexico, or London. The Court admitted such testimony concerning
+13
+EFTA02838217
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 14 of 45
+sexual conduct outside of New York as relevant to Count Three because it tended to establish the
+existence of a conspiracy and of the Defendant and Epstein's intent to abuse the victims in New
+York. In sum, the same locations—particularly Florida—were part of the Government's case for
+both counts. And over time, a conspiracy's "shifting emphasis in the location of operations
+do[es] not necessarily require a finding of more than one conspiracy." Eppolito, 543 F.3d at 48
+(quoting |
+1, 482 F.3d at 72). This factor therefore favors the Defendant or, at least, is neutral.
+Common overt acts. The Government correctly notes that the overt acts provided to the
+jury for Counts Three and Five are distinct. See Jury Charge, Dkt. No. 565 at 49-50. This factor
+therefore tips toward the Government but only slightly. A number of the overt acts listed for
+Count Three could have been prosecuted under Count Five but for the fact that 18 U.S.C. § 1591,
+the Trafficking Victims Protection Act, was not enacted until 2000. See Gov. Br. at 28. That
+some identical overt acts were not listed for both conspiracies is therefore more a function of
+legal timing than an indication of two distinct conspiracies. Cy.
+2009 WL 3169226,
+at *12.
+Interdependence. Counts Three and Five are not interdependent because the success or
+failure of one conspiracy is independent of the success or failure of the other. See Macchia, 35
+F.3d at 671. In other words, the success of the Defendant and Epstein's scheme to abuse Carolyn
+from 2001 to 2004 was not made more or less likely by the prior success or failure to abuse Jane,
+Annie, or any other underage girl. This factor, however, makes little difference in the final
+analysis if "what was ultimately proven was one common conspiracy." Maslin, 356 F.3d at 197.
+The Government's theory at trial. The Second Circuit has instructed district courts to
+consider not only the enumerated Korfant factors but to consider the entire record. See id. at
+196; United States v. Olmeda, 461 F.3d 271, 282 (2d Cir. 2006). In Maslin, the Second Circuit
+14
+EFTA02838218
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 15 of 45
+first explained that applying the Korfant factors led to the conclusion that successive
+prosecutions for conspiracies to distribute marijuana were barred by double jeopardy, but then
+continued, stating that "several additional factors ... not directly addressed in Korfant ... further
+point toward a finding of double jeopardy," namely, "the fact that the Government, in its opening
+and closing arguments, presented both cases to the jury as broad conspiracies of an essentially
+identical nature." 356 F.3d at 197. The same is true here. As explained above, the
+Government's opening statement and closing arguments presented a theory of a singular
+conspiracy, highlighting: The degree of similarity between each victim witness's experience
+over a decade; the common "playbook" that the Defendant ran "over and over and over again,"
+Trial Tr. at 2848; and the tight partnership between the Defendant and Epstein. And each of
+those features was accompanied by references to a singular "scheme" to abuse all victim
+witnesses. Id. at 36, 2843, 2853. At bottom, the case presented to the jury by the Government
+was of a single decade-long conspiracy by the Defendant and Epstein to sexually abuse underage
+girls. Having pursued such a broad and encompassing conspiracy, the Government cannot now
+claim, and cannot carry its burden of proving by a preponderance of the evidence, that Count
+Five was legally and factually distinct. See Maslin, 356 F.3d at 197.
+Because Count Three and Count Five are multiplicitous, the proper remedy is to enter
+judgment on only one of the counts. See Josephberg, 459 F.3d at 355 ("If the jury convicts on
+more than one multiplicitous count, the defendant's right not to suffer multiple punishments for
+the same offense will be protected by having the court enter judgment on only one of the
+multiplicitous counts." (citing Ball v. United States, 470 U.S. 856, 865 (1985)). Because Count
+Five is factually subsumed by Count Three, the Court will impose judgment only on Count
+Three. The Court emphasizes, however, that finding Count Five to be multiplicitous "does not
+15
+EFTA02838219
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 16 of 45
+overturn any of the factual findings made by the jury" —it means only that, "as a matter of law,
+the jury found the same thing twice." Ansaldi, 372 F.3d at 125. Or, in this case, three times.
+Il.
+The Court denies the Defendant's Rule 29 motion.
+The Defendant argues there was insufficient evidence to support any of her five counts of
+conviction, and, therefore, the Court should enter a judgment of acquittal as to all counts under
+Rule 29 of the Federal Rules of Criminal Procedure. Rule 29 provides, in relevant part, that
+"[a]fter the government closes its evidence or after the close of all the evidence, the court on the
+defendant's motion must enter a judgment of acquittal of any offense for which the evidence is
+insufficient to sustain a conviction." Fed. R. Crim. P. 29(a); United States v. Pugh, 945 F.3d 9,
+19 (2d Cir. 2019). "[T]he critical inquiry on review of the sufficiency of the evidence to support
+a criminal conviction must be ... to determine whether the record evidence could reasonably
+support a finding of guilt beyond a reasonable doubt."
+v. Virginia, 443 U.S. 307, 318
+(1979). "The court must make that determination with the evidence against a particular
+defendant, viewed in the light most favorable to the government, and with all reasonable
+inferences resolved in favor of the government." Pugh, 945 F.3d at 19 (cleaned up) (quoting
+Eppolito, 543 F.3d at 45). Under this inquiry, "the relevant question is whether, after viewing
+the evidence in the light most favorable to the prosecution, any rational trier of fact could have
+found the essential elements of the crime beyond a reasonable doubt."
+443 U.S. at 319
+(citing
+v. Louisiana, 406 U.S. 356, 362 (1972)); United States v. Zhong, 26 F.4th 536,
+560 (2d Cir. 2022).
+At the close of the Government's case, the Defendant made her Rule 29 application "with
+respect to every count in the S2 indictment," but "confine[d] [her] comments to address
+specifically Counts One and Two." Trial Tr. at 2266. The Court denied the motion. Id. at 2274.
+16
+EFTA02838220
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 17 of 45
+Following the close of the defense case, the Defendant renewed her previous Rule 29
+application. Id. at 2736.
+In her brief, the Defendant reiterates her request that the Court "enter a judgment of
+acquittal as to all counts." Maxwell Br. at 30. The Court has deemed Counts One and Five
+multiplicitous, see supra Part I, and therefore the Court will not enter judgment on those counts.
+And at trial, the jury found the Defendant not guilty on Count Two. Thus, the Court will
+consider the sufficiency of the evidence for the remaining counts: Three, Four, and Six. After
+considering the arguments and evidence, the Court denies the Defendant's Rule 29 motion.
+The Court first notes that the Defendant has not provided substantive argument on the
+sufficiency of the evidence—in either the oral application or the post-conviction briefing-for
+Counts Three, Four, or Six. Instead, for these remaining counts, the Defendant simply asserts
+that the Court should enter a judgment of acquittal as to all counts under Rule 29 ... because
+the government failed to prove each element of the charges beyond a reasonable doubt."
+Maxwell Reply at 18, Dkt. No. 647; Maxwell Br. at 30. The Court disagrees.
+The Court first considers the substantive counts. Count Four charged the Defendant with
+the substantive count of transportation of an individual under the age of seventeen with intent to
+engage in sexual activity in violation of New York law. This count related only to Jane during
+the period 1994 to 1997. The Government was required to establish the following elements
+beyond a reasonable doubt: (1) that the Defendant knowingly transported an individual in
+interstate commerce, as alleged in the Indictment; (2) that the Defendant transported the
+individual with the intent that the individual would engage in sexual activity for which any
+person can be charged with a criminal offense under New York law, as alleged in the Indictment;
+and (3) that the Defendant knew that the individual was less than seventeen years old at the time
+17
+EFTA02838221
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 18 of 45
+of the acts alleged in Count Four; or that the Defendant aided and abetted the same. Jury Charge
+at 26,37.
+The Court concludes that there was sufficient evidence for the jury to find the Defendant
+guilty of Count Four beyond a reasonable doubt. Jane testified that Epstein first engaged in
+sexual activity with her in Palm Beach when she was fourteen years old. Trial Tr. at 305. She
+then began traveling from Palm Beach to New York with the Defendant and Epstein at that same
+age. Id. at 315-16. Jane explained that she traveled on commercial flights and Epstein's private
+jet. Id. at 316. She testified that the Defendant also traveled on some of these flights, and that
+the Defendant assisted her in making her travel arrangements to New York. Id. at 316-17. On
+one occasion when she was fifteen, Jane recounted, she had trouble getting on a commercial
+flight because she did not have proper identification. However, the Defendant "made it happen"
+for her by making a call and helping her get on the flight. Id. at 323-24. Jane also testified that
+the Defendant was present on some occasions when Epstein sexually abused Jane in New York
+when she was under the age of seventeen. Id. at 320. The Court concludes that this evidence,
+taken together, was sufficient for the jury to find beyond a reasonable doubt that the Defendant
+knowingly transported Jane to New York with the intent to engage in sexual activity illegal
+under New York law, or at minimum, aided and abetted Epstein in doing so.
+Next, the Court concludes that there was sufficient evidence for the jury to find the
+Defendant guilty of Count Six. Count Six charged the Defendant with the substantive count of
+sex trafficking of an individual under the age of eighteen. The Government was required to
+prove beyond a reasonable doubt that: (1) the Defendant knowingly recruited, enticed, harbored,
+transported, provided, or obtained a person; (2) the Defendant knew that the person was under
+the age of eighteen; (3) the Defendant knew the person would be caused to engage in a
+18
+EFTA02838222
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 19 of 45
+commercial sex act; and (4) the Defendant's acts were in or affecting interstate commerce; or
+that the Defendant aided and abetted the same. Jury Charge at 32, 37. Count Six applied solely
+to Carolyn during the period 2001 to 2004. Id. at 32.
+Carolyn testified that when she was under the age of eighteen, the Defendant would call
+her to set up appointments for Carolyn to perform sexualized massages on Epstein. Trial Tr.
+1527, 1530. Carolyn explained the sexual activities that occurred during the massages. Id. at
+1544 47. Carolyn testified that the Defendant saw her naked in the massage room and continued
+to call Carolyn to schedule appointments with Epstein. Id. at 1538. She recalled a specific
+incident when she was fourteen in which she was naked in the massage room and the Defendant
+touched her breasts and commented that Carolyn "had a great body for Mr. Epstein and his
+friends." Id. at 1536-38. Carolyn testified that the Defendant knew that she was under the age
+of eighteen and continued to call her to schedule appointments with Epstein after learning that
+fact. Id. at 1535. Carolyn further testified that she received money in exchange for performing
+sexualized massages on Epstein. E.g., id. 1523. She recalled that while money was often left on
+the sink outside of the massage room, the Defendant paid her directly after massages on one or
+two occasions. Id. at 1540 41. Carolyn's testimony was corroborated by Shawn, Carolyn's
+boyfriend at the time, and physical evidence including phone message pads. This evidence was
+plainly sufficient for the jury to find beyond a reasonable doubt that the Defendant committed
+sex trafficking of an individual under eighteen, or aided and abetted Epstein in doing so.3
+3 If the Court were to conclude that Count Five is not multiplicitous, it would deny the Defendant's Rule 29 motion
+as to Count Five. Count Five charged the Defendant with participating in a conspiracy to commit sex trafficking of
+individuals under the age of eighteen from about 2001 to 2004. The evidence that supports the Defendant's
+conviction of Count Six, the substantive count, also supports the Count Five conspiracy conviction. Additionally,
+Juan Alessi testified that the Defendant approached |
+in a parking lot and that he then saw her at
+Epstein's Palm Beach residence later that day. Trial Tr. at 841-43. Documentary evidence, including flight records,
+established that Virginia was under the age of eighteen when she met the Defendant and Epstein. See, e.g., id. at
+1855 (December 2000 flight record including Epstein, the Defendant, and Virginia); see also GX-14 (birth
+certificate). Carolyn testified that Virginia recruited her and that Virginia performed sexualized massages on
+19
+EFTA02838223
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 20 of 45
+Finally, Count Three charged the Defendant with conspiracy to transport individuals
+under the age of seventeen to travel in interstate commerce with intent to engage in illegal sexual
+activity in violation of New York law. The Government was required to prove beyond a
+reasonable doubt: (1) that two or more persons entered into the unlawful agreement charged; (2)
+the Defendant knowingly and willfully became a member of that conspiracy; (3) one of the
+members of the conspiracy knowingly committed at least one overt act; and (4) the overt act that
+the jury found to have been committed was committed in furtherance of that conspiracy. Jury
+Charge at 41.
+The Court concludes that the trial evidence supported a finding of guilt beyond a
+reasonable doubt for each element of Count Three. The Government presented evidence that
+could lead a reasonable juror to conclude that the Defendant worked with Epstein between 1994
+and 2004 to groom minor victims in an effort to transport them to New York to engage in sexual
+activity illegal under New York law. As noted above, Jane testified in detail about her travel to
+New York with the Defendant and Epstein where she was sexually abused. Trial Tr. at 319-20.
+Jane also testified about the steps taken by the Defendant and Epstein to make her feel
+comfortable before they began engaging in sexual activity with her and inviting her to travel. Id.
+299-303; see also id. at 348 (Jane testifying that their behavior toward her made her "feel
+special").
+Other witnesses testified to similar conduct. Annie testified that after she met Epstein in
+New York, she was invited to travel with the Defendant and Epstein to New Mexico when she
+was sixteen. Id. at 2068-69, 2075-77. She testified that on this trip, the Defendant and Epstein
+took her shopping and to the movies. Id. at 2080-81. She also testified that the Defendant
+Epstein in exchange for money. Trial Tr. 1518-24. The Court concludes that the evidence related to Carolyn and
+Virginia was sufficient for the jury to convict the Defendant on Count Five.
+20
+EFTA02838224
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 21 of 45
+encouraged her to massage Epstein's feet, and that the Defendant then gave her a massage during
+which the Defendant touched Annie's breasts. Id. at 2083-86. As noted above, Carolyn testified
+that the Defendant paid her for performing sexualized massages on Epstein. She also testified
+that Epstein and the Defendant asked her about her life and family and discussed sexual topics
+with her. Id. at 1533-36. Epstein then invited her to travel generally, and the Defendant invited
+her to travel to Epstein's private island in the Caribbean. Id. at 1535, 1540. A reasonable juror
+could have concluded that the Defendant's and Epstein's actions, including their efforts to
+normalize sexual conduct and invitations for underage girls to travel to New Mexico and the
+Caribbean, were in furtherance of the conspiracy's goal of transporting minors to New York for
+the purpose of engaging in sexual activity illegal under New York law. Finally, although the
+jury was instructed that it could not convict the Defendant solely on the basis of Kate's
+testimony, her testimony corroborated the testimony of other witnesses as to the Defendant's
+knowledge and role in the conspiracy. Id. at 1177-90. The Court concludes that this evidence
+was sufficient for a reasonable jury to convict the Defendant for conspiring to transport
+individuals in interstate commerce with intent to engage in sexual activity illegal under New
+York law.
+Accordingly, the Court denies the Defendant's Rule 29 motion for a judgment of
+acquittal.
+The Court denies the Defendant's motion claiming a constructive amendment or
+prejudicial variance.
+The Defendant also seeks to vacate her convictions as to Counts One, Three, and Four
+(the
+Act counts) pursuant to Federal Rule of Criminal Procedure 33. She contends that the
+jury convicted her of intending that Jane engage in sexual activity in New Mexico, rather than
+New York, thus resulting in a constructive amendment of the Indictment, or in the alternative, a
+21
+EFTA02838225
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 22 of 45
+prejudicial variance. For the following reasons, the Court disagrees and denies the Defendant's
+motion on this basis.
+A. Applicable Law
+Under the Fifth Amendment's Grand Jury Clause, "a defendant has the right to be tried
+only on charges contained in an indictment returned by a grand jury." United States v. Wozniak,
+126 F.3d 105, 109 (2d Cir. 1997). "[WJhen the charge upon which the defendant is tried differs
+significantly from the charge upon which the grand jury voted," a constructive amendment
+occurs and reversal is required. United States v. Khalupsky, 5 F.4th 279, 293 (2d Cir. 2021).
+"To prevail on a constructive amendment claim, a defendant must demonstrate that either
+the proof at trial or the trial court's jury instructions so altered an essential element of the charge
+that, upon review, it is uncertain whether the defendant was convicted of conduct that was the
+subject of the grand jury's indictment." United States v. Salmonese, 352 F.3d 608, 620 (2d Cir.
+2003) (quoting United States v.
+156 F.3d 332, 337 (2d Cir. 1998)). In making this
+determination, the Court first delineates the "core of criminality" of the crime alleged. United
+States v. Gross, No. 15-cr-769 (AJN), 2017 WL 4685111, at *20 (S.D.N.Y. Oct. 18, 2017), aff'd
+sub nom. United States v. Lebedev, 932 F.3d 40 (2d Cir. 2019). The "core of criminality ...
+involves the essence of a crime, in general terms." United States v. Daugerdas, 837 F.3d 212,
+225 (2d Cir. 2016) (alteration in original) (quoting United States v. D'Amelio, 683 F.3d 412, 418
+(2d Cir. 2012)). The Court then determines whether the evidence or jury instructions at trial
+created a "substantial likelihood" that the defendant was not convicted of the crime described in
+that core, but instead of a crime "distinctly different." D'Amelio, 683 F.3d at 416, 419. The
+Second Circuit has "consistently permitted significant flexibility in proof, provided that the
+defendant was given notice of the core of criminality to be proven at trial." United States v.
+22
+EFTA02838226
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 23 of 45
+Banki, 685 F.3d 99, 118 (2d Cir. 2012) (quoting United States v. Rigas, 490 F.3d 208, 228 (2d
+Cir. 2007)). Thus, the defendant must show that "the challenged evidence or jury instructions
+tied a defendant's conviction to "behavior entirely separate from that identified in the
+indietment."" United States v. Bastian, 770 F.3d 212, 223 (2d Cir. 2014) (emphasis added)
+(quoting United States v. Danielson, 199 F.3d 666, 670 (2d Cir. 1999)).
+By contrast, "[a] variance occurs when the charging terms of the indictment are left
+unaltered, but the evidence at trial proves facts materially different from those alleged in the
+indictment." Salmonese, 352 F.3d at 621 (quoting
+_. 156 F.3d at 337 n.5). "Although the
+distinction between constructive amendment and variance may appear "merely one of degree,'
+there is an important difference in outcome: *a constructive amendment of the indictment is
+considered to be a per se violation of the grand jury clause, while a defendant must show
+prejudice in order to prevail on a variance claim."' Id. (quoting
+156 F.3d at 337 n.5); see
+also Rigas, 490 F.3d at 226 ("[A] defendant alleging variance must show "substantial prejudice'
+to warrant reversal."). "A defendant cannot demonstrate that [s]he has been prejudiced by a
+variance where the pleading and the proof substantially correspond, where the variance is not of
+a character that could have misled the defendant at the trial, and where the variance is not such as
+to deprive the accused of his right to be protected against another prosecution for the same
+offense." Khalupsky, 5 F.4th at 294 (quoting Salmonese, 352 F.3d at 621-22). Moreover, when
+a defendant has sufficient notice of the Government's theory at trial, she cannot claim that she
+was unfairly or substantially prejudiced. See United States v. Kaplan, 490 F.3d 119, 129-30 (2d
+Cir. 2007).
+Finally, the Court bears in mind that the Defendant brings her motion pursuant to Rule
+33, which permits the Court to "vacate any judgment and grant a new trial if the interest of
+23
+EFTA02838227
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 24 of 45
+justice so requires." Fed. R. Civ. P. 33(a). Such a motion is granted "sparingly and in the most
+extraordinary circumstances, and only in order to avert a perceived miscarriage of justice."
+United States v. Gramins, 939 F.3d 429, 444 (2d Cir. 2019) (cleaned up).
+B. No constructive amendment occurred.
+Count Four charged the Defendant with transportation of an individual under the age of
+seventeen with intent to engage in illegal sexual activity, and Count Three charged a conspiracy
+to do the same. The core of criminality of these counts, the parties agree, was a scheme by
+Epstein and the Defendant to cause underage girls to travel to New York with the intent that they
+would engage in sexual activity in violation of New York law. Gov. Br. at 6; Maxwell Br. at 9.4
+The Defendant contends that a jury note received during deliberations revealed that the
+jury convicted the Defendant on a crime different from this core of criminality. Namely, the
+Defendant argues that in convicting her of Count Four, the jury found she intended for Jane to
+engage in sexual activity in New Mexico, without finding that she intended for Jane to engage in
+sexual activity in New York. Maxwell Reply at 2. She argues the Court's decision to refer the
+jury back to the charge and refusal to give a supplemental instruction was error. As a result of
+this same error, she says, the jury also improperly convicted her of Count Three. For the reasons
+that follow, the Court concludes that there is not a "substantial likelihood" that the Defendant
+was "convicted of an offense other than that charged in the indictment." D'Amelio, 683 F.3d at
+416 (quoting United States v. Mollica, 849 F.2d 723, 729 (2d Cir. 1988)).
+* The Defendant also contends that her conviction on Count One was the result of a constructive amendment.
+24
+EFTA02838228
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 25 of 45
+1. The Court's instructions, the evidence at trial, and the Government's
+summation captured the core of criminality.
+First, the Court's instructions to the jury during trial and after the close of evidence
+captured the core of criminality. As explained above, the Indictment charged the Defendant with
+four counts in violation of the
+Act, each predicated on a violation of New York Penal Law
+Section 130.55. That provision of New York law criminalizes sexual contact with an individual
+known to be under the age of seventeen. Jury Charge at 24. The jury charge made clear that this
+provision of New York law served as the predicate offense for Counts Two and Four. See id. at
+23-24 (Count Two), 28 (Count Four, instructing the jury to decide whether the Defendant had
+knowingly transported Jane with the intent to engage in sexual activity with Jane in violation of
+New York Penal Law Section 130.55, as alleged in the Indictment). The Court also accepted the
+Defendant's requested edits that further clarified that the predicate state offense was New York
+law. See, e.g., Request to Charge at 19, 23, 26, 30, 31, Dkt. No. 410-1; Jury Charge at 20, 24,
+26, 28 (specifying, e.g., that the predicate state offense was "New York law," rather than an
+unspecified "criminal offense").
+The jury charge also clearly instructed on the role of New York law in the jury's
+assessment of the
+Act conspiracy counts, Counts One and Three. The charge explained
+that the object of the conspiracies was a violation of the same New York law at issue in Count
+Two. See Jury Charge at 44 45. In particular, the objects of Counts One and Three were the
+enticement of minors to travel and the transport of minors, respectively, with the intent to engage
+in sexual activity illegal under New York law. See id. As for the overt acts, the Court, at the
+parties' request, did not provide the jury with a copy of the Indictment. Trial Tr. at 2781-82.
+Rather, the charge specified the relevant overt acts. Jury Charge at 49-50. For Counts One and
+Three, this included the instruction: "the Indictment alleges as follows: ... (2) In or about 1996,
+25
+EFTA02838229
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 26 of 45
+when Jane was under the age of 17, Jane was enticed to travel from Florida to New York for
+purposes of sexually abusing her at the New York Residence, in violation of New York Penal
+Law, Section 130.55." Id. at 49.
+The Court also gave two limiting instructions to ensure that the jury's consideration of
+certain relevant evidence was properly focused on the core of criminality. These instructions
+pertained to testimony about sexual activity that was not criminal conduct under New York Penal
+Law Section 130.55. The first limiting instruction pertained to Kate. This instruction informed
+the jury that it could not convict the Defendant on Counts One and Three solely on the basis of
+Kate's testimony because Kate could not be considered a victim of the crimes charged. Trial Tr.
+at 1167-68. This was so because she was older than seventeen at the time of the events, and, as
+explained, the object of the charged conspiracies was transport with intent to engage in sexual
+conduct in violation of New York Penal Law Section 130.55, which criminalizes sexual contact
+with individuals under the age of seventeen. See Nov. 1, 2021 Tr. at 67-68. The second limiting
+instruction pertained to Annie, who testified about sexual contact in New Mexico only. The
+instruction explained that her testimony about sexual conduct did not describe "illegal sexual
+activity" as alleged in the Indictment, which was a legal term that the Court would explain at the
+end of the case. Trial Tr. at 2048-49. This was so because, as explained, the object of the
+charged conspiracies was a violation of New York law, not New Mexico law. Both limiting
+instructions explained that the jury could determine that the testimony was relevant evidence.
+That was so because such evidence tended to establish the Defendant's intent that transport of a
+minor victim to New York was for the purpose of sexual activity illegal under New York law.
+The Defendant concedes this point as to testimony about sexual activity in states other than New
+26
+EFTA02838230
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 27 of 45
+York. Maxwell Reply at 5. The jury charge and limiting instructions at trial thus instructed the
+jury on the core of criminality.
+Second, the Government marshaled evidence that captured the core of criminality as pled
+in the Indictment and instructed by the Court. Jane testified that after she met the Defendant and
+Epstein at a summer camp, Epstein began engaging in sexual activity with her at his residence in
+Florida. Trial Tr. at 293-95, 305-06. Jane then began traveling with Epstein and the Defendant
+when she was fourteen years old. Id. at 315. As the Defendant notes, the majority of Jane's
+testimony discussing travel pertained to trips to New York and sexual activity that took place in
+New York. Maxwell Br. at 13. In her testimony, Jane recalled specific details of Epstein's New
+York residence and the sexual acts that occurred there. See Trial Tr. at 316-20. She explained
+that while she "mainly" traveled to New York on Epstein's private plane, she also took
+commercial flights. Id. at 316. She further testified that the Defendant assisted in making these
+travel arrangements. Id. at 316-17. Corroborating evidence included flight records to New York
+and photos of Epstein's New York residence matching Jane's description. See id. at 320.
+In addition to the New York trips, Jane testified about a trip she took to New Mexico with
+the Defendant and Epstein when she was fifteen or sixteen years old. Id. at 321. In her
+testimony regarding this trip, which spanned only three transcript pages, Jane explained that
+during the trip Epstein engaged in sexual activity with her similar to what took place in New
+York. See id. at 321-23. As explained above, testimony about sexual activity in other states,
+including Florida and New Mexico, was relevant to the Defendant's intent. The testimony was
+part and parcel of the Defendant and Epstein's scheme to groom underage girls at Epstein's
+various properties, including in New Mexico and Palm Beach, to then be transported to New
+York for sexual activity illegal under New York law. Accordingly, this particular testimony was
+27
+EFTA02838231
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 28 of 45
+part of the same "set of discrete facts consistent with the charge in the indictment," not a
+previously unidentified and independent theory of guilt. D'Amelio, 683 F.3d at 419; see also
+United States v.
+,, 847 F. App'x 28, 30 (2d Cir. 2021) (summary order) (no constructive
+amendment in sex trafficking case where indictment did not allege "advertising" but the
+evidence "fell squarely within the charged scheme" (cleaned up)).
+Third, the Government's summation also reflected the core of criminality of transporting
+Jane and other underage girls to New York with the intention that sexual activity would occur in
+New York. In its summation regarding Count Four, the Government focused on travel to New
+York. See Trial Tr. at 2891-92.S The Government's explanation of Counts One and Three
+followed this pattern as well, with the summation again making clear that the Defendant and
+Epstein had intended for the victims to be "sexually abused in New York." Id. at 2895. Thus,
+the Court's instructions to the jury, the evidence presented at trial, and the Government's
+argument in summation did not describe "behavior entirely separate from that identified in the
+indictment," Bastian, 770 F.3d at 223 (quoting Danielson, 199 F.3d at 670), but instead
+consistently captured the core of criminality with which the Defendant was charged.
+2. The jury note and the Court's response did not result in a
+constructive amendment.
+The Defendant contends that regardless of whether the Court's prior instructions or
+Government's arguments at trial were proper, a jury note revealed that the jury convicted the
+Defendant for intending that Jane engage in sexual activity in New Mexico, not New York. See
+Maxwell Reply at 2. She argues that the Court then erred by refusing a supplemental instruction.
+The ambiguous note and the Court's rejection of the Defendant's proposed responses to it did not
+" In its summation regarding Count Two, which introduced the New York predicate offense to the jury, the
+Government also repeatedly emphasized that the Defendant and Epstein enticed Jane to travel to New York to be
+abused. See Trial Tr. 2889-90.
+28
+EFTA02838232
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 29 of 45
+alter the fact that the evidence and instructions at trial captured the core of criminality of the
+Indictment.
+The jury note at issue read:
+Under Count Four (4), if the defendant aided in the transportation of Jane's return flight,
+but not the flight to New Mexico where/if the intent was for Jane to engage in sexual
+activity, can she be found guilty under the second element?
+Court Ex. 15, Dkt. No. 593 at 23. After hearing from the parties, the Court determined that it
+was unclear to what testimony the note referred and what legal question the note asked.
+Accordingly, the Court concluded that the appropriate course was to refer the jury back to the
+instruction for the second element of Count Four, with a reminder to consider carefully the full
+instruction. Trial Tr. at 3141. The Court also rejected the Defendant's supplemental instruction
+proposed the following day because it was partially unresponsive, partially redundant, and
+partially an erroneous statement of law. Id. at 3148-50.
+The Defendant's contention that this series of events worked a constructive amendment
+to the Indictment is without merit. First, the Defendant speculates extensively about which
+flights and evidence the jury was referencing in the note, hazarding that the jury was focused on
+a 1997 flight from New York to New Mexico and an unidentified return flight to Florida. See
+Maxwell Br. at 14-15. But Jane testified about taking numerous flights both on Epstein's private
+plane and on commercial carriers. The note did not specify which of these many flights or other
+testimony the jury was considering. The Court could not provide supplemental instruction based
+on such a speculative foundation.
+Second, the note was not "crystal clear" as the Defendant contends. Maxwell Reply at 6.
+Rather, as sometimes occurs, the note was decidedly ambiguous as to the precise legal question
+being asked. For example, the jury could have been asking about aiding-and-abetting liability as
+29
+EFTA02838233
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 30 of 45
+to the second element. Or it could have been asking if it was permissible to consider the New
+Mexico testimony in its assessment of Count Four. Indeed, the Defendant proffered a different
+interpretation when the Court first read the note at trial. Initially, the Defendant argued that the
+jury was asking if the Defendant could be found guilty solely for aiding and abetting a flight
+home from New Mexico, which she said raised the issue of whether sexual activity could be the
+"significant or motivating purpose" for the travel. Trial Tr. at 3128-30. It was only after a
+protracted discussion, spanning ten pages of transcript, that the Defendant eventually suggested
+that the jury was considering convicting the Defendant on Count Four solely on conduct in New
+Mexico without any travel to New York. On this score, the Defendant argued at trial and argues
+now that the absence of a comma between "New Mexico" and "where/if" revealed the jury's
+thinking. Maxwell Reply at 6 n.2.° But hinging the note's meaning on an absent comma does
+not indicate a meaning "clear on [its] face." Maxwell Reply at 9. With or without the comma,
+the note was ambiguous as to the destination of the hypothetical return flight, the testimony
+being referenced, and the legal question being asked.
+The note was clear on one point the jury was asking about the second element of Count
+Four. Accordingly, the Court sent the jury back to the charge, which accurately instructed that
+Count Four had to be predicated on finding a violation of New York law. This response ensured
+that the jury focused on the correct instruction and, in turn, reminded the jury that the only state
+law at issue was New York's, even if sexual abuse in New Mexico was relevant evidence of
+intent. See United States v. Rommy, 506 F.3d 108, 126 (2d Cir. 2007) ("[A] trial court
+" The Defendant also accuses the Government of muddying the inquiry by inserting a comma in this supposedly
+crucial spot. Maxwell Reply at 5, 6 n.2. It is apparent from the Government's brief that it relied on the trial
+transcript for its transcription of the jury note, which included a comma between these words. See Gov. Br. at 13
+(quoting Trial Tr. at 3126).
+30
+EFTA02838234
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 31 of 45
+responding to a note from a deliberating jury is only required to answer the particular inquiries
+posed."); see also United States v.
+1. 903 F.2d 91, 101 (2d Cir. 1990) ("The trial judge is in
+the best position to sense whether the jury is able to proceed properly with its deliberations, and
+[sJhe has considerable discretion in determining how to respond to communications indicating
+that the jury is experiencing confusion."). The jury was free to send a clarifying or further note
+following the Court's instruction.
+By contrast, the Defendant failed to propose a legally accurate response for the jury. Her
+proposed responses to the note on the day it was received and the following morning were
+erroneous. At the time the Court received the note and discussed it with counsel, the Defendant
+first proposed that the answer to the note's question was simply "no" because, she argued, a
+return flight is for the purpose of returning home, "not for the purpose of illegal sexual activity."
+Trial Tr. at 3128-30. But the Court could not respond "no" to an ambiguous question. Id. at
+3138. Moreover, the Defendant eventually conceded the principle that assistance with a return
+flight home could aid and abet a trip that was for the purpose of illegal sexual activity. See id. at
+3136. Alternatively, the Defendant requested that if the Court were to refer the jury to the
+charge, that it direct the jury to lines 14 to 17 of Instruction No. 21, which instructed on
+"significant or motivating purpose." Id. at 3131. But it was unclear that those particular lines
+addressed the jury's question, and the Court's decision to refer the jury to the entirety of
+Instruction No. 21 encompassed those lines.
+The following day, although the jury had not sought further clarification, the Defendant
+took another pass at proposing an additional response to the note. She requested a three-
+paragraph supplemental instruction that referenced elements of Counts Two and Four. See Dkt.
+31
+EFTA02838235
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 32 of 45
+No. 566.' The Second Circuit has cautioned that supplemental instructions "enjoy special
+prominence in the minds of jurors," Arroyo v. L
+1, 685 F.2d 35, 39 (2d Cir. 1982), and that
+complete accuracy is of "crucial importance," United States v. Kopstein, 759 F.3d 168, 172 (2d
+Cir. 2014) (quoting United States v. Lefkowitz, 284 F.2d 310, 314 (2d Cir. 1960)). Portions of
+the requested instruction were unresponsive, portions were redundant, and portions were legally
+inaccurate. The first paragraph, which pertained to Count Two, was unresponsive to the jury's
+note that asked only about Count Four. The second paragraph was unnecessary because it was
+redundant. The Defendant now raises for the first time, in a footnote, that the Court should have
+sua sponte provided the jury this paragraph alone. Maxwell Reply at 9 n.4. But the charge as a
+whole already made clear that a violation of New York Penal Law Section 130.55 was the key
+inquiry. See Jury Charge at 20, 23, 26, (specifying "a criminal offense under New York
+law"), 24 (Count Two instructions on New York Penal Law Section 130.55), 28 (Count Four
+referring back to these instructions), 49-50 (specifying the overt act of Jane traveling "from
+Florida to New York for purposes of sexually abusing her at the New York Residence, in
+violation of New York Penal Law, Section 130.55"). Finally, the proposal also inaccurately
+stated that "sexual activity in any state other than New York cannot form the basis" of
+" The requested instruction read:
+As to the third element of Count Two, you must determine whether the Government has proven beyond a
+reasonable doubt that the Defendant acted with the intent that Jane would engage in sexual activity within
+the state of New York in violation of New York Penal Law 130.55.
+As to the second element of Count Four, you must determine whether the Government has proven beyond a
+easonable doubt that the Defendant transported Jane with the intent that Jane would engage in sexua
+ctivity within the state of New York in violation of New York Penal Law 130.55
+An intent that Jane engage in sexual activity in any state other than New York cannot form the basis of
+these two elements of Counts Two and Four.
+Dkt. No. 566 at 7.
+32
+EFTA02838236
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 33 of 45
+convictions on Counts Two and Four, erroncously implying that such evidence was irrelevant.
+Dkt. No. 566 at 7 (emphasis added). Thus, in light of the note's ambiguity and the Defendant's
+failure to propose an accurate response in either the first attempt or the second attempt a day
+later, the Court's decision to refer the jury back to the legally sound charge was not error and
+plainly did not result in a constructive amendment to the Indictment.
+The Defendant does not expressly contend that the instructions were legally erroneous-
+nor could she. As explained above, the charge made clear that the only predicate state law at
+issue was New York's. Instead, the Defendant objects that the charge was "stripped of any
+mention of 'travel to New York."" Maxwell Br. at 15. But the Court rejected the Defendant's
+specific requests that were unnecessary, inaccurate, or would have confused the jury. For
+example, the Court rejected the Defendant's request to limit the charge to requiring travel from
+"Florida to New York," as alleged in the "to wit" clause of the Indictment, because travel from
+New Mexico to New York, for example, would also have been sufficient. See Trial Tr. at 2758-
+61 (Charging Conference); see also United States v. Little, 828 F. App' x 34, 37-38 (2d Cir.
+2020) (summary order) (noting that generally, ""to wit' clauses do not modify essential elements
+of the offense"). The Court also denied the Defendant's request to instruct the jury on law
+governing the age of consent in New Mexico, the United Kingdom, and Florida. First, the
+Defendant's proposal oversimplified New Mexico's age of consent law. The Court could not
+accurately instruct the jury on New Mexico's law without potentially introducing a theory of
+guilt that the Government had not charged, or resolving a factual question on the use of force for
+the jury. Trial Tr. at 1712-13; Nov. 23, 2021, Final Pretrial Conference Tr. at 31-38. And
+second, instructing on state law that the Defendant was not alleged to have violated ran a serious
+risk of confusing the jury as to the role of that law. Indeed, it was the Defendant's proposal that
+33
+EFTA02838237
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 34 of 45
+ran the risk of moving the jury away from consideration of the core of criminality alleged in the
+Indictment.®
+The appropriate approach was to instruct the jury on the one and only predicate state
+offense for the
+Act counts charged in the Indictment: New York Penal Law Section
+130.55. For that reason, the Court also rejected the Defendant's request to repeat in the charge
+the limiting instructions as to Kate's and Annie's testimony and the Defendant's request, raised
+for the first time at the charging conference and well after completion of her testimony, to
+include an unspecified limiting instruction as to Jane's New Mexico testimony. Trial Tr. at
+2773-77. During the witnesses' testimony, the jury had yet to be instructed on the meaning of
+"illegal sexual activity as alleged in the indictment." But it was unnecessary to repeat the
+limiting instructions alongside the charge's definition of "illegal sexual activity." Id. at 2774-75.
+The jury now had that phrase clearly defined as a violation of New York Penal Law Section
+130.55. In sum, the jury instructions charged that the jury could convict the Defendant only on
+the predicate state offense of New York law. The jury is presumed to have followed these
+instructions. See United States v. Joyner, 313 F.3d 40, 47 (2d Cir. 2002).
+At bottom, the Defendant asks the Court to speculate based on an ambiguous note that
+the jury disregarded Jane's substantial testimony about travel to New York and sexual conduct in
+New York and further assumed a violation of New York law could be based on conduct only in
+New Mexico. It is hardly plausible, let alone substantially likely, that this was the jury's
+" The Defendant's proposed instruction on other jurisdictions" ages of consent first stated that "[t]o prove Counts
+One and Three, the government must establish beyond a reasonable doubt that Ms. Maxwell acted with the intent
+that the minors would engage in sexual activity for which any person can be charged with a criminal offense."
+Request to Charge at 51. It then instructed on the ages of consent in several jurisdictions and stated that *filf the
+individual was at or above the age of consent in the relevant jurisdiction when the sexual activity occurred, then for
+the purposes of Counts One and Three, the sexual activity was not illegal." Id. at 52. This proposed instruction
+would likely have created the confusion the Defendant raises now.
+34
+EFTA02838238
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 35 of 45
+understanding. See D'Amelio, 683 F.3d at 416. Accordingly, the Court concludes that no
+constructive amendment resulted as to Count Four.
+3. No constructive amendment occurred as to Count Three.
+The Defendant's argument as to constructive amendment of Count Three, conspiracy to
+transport, wholly depends on her theory as to Count Four.? She argues that since it is "clear" that
+the jury convicted the Defendant of Count Four based only on Jane's New Mexico testimony, it
+must have convicted on the same basis for the conspiracy counts. Maxwell Br. at 16. Because
+no constructive amendment resulted as to Count Four, this argument is unavailing. But even if
+the Court were persuaded that the jury note revealed that the jury convicted the Defendant of
+Count Four on that basis, the note pertained only to Count Four and provided no basis to
+speculate as to the jury's conviction of Count Three. Moreover, it is not substantially likely that
+the jury convicted the Defendant of Count Three on Jane's New Mexico testimony alone. As
+described in detail above in the Court's denial of the Defendant's Rule 29 motion, the
+Government presented evidence that Annie and Carolyn were also victims of the conspiracy.
+Accordingly, even if a constructive amendment resulted as to Count Four, vacatur would still not
+be warranted as to Count Three.
+C. No prejudicial variance occurred.
+In the alternative, the Defendant argues that she was substantially prejudiced because the
+Indictment did not contain any allegations that Jane was sexually abused in New Mexico. She
+therefore claims she was unfairly surprised by its introduction. For purposes of this motion, the
+Court will assume that Jane's testimony regarding New Mexico constituted a variance from the
+" As noted above, because the Court will not enter judgment on Count One on the parties" consent, the Court
+addresses only Count Three here. In any event, the Defendant's arguments as to why Counts One and Three were
+constructively amended are the same. See Maxwell Br. at 16.
+35
+EFTA02838239
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 36 of 45
+Indictment. The Defendant has nevertheless failed to show that she was substantially prejudiced
+by this evidence. See Salmonese, 352 F.3d at 621.
+When a defendant has notice of the government's theory of the case before trial, she is
+not prejudiced by a variance. See Kaplan, 490 F.3d at 129-30. Pretrial disclosures may put a
+defendant on notice of evidence not specifically included in the indictment. See Khalupsky, 5
+F.4th at 294. And a defendant's failure to object to allegedly surprising evidence or to request a
+continuance when evidence is introduced suggests that a defendant was not unfairly surprised or
+prejudiced. See Kaplan, 490 F.3d at 130.
+Here, the Defendant had sufficient notice of the Government's theory of the case, and of
+Jane's testimony regarding New Mexico specifically, to avoid substantial prejudice. The
+Indictment charged a scheme to sexually abuse underage girls in New York. In service of this
+scheme, the Indictment alleged that Epstein and the Defendant groomed the victims for abuse at
+various properties and in various states, including Epstein's ranch in New Mexico. Jane had
+long recalled traveling to New Mexico, see Maxwell Br. at 16-17, although she did not report
+that Epstein had engaged in sexual activity with her at this property until closer to trial. But the
+Defendant had adequate notice of this particular testimony such that there was no danger of
+substantial prejudice. The Defendant received the Government's notes of Jane's interview where
+she recalled abuse in New Mexico on November 6, 2021, more than three weeks before trial. At
+that point, the parties were still litigating the very instructions for Kate and Annie that the
+Defendant claims she would have sought for Jane had she received adequate notice. See, e.g.,
+Nov. 23, 2021 Tr. at 28-38; see also Lebedev, 932 F.3d at 54 (concluding in part that the
+defendant was not "unfairly and substantially" prejudiced because "[t]he government disclosed
+the evidence and exhibits ... four weeks prior to trial"). Moreover, that the Defendant did not
+36
+EFTA02838240
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 37 of 45
+request a continuance or object to Jane's testimony until the charging conference suggests that
+she was not unfairly surprised. See Kaplan, 490 F.3d at 130. Accordingly, there is no indication
+in the record that the evidence adduced at trial unfairly surprised or prejudiced the Defendant.
+Finally, the Defendant argues that Jane's testimony resulted in the "ultimate prejudice"
+because it led to the jury improperly convicting her on three of the four
+Act counts.
+Maxwell Br. at 18. For the same reasons noted above, the Defendant was not prejudiced by the
+Court's response to the jury note because the ambiguous note did not reveal that the jury
+improperly convicted the Defendant of the
+Act counts. Moreover, as explained above, the
+Defendant's request for a limiting instruction in the jury charge and a supplemental instruction
+following the ambiguous jury note was unnecessary. While Kate's and Annie's limiting
+instructions were appropriate at the time of their testimony when the jury had not yet been
+instructed on the meaning of "illegal sexual activity," it was unnecessary and potentially
+confusing to repeat them again in the context of the charge. At that point, the charge made clear
+to the jury that only a violation of New York law could form the predicate for the
+Act
+counts not New Mexico law. In sum, the Defendant has not shown that she suffered
+"substantial prejudice" meriting the vacatur of the
+] Act counts.
+IV. The Court denies the Defendant's pre-indictment delay claim.
+Last, the Defendant argues, as she did in two pretrial motions, that all of her convictions
+should be vacated because of the Government's allegedly excessive and prejudicial delay in
+prosecuting the Defendant. As this Court previously explained, because "the statute of
+limitations is 'the primary guarantee against bringing overly stale criminal charges, the
+Defendant must satisfy a stringent two-part test. Maxwell, 534 F. Supp. 3d at 316 (quoting
+United States v. Cornielle, 171 F.3d 748, 751 (2d Cir. 1999)). The Defendant "must show both
+37
+EFTA02838241
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 38 of 45
+that the Government intentionally delayed bringing charges for an improper purpose and that the
+delay seriously damaged [her] ability [to] defend against the charges." Id. (citing Cornielle, 171
+F.3d at 751).
+In its prior rulings, this Court concluded that the Defendant satisfied neither requirement:
+there was "no evidence that the Government's delay in bringing these charges was designed to
+thwart Maxwell's ability to prepare a defense," and she "failed to establish actual prejudice from
+the Government's delay." Id. at 316-17. But, the Court explained, the Defendant could renew
+her motion if the factual record at trial showed prejudice that the pretrial record did not. The
+Defendant now renews her motion, identifying a bevy of documentary records and witnesses
+that, she says, were unavailable because of the Government's delay. The Court, for the reasons
+stated below, disagrees and denies the motion.
+As an initial matter, even if the Court accepts all of the Defendant's contentions in her
+briefing, her pre-indictment delay claim must fail because the Defendant has made no claim that
+the Government intentionally delayed the Indictment to gain a tactical advantage over the
+Defendant. United States v. Alameh, 341 F.3d 167, 176 (2d Cir. 2003). The Court has twice
+concluded that "nothing in the record indicates that the Government's delay in bringing these
+charges was designed to thwart Maxwell's ability to prepare a defense." Maxwell, 2021 WL
+3591801, at *5.
+It is the Defendant's burden to prove the Government's improper motive, but in
+her briefing she does not attempt to present evidence of intentional delay for tactical advantage.
+The Court therefore does not alter its prior conclusion. If anything, as the Government notes,
+testimony at trial supplied legitimate explanations for the Government's failure to indict the
+Defendant at an earlier time. For example, several witnesses testified that their cooperation with
+38
+EFTA02838242
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 39 of 45
+the Government's investigation was relatively recent, e.g., Trial Tr. at 354 (Jane), 1245 (Kate),
+1680-84 (Carolyn), suggesting that an earlier prosecution was not feasible.
+Even on the first step of the inquiry, the Defendant has failed to demonstrate that she
+suffered actual and substantial prejudice from delay. United States v. Pierre-Louis, No. 16 CR
+541 (CM), 2018 WL 4043140, at *5 (S.D.N.Y. Aug. 9, 2018). Substantial prejudice is a
+stringent standard. The Defendant's "proof of prejudice must be definite and not speculative."
+United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982). Actual prejudice "is commonly
+demonstrated by the loss of documentary evidence or the unavailability of a key witness."
+Cornielle, 171 F.3d at 752. But "claims of mere loss of memory resulting from the passage of
+time have been held to be insufficient." Pierre-Louis, 2018 WL 4043140, at *4. And for any
+evidence lost because of delay, the Defendant "must "demonstrate how (the loss of evidence) is
+prejudicial' to her." Birney, 686 F.2d at 106 (quoting United States v. Mays, 549 F.2d 670, 677
+(9th Cir. 1977)).
+The Defendant identifies two major sets of lost evidence that, she says, demonstrate
+actual prejudice to her defense at trial. First, she points to documentary evidence absent at trial:
+(1) flight records, including passenger manifests and records from Epstein's travel agent, that
+may have been more detailed than the flight logs entered at trial; (2) financial documents,
+including bank records and credit card records, which would have revealed more about the
+Defendant's receipt of funds from Epstein and could have been used to verify or disprove certain
+dates; (3) a complete set of the Defendant's phone records; and (4) Epstein's property records for
+both his New York and New Mexico residences. Second, the Defendant identifies four deceased
+witnesses: Albert Pinto and Roger Salhi, architects that built and renovated Epstein's residences
+in Florida, New York, and New Mexico; L
+_, a property manager for Epstein in the
+39
+EFTA02838243
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 40 of 45
+2000s that could have testified the household manual was created by "the Countess," not the
+Defendant; and
+Fontanilla, a live-in housekeeper for Epstein in New York that could have
+testified about the Defendant's and Epstein's habits.
+None of these identified pieces of alleged evidence satisfies the Defendant's burden of
+proving actual and substantial prejudice. The Court addresses first the documentary evidence.
+First, the Defendant does not attest, or even suggest, what the absent documents are likely to
+show. Though the Defendant would herself be best positioned to explain her own financial
+transactions (or the lack thereof), her brief does not suggest what the absent financial records
+would have shown. Similarly, the Defendant does not identify what would have been shown in
+the absent phone records. The same is true of the flight records that the Defendant argues were
+missing. At trial, the Government elicited testimony that flight manifests from before September
+11, 2001, were far less detailed than modern manifests. E.g., Trial Tr. at 2518-22. The
+Defendant can therefore only speculate that more accurate records ever existed. The location
+and appearance of Epstein's residences were also the source of significant testimony at trial. The
+Defendant does not explain what additional information would have been contained in official
+property records.
+Second, even if more detail of the contents of these documents were presented, the
+Defendant fails to show why the evidence, if admitted at trial, would have benefitted her case.
+The Defendant's motion presumes that each piece of missing evidence would have favored her:
+an absence of payments by Epstein to the Defendant, an absence of phone calls from the
+Defendant to victims, an absence of the victims on detailed flight manifests. But this
+presumption is purely speculative. Each piece of evidence may very well have further
+substantiated the Government's case. Because the Defendant carries the burden of proof, she is
+40
+EFTA02838244
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 41 of 45
+not entitled to the inference that all absent evidence would have been both favorable and material
+to her case. United States v. Berry, No. 20-CR-84 (AJN), 2021 WL 2665585, at *2 (S.D.N.Y.
+June 29, 2021).
+Third, the Defendant must show that the prejudicial loss of evidence was caused by the
+pre-indictment delay. That is, the Defendant must show that the evidence was at one point
+available but that at trial "the lost testimony or information was not available through other
+means." Pierre-Louis, 2018 WL 4043140, at *4 (quoting United States v. Sprouts, 282 F.3d
+1037, 1041 (8th Cir. 2002)). Here, the Defendant has made only a "bare allegation that [certain]
+records have been lost or destroyed," but without explaining when or why they were lost. United
+States v. Dornau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973). Further, the Defendant does not
+explain whether any attempt was made to acquire these records either directly or by other means.
+It is unexplained, for example, why the Defendant believes that government property records that
+at one point existed are no longer available. Or why the Defendant could not have proven
+Epstein's residency by any alternative means. Similarly, the Defendant does not explain why the
+flight manifests that pilot Larry Visoski delivered to Epstein's office in New York have been
+lost. See Trial Tr. at 172. In short, the Defendant fails to show that the absence of documentary
+evidence was causally related to any decision by the Government to delay the Indictment.
+For similar reasons, the Defendant fails to demonstrate prejudice by reference to the
+deceased potential witnesses.
+First, "[c]ourts have generally found that vague assertions that a
+deceased witness might have provided favorable testimony do not justify dismissing an
+indictment for delay." Maxwell, 534 F. Supp. 3d at 317; see, e.g., United States v. Lovasco, 431
+U.S. 783, 785-86, 788-90 (1977) (reversing dismissal for pre-indictment delay where a material
+defense witness had died); United States v.
+668 F.2d 686, 689 (2d Cir. 1982) (two
+41
+EFTA02838245
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 42 of 45
+defense witnesses died three years or more prior to indictment); United States v. L
+, 560 F.2d
+122, 130 (2d Cir. 1977) (defense witness died a year prior to the indictment). Here, the
+Defendant largely speculates about the contents of these deceased witnesses' absent testimony.
+She states, for example, that the two architect witnesses "could have established" the timeline for
+Epstein's residences and renovations at each but does not say what that timeline is. Maxwell Br.
+at 29. Similarly, the Defendant states that Epstein's live-in housekeeper could have testified that
+the Defendant spent only limited time with Epstein at his townhouse in New York but provides
+little basis or detail for that anticipated testimony. As with the documentary evidence above,
+such speculation, with the apparent presumption that absent evidence would necessarily favor the
+Defendant, is insufficient to establish actual prejudice. See United States v. Long, 697 F. Supp.
+651, 657 (S.D.N.Y. 1988) (no prejudice where there is "no way of knowing what [an absent
+witness's] testimony would have been").
+Second, the Defendant fails to establish that the content of these witnesses' testimony
+could not have been introduced into trial by other means. At trial, witnesses testified that Epstein
+employed a significant number of individuals to work at his residences, renovate those
+residences, or fly his private airplane. Some, like Juan Alessi, Larry Visoski, and David
+Rodgers, testified at trial. Still others were listed on the parties' witness lists. The Defendant
+does not explain why these witnesses' testimony, or the testimony of those listed witnesses who
+were not called, could not have supplied the same information that she seeks from individuals
+who were unavailable to testify. Her assertion that only individuals that have since died could
+provide adequate testimony is entirely unsubstantiated. Similarly, the Defendant does not
+explain why evidence of construction or renovations at Epstein's residences could not be proven
+by other witness testimony or by documentary evidence.
+42
+EFTA02838246
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 43 of 45
+And third, the Defendant does not demonstrate that such witnesses, even if available to
+testify as the Defendant speculates they may have, would have meaningfully altered her defense
+such that she was substantially prejudiced by their absence. Pierre-Louis, 2018 WL 4043140, at
+*4. No witness listed could testify directly to whether or not the Defendant and Epstein sexually
+abused the victims. Rather, each would at best provide additional corroboration of the
+Defendant's arguments at trial to impeach the witnesses' credibility as to particular aspects of
+their testimony. This falls short of substantial prejudice. United States v. Lawson, 683 F.2d 688,
+694 (2d Cir. 1982) (no prejudice where absent witness's testimony was "at best corroborative on
+minor points").
+Specifically, the housekeeper's anticipated testimony that the Defendant rarely spent the
+night at Epstein's townhouse and that she and Epstein were not "always" together contradicts
+little, if any, of the Government's case at trial. Maxwell Br. at 30. The Defendant does not
+claim that the housekeeper was always aware of the Defendant's or Epstein's actions, and so is
+unlikely to have rebutted testimony that at other times and other locations, the Defendant and
+Epstein committed crimes. See Pierre-Louis, 2018 WL 4043140, at *4 (absence of a witness not
+prejudicial because unless the witness was with the defendant "every moment," it would have
+been "impossible for him to testify that defendant did not commit the charged crimes").
+The speculated testimony of
+that an individual known only as "the
+Countess," not the Defendant, wrote the household manual—is similarly unhelpful to the
+Defendant's claim. In considering whether testimony would have been beneficial to the
+Defendant, the Court must consider whether the witness would have been credible and withstood
+cross-examination. See Maxwell, 534 F. Supp. 3d at 317 (citing United States v. Spears, 159
+F.3d 1081, 1085 (7th Cir. 1999)). The Defendant provides no basis to conclude that the jury
+43
+EFTA02838247
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 44 of 45
+would have credited this vague testimony about an unnamed individual over the evidence
+presented at trial, including the testimony of Juan Alessi and an email chain between the
+Defendant and
+that indicates that the Defendant worked closely with
+to
+create the manual and provided specific content, such as the checklists, to be included. See GX-
+424.
+Finally, the Defendant refers to her prior briefing in which she alleged substantial
+prejudice because of the absence of other deceased potential witnesses, including Epstein,
+Epstein's mother, Jane's talent agent Michael
+and Palm Beach Police Department
+Detective
+Recarey. See Dkt. No. 138 at 8-11. The Court has previously considered and
+rejected the Defendant's claim of prejudice based on these absent witnesses. Maxwell, 534 F.
+Supp. 3d at 317. The Defendant points to no development at trial that she believes should alter
+the Court's conclusion, nor is the Court aware of any such reason for reconsideration.
+The Defendant's reply brief devotes just a single sentence to her claim of pre-indictment
+delay and does not address any of the defects identified by the Government. She has not
+satisfied either element required for a claim of pre-indictment delay, as she has not demonstrated
+that the Government improperly delayed prosecution nor that she suffered actual and substantial
+prejudice from such delay. The Court therefore denies her motion to vacate her convictions on
+this basis.
+Conclusion
+For the foregoing reasons, the Court denies the Defendant's Rule 29 motion because the
+jury's guilty verdicts were supported by the witness testimony and documentary evidence
+presented at trial. The Court denies the Defendant's motion based on constructive amendment or
+variance because the jury instructions, the Government's evidence at trial, and summation all
+44
+EFTA02838248
+
+Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 45 of 45
+captured the core of criminality charged in the Indictment, and the Defendant was not prejudiced
+by any alleged variance. Further, because the Government neither intentionally delayed its
+prosecution nor was the Defendant prejudiced by any delay, the Court also denies the
+Defendant's motion based on pre-indictment delay. Finally, the Court grants the Defendant's
+motion as to multiplicity. The Government concedes that Count One is multiplicitous with
+Count Three, and the Court further concludes that Count Five is multiplicitous with Count Three.
+Count Five, like Counts One and Three, charged the Defendant's participation in the same
+decade-long unlawful agreement with the Defendant's continuous coconspirator, Jeffrey Epstein,
+to groom and sexually abuse underage girls.
+Accordingly, the Court will enter judgment of conviction on Counts Three, Four, and Six.
+The Defendant's sentencing date remains scheduled for June 28, 2022. The Court previously set
+a schedule for sentencing submissions that remains in effect. Dkt. No. 656.
+This resolves Dkt. No. 599.
+SO ORDERED.
+Dated: April 29, 2022
+New York, New York
+Ali O. Mator
+ALISON J. NATHAN
+United States Circuit Judge
+Sitting by Designation
+45
+EFTA02838249

vision-joined/court-04/866ad04329953ea47db1cb1b7865f814eec01cc6492b500790894cbad9da745b.json

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+}

vision-joined/court-04/866ad04329953ea47db1cb1b7865f814eec01cc6492b500790894cbad9da745b.md

@@ -0,0 +1,144 @@
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 1 of 8
+Exhibit T
+EFTA02829881
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 2 of 8
+Waiver of Extradition:
+United Kingdom
+EFTA02829882
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 3 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+UNITED STATES OF AMERICA,
+- against -
+GHISLAINE MAXWELL,
+Docket No. 20-CR-330 (AJN)
+AFFIDAVIT AND WAIVER OF
+EXTRADITION
+Defendant.
+Ghislaine Maxwell, being duly sworn, deposes and says:
+1.
+I am the named defendant in the above-captioned case. I am a citizen of the
+United States, the United Kingdom, and France. I have resided in the United States since
+approximately 1991. I am currently incarcerated at the Metropolitan Detention Center in
+Brooklyn, New York.
+I have reviewed with my counsel, Mark S.
+and Christian R. Everdell of
+& Gresser, LLP, the charges contained in the superseding indictment in the above-
+captioned case (the "Indictment"). In addition, I have been informed by United States and
+United Kingdom counsel, with whom I am satisfied, of my rights under the United Kingdom's
+Extradition Act 2003 (the "Act"), which gives effect to the Extradition Treaty between the
+Government of the United Kingdom of Great Britain and Northern Ireland and the Government
+of the United States of America (the "Treaty"). I understand that, in proceedings in the United
+Kingdom under the Act in respect of an extradition request by the United States under the Treaty
+in connection with the Indictment, I would be entitled to argue that I should not be extradited to
+the United States. I understand that in the absence of my consent to extradition, I cannot be
+EFTA02829883
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 4 of 8
+surrendered to the United States authorities unless and until a court in the United Kingdom issues
+a ruling finding that there are no bars to my extradition.
+3.
+If I am released on bail in connection with the Indictment, I hereby voluntarily
+and irrevocably waive any rights to contest any extradition request by the United States under the
+Treaty with respect to the offenses charged in the Indictment. Specifically, I consent to
+extradition pursuant to Part 2 sections 127 and 128 of the Act in connection with the offenses
+charged in the Indictment. In addition, to the extent that it might be relevant, I waive any rights
+to assert that any bars to extradition apply, and I confirm that no such bars apply.
+4.
+In the event that I violate my bail conditions after being released, I understand
+that the purpose of this affidavit is for the government to offer it to the authorities in the United
+Kingdom when my extradition is sought by the United States government in relation to the
+charges in the Indietment. I understand that the United Kingdom authorities may use this
+affidavit to assist in determining my extraditability.
+I make this waiver freely and voluntarily, after having consulted with counsel.
+Dated this
+_ day of December 2020.
+Ghislaine Maxwell
+I hereby certify that on this
+day of December 2020, Ghislaine Maxwell personally appeared
+before me and made his oath in due form of law that the statements herein are true.
+The Honorable Alison J. Nathan
+United States District Judge
+Southern District of New York
+2
+EFTA02829884
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 5 of 8
+Waiver of Extradition:
+France
+EFTA02829885
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 6 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+UNITED STATES OF AMERICA,
+- against -
+GHISLAINE MAXWELL,
+Docket No. 20-CR-330 (AJN)
+AFFIDAVIT AND WAIVER OF
+EXTRADITION
+Defendant.
+Ghislaine Maxwell, being duly sworn, deposes and says:
+1.
+I am the named defendant in the above-captioned case. I am a citizen of the
+United States, the United Kingdom, and France. I have resided in the United States since
+approximately 1991. I am currently incarcerated at the Metropolitan Detention Center in
+Brooklyn, New York.
+2.
+I have reviewed with my counsel, MarkS.
+and Christian R. Everdell of
+& Gresser, LLP, the charges contained in the superseding indictment in the above-
+captioned case (the "Indictment"). In addition, I have been informed by United States and
+counsel, with whom I am satisfied, of my rights under
+law on extradition, under the
+Extradition Treaty between the United States of America and France signed 23 April 1996 (the
+"Treaty"), under the Agreement on Extradition between the United States of America and the
+European Union signed 25 June 2003 (the "USA/EU Agreement on Extradition"), under the
+Instrument Amending the Treaty of April 23, 1996 between the United States of America and
+France signed 30 September 2004 (the "Instrument Amending the Treaty"), and under the
+provisions of the
+Code of Criminal Procedure. I understand that, in proceedings in France
+under the aforementioned provisions in respect of an extradition request by the United States
+EFTA02829886
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 7 of 8
+under the Treaty as amended by the Instrument Amending the Treaty and/or under the USA/EU
+Agreement on Extradition in connection with the Indictment, I would be entitled to argue that I
+should not be extradited to the United States on the ground of my
+citizenship. I
+understand that in the absence of my consent to extradition, I cannot be surrendered to the United
+States authorities unless and until a court in France issues a ruling finding that there are no bars to
+my extradition, followed by an extradition decree issued by the
+government.
+If I am released on bail in connection with the Indictment, I hereby voluntarily and
+irrevocably waive any rights to contest any extradition request by the United States under the
+Treaty as amended by the Instrument Amending the Treaty as well as under the USA/EU
+Agreement on Extradition with respect to the offenses charged in the Indictment. Specifically, I
+consent to extradition in accordance with Article 11 of the USA/EU Agreement on Extradition as
+incorporated in the Treaty by the Instrument Amending the Treaty, in connection with the
+offenses charged in the Indictment. In addition, to the extent that it might be relevant, I waive
+any rights to assert that any bars to extradition apply, and I confirm that no such bars apply.
+In the event that I violate my bail conditions after being released, I understand that
+the purpose of this affidavit is for the government to offer it to the authorities in France when my
+extradition is sought by the United States government in relation to the charges in the Indictment.
+I understand that France authorities may use this affidavit to assist in determining my
+extraditability.
+5.
+I make this waiver freely and voluntarily, after having consulted with counsel.
+Dated this
+day of December 2020.
+Ghislaine Maxwell
+2
+EFTA02829887
+
+Case 1:20-cr-00330-AJN Document 97-20 Filed 12/14/20 Page 8 of 8
+I hereby certify that on this
+day of December 2020, Ghislaine Maxwell personally appeared
+before me and made her oath in due form of law that the statements herein are true.
+The Honorable Alison J. Nathan
+United States District Judge
+Southern District of New York
+3
+EFTA02829888

vision-joined/court-04/86765c43a6d5eeea41254ad83d9b5c73d9d398810bd2ae60a81c8187089ac744.json

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vision-joined/court-04/86765c43a6d5eeea41254ad83d9b5c73d9d398810bd2ae60a81c8187089ac744.md

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+Case 1:20-cr-00330-AJN Document 103-2 Filed 12/23/20 Page 1 of 4
+Exhibit B
+EFTA02830049
+
+Case 1:20-cr-00330-AJN Document 103-2 Filed 12/23/20 Page 2 of 4
+IN THE MATTER OF AN OPINION
+ON THE EXTRADITION LAW OF ENGLAND AND WALES
+RE GHISLAINE MAXWELL
+ADDENDUM OPINION
+1. This Addendum Opinion is provided in response to the Government's Memorandum
+in Opposition to the Defendant's Renewed Motion to Release dated 16 December
+2020, insofar as it pertains to matters of English extradition law and practice.
+2. The primary conclusions of the Opinion dated 8 October 2020 ('the Opinion')
+remain unchanged, namely: (a) in the majority of cases, proceedings in England and
+Wales in relation to US extradition requests are concluded in under two years; (b) it
+is virtually certain that bail would be refused in an extradition case in circumstances
+where the requested person had absconded from criminal proceedings in the United
+States prior to trial and in breach of bail; and (c) on the basis of the information
+currently known, it is highly unlikely' that Ghislaine Maxwell would be able
+successfully to resist extradition to the United States in relation to the charges in the
+superseding indictment dated 7 July 2020. In addition to those conclusions, the
+following three points may be made.
+3. First, as noted in the Opinion, Ms Maxwell's waiver of extradition would be
+admissible in any extradition proceedings in England and Wales. While such a
+document cannot compel a requested person to consent to their extradition once in
+the United Kingdom, the document would be a highly relevant factor in any
+contested extradition proceedings. In particular:
+(a) If Ms Maxwell were to rely on such a waiver to secure bail in the United
+States and then, having absconded, renege on the undertakings in that
+'The Government observes, at p.16 of the Motion, that this leaves open a "possibility" that extradition could be
+resisted. Absolute certainty in any legal context is rare but the practical effect of the conclusion in the Opinion is
+that, at this stage and on the basis of the information currently known, it is difficult to conceive of circumstances
+in which Ms Maxwell could successfully resist extradition, and her extradition would be a virtual foregone
+conclusion.
+"Opinion, para. 39.
+EFTA02830050
+
+Case 1:20-cr-00330-AJN Document 103-2 Filed 12/23/20 Page 3 of 4
+document to seek to resist her extradition, bail would almost certainly be
+refused for the duration of the extradition proceedings.
+(b) The majority of the bars that might be relied upon by Ms Maxwell' require
+the extradition judge to make a finding that extradition would be
+oppressive. Quite apart from the other factors rendering those bars
+unavailable to Ms Maxwell, as set out in the Opinion, it is difficult to
+conceive of circumstances in which a finding of oppression could be made
+in relation to the serious charges faced by Ms Maxwell in circumstances
+where she had absconded from the United States and was contesting her
+extradition in breach of good faith undertakings relied upon to secure her
+bail. Similar considerations apply to the balancing exercise required in
+assessing whether extradition would breach the right to family life under
+Article 8 of the ECHR. The remaining bars to extradition and human rights
+bars are unlikely to be available to Ms Maxwell for the reasons given in
+the Opinion*.
+(c) A breach of the undertakings in the waiver of extradition would be highly
+likely to be viewed as a sign of bad faith and cause the extradition judge to
+treat any evidence given by Ms Maxwell with scepticism.
+4. Second, it is not correct that section 93 of the Extradition Act 2003 ('the 2003 Act')
+confers a general discretion on the Secretary of State to refuse extradition if a case is
+sent to her by the extradition judge. The ambit of the power in section 93 is
+described at paragraph 8 of the Opinion. The Secretary of State may only refuse
+extradition on the grounds provided for in that section, namely: (a) if an applicable
+bar to extradition® is found to exist; (b) the Secretary of State is informed that the
+request has been withdrawn?; (c) there is a competing claim for extradition from
+" Opinion, para. 26. Those bars are passage of time; forum; and mental and physical condition.
+*Opinion, paras. 27-29 and 36-37.
+5 As appears to be submitted by the Government at p. 19 of the Memorandum.
+" The bars to extradition that the Secretary of State must consider are: (a) the death penalty (s. 94); (b) speciality
+(s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the
+United Kingdom from the International Criminal Court (s. 96A).
+' Extradition Act 2003, s. 93(4)(a).
+EFTA02830051
+
+Case 1:20-cr-00330-AJN Document 103-2 Filed 12/23/20 Page 4 of 4
+another state®; (d) the person has been granted asylum or humanitarian protection in
+the United Kingdom'; or (e) extradition would be against the interests of UK
+national security'°. On the information currently known, none of these bars or
+exceptions would arise in the case of Ms Maxwell.
+5.
+The exceptional nature of the Secretary of State's power is illustrated by the fact that
+it has been exercised in the favour of a requested person on only one occasion since
+the enactment of the 2003 Act, and that that single exercise of the power was based
+on grounds on which reliance may not now be placed."
+6. Third, as to the timescales of extradition proceedings arising from requests for
+extradition made by the Government of the United States, it is to be noted that the
+purpose of the 2003 Act to streamline extradition procedures? and, in practice, the
+legislation works to facilitate extradition. As noted in the Opinion' the majority of
+extradition cases conclude within two years, or three months in cases where consent
+to extradition is given.
+David
+6KBW College
+_OC
+17 December 2020
+" Extradition Act 2003, ss. 93(4)(b), 126(2) and 179(2).
+'Extradition Act 2003, s. 93(4)(c) and (6A).
+10 Extradition Act 2003, s. 208.
+" viz. in the case of Gary
+. whose extradition was refused by the Secretary of State in 2012 on the
+basis that he was seriously mentally ill and that there was a high risk of suicide were he to be extradited; since
+that decision, the Secretary of State has been barred from refusing extradition on the basis of human rights
+grounds: Extradition Act 2003, s. 70(11) (as inserted by the Crime and Courts Act 2013 with effect from 29 July
+' Welsh v United States [2007] 1 WLR 156 (Admin) para. 26.
+1 Opinion, para. 13.
+EFTA02830052

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vision-joined/court-04/86aa9970db952688a960cbc5489fe81a561f921396bf356591e8acc609fbb08e.md

@@ -0,0 +1,400 @@
+Case 1:20-cr-00330-PAE Document 382-5 Filed 10/29/21 Page 1 of 16
+EXHIBIT E
+EFTA02833298
+
+Case 1:10ągr21386ґА833QBAFner₽gcgmente782 En FEB2N 606#205/1P|2948 Фде 1 of 15
+COMPOSITE EXHIBIT A
+NON-PROSECUTION AGREEMENT AND
+ADDENDUM
+EFTA02833299
+
+Case 1:10ąge 21386A833@BAFner₽9cmente782 En FEB* 606#205/1P|2946 Фде 2 of 15
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+NON-PROSECUTION AGREEMENT
+IT APPEARING that the City of Palm Beach Police Department and the State
+Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County hereinafter,
+the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
+Epstein (hereinafter "Epstein");
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and an
+oftenses that may have been committed by Epstein against the United States from in o
+around 2001 through in or around September 2007, including:
+(1)
+knowingly and willfully conspiring with others known and unknown to
+commit an offense against the United States, that is, to use a facility or means
+of interstate or foreign commerce to knowingly persuade, induce, or entic
+minor females to engage in prostitution, in violation of Title 18, United States
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+(2)
+knowingly and willfully conspiring with others known and unknown to travel
+n interstate commerce for the purpose of engaging in illicit sexual conduct, a
+lefined in 18 U.S.C. § 2423(f, with minor females, in violation of Title I8
+United States Code, Section 2423(b); all in violation of Title 18, United States
+Code, Section 2423(e);
+(3)
+using a facility or means of interstate or foreign commerce to knowingly
+persuade, induce, or entice minor females to engage in prostitution; in
+violation of Title 18, United States Code, Sections 2422(b) and 2;
+(4)
+traveling in interstate commerce for the purpose of engaging in illicit sexual
+conduct, as defined in 18 U.S.C. § 2423(D, with minor females; in violation
+Page 1 of 7
+EFTA02833300
+
+Case 1:10ągr 21386ґА833QBAFner₽gcgmente782 en FEB 606#205/1PI2940 age 3 of 15
+of Title 18, United States Code, Section 2423(b); and
+(5) knowingly, in and aflecting interstate and foreign commerce, recruiting,
+enticing, and obtaining by any means a person, knowing that the person had
+not attained the age of 18 years and would be caused to engage in a
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(I) and 2; and
+IT APPEARING that Epstein seeks to resolve globally his state and federal crimina
+iability and Epstein understands and acknowledges that, in exchange for the benefit
+provided by this agreement, he agrees to comply with its terms, including undertaking certain
+actions with the State Attorney's Office;
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+If the United States Attorney should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attorney may, within ninety (90) days following the
+expiration of the term of home confinement discussed below, provide Epstein with timel
+notice specifying the condition(s) of the Agreement that he has violated, and shall initiate it
+prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
+notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
+United States learning of facts which may provide a basis for a determination of a breach of
+the Agreement.
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+dismissed.
+Page 2 of 7
+EFTA02833301
+
+Case 1:10ąg₽21386A883@BAFner₽9cmente782 En FEB 696#205/1P|2946 Фде 4 of 15
+Terms of the Agreement:
+1.
+2.
+4.
+6.
+Epstein shall plead guilty (not nolo contendere) to the Indictment as
+currently pending against him in the 15th Judicial Circuit in and for
+Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
+one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
+796.07. In addition, Epstein shall plead guilty to an Information filed
+by the State Attorney's Office charging Epstein with an offense that
+requires him to register as a sex offender, that is, the solicitation of
+minors to engage in prostitution, in violation of Florida Statutes Section
+796.03;
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+(a) Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of
+(b)
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the I5th Judicial Circuit
+accepting and executing the sentence agreed upon between the State
+Attorney's Office and Epstein, the details of which are set forth in this
+agreement.
+The terms contained in paragraphs 1 and 2, supra, do not foreclose
+Epstein and the State Attorney's Office from agreeing to recommend
+any additional charge(s) or any additional term(s) of probation and/o
+incarceration.
+Epstein shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction and
+sentence, except a sentence that exceeds what is set forth in paragraph
+(2), supra.
+Epstein shall provide to the U.S. Attorney's Office copies of all
+Page 3 of 7
+EFTA02833302
+
+Case 1:10ągr21386ґА833QBAFner₽gcgmente782-En FEB 606#205/1P)29L6 Фде 5 of 15
+7.
+8.
+proposed agreements with the State Attomey's Office prior to entering
+into those agreements.
+The United States shall provide Epstein's attorneys with a list of
+individuals whom it has identified as victims, as defined in 18 U.S.C.
+§ 2255, after Epstein has signed this agreement and been sentenced
+Upon the execution of this agreement, the United States, in consultation
+with and subject to the good feith approval of Epstein's counsel, shall
+select an attorney representative for these persons, who shall be paid for
+by Epstein. Epstein's counsel may contact the identified individuals
+through that representative.
+If any of the individuals referred to in paragraph (7), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Epstein waives
+his right to contest lability and also waives his right to contest damages
+up to an amount as agreed to between the identified individual and
+Epstein, so long as the identified individual elects to proceed
+exclusively under 18 U.S.C. § 2255, and agrees to waive any other
+claim for dameges, whether pursuant to state, federal, or common law.
+damages in any suit are not to be construed as an admission of any
+criminal or civil lability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal lability or a waiver of any jurisdictiona]
+or other defense as to any person whose name does not appear on the
+list provided by the United States.
+10.
+11.
+lefense as to any person, whether or not her name appears on the lis
+rovided by the United States
+Epstein shall use his best efforts to enter his guilty plea and be
+Page 4 of 7
+EFTA02833303
+
+Case 1:10ąg₽21386A833@BAFner₽9cmente782 En FEB 696#205/1P|294Ơ Фде 6 of 15
+12.
+sentenced not later than October 26, 2007. The United States has no
+objection to Epstein self-reporting to begin serving his sentence not
+later than January 4, 2008.
+Epstein agrees that he will not be afforded any benefits with respect to
+gain time, other than the rights, opportunities, and benefits as any other
+inmate, including but not limited to, eligibility for gain time credit
+based on standard rules and regulations that apply in the State of
+Florida. At the United States' request, Epstein agrees to provide an
+accounting of the gain time he earned during his period of
+incarceration.
+13.
+The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Epstein, including but not limited to
+Lesley Groff, or 1
+outstanding grand jury subpoenas shall be deemed withdrawn.
+Page 5 of 7
+EFTA02833304
+
+Case 1:10ągr21386ґА833QBAFner₽gcgmente782 En FEB 696#205/1P|2948 Фде 7 of 15
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+material to this agreement and is supported by independent consideration and that a breach
+of any one of these conditions allows the United States to elect to terminate the agreement
+and to investigate and prosecute Epstein and any other individual or entity for any and all
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+the Sixth Amendment to the Constitution of the United States provides that in all criminal
+prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
+is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deemed to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein further asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
+and consents that, if a prosecution gainst him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby weives his right to be indicted by a grand jury as
+to any such offense.
+//1
+11/
+///
+Page 6 of 7
+EFTA02833305
+
+Case 1:10ągr21386ґA833QBAFner₽gcgmente782 En FEB 696#205/1P|294O Фде 8 of 15
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+sae tetor
+By:
+VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+JEFFREY EPSTEIN
+Dated: _
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+LILLY ANN
+ESQ.
+ATTORNEY POR JEFFREY EPSTEIN
+Page 7 of 7
+EFTA02833306
+
+Case 1:080 21986-A9330 RAEme Rorigmenitered on FLIeD B6ZRE? D5/17229100 plalje 9 of 15
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+A.
+VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Dated:
+Dated: 9/24/07
+JEFFREY EPSTEIN
+Cold Front
+IFCOURT/ESC
+COUNSEL TO JEFFREY EPSTEIN
+Dated: _
+LILLY ANN
+ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+Page 7 of 7
+EFTA02833307
+
+Case 1:10ąge 21386/833QBAFner₽9cmente782-5n FEB| 6068205/1712990 1 págê 10 of 15
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Agreement and agrees to comply with thern.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+A
+[VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Dated: _
+JEPFREY EPSTEIN
+Dated: _
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Datod: 9-24-07
+ILLY ANN SANG
+Z, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+Page 7 of 7
+EFTA02833308
+
+Case 1:10ąse 21386/833QBAFner₽qcgmente782-5n FEBD| 606#205/17129902 págê 11 of 15
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+T APPEARING that the parties seck to clarify certain provisions of page 4, paragraph
+f the Non-Prosecution Agreement (hereinafter "paragraph 7*), that agreement is modified e
+7A.
+The United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
+the attorney representative for the individuals identified under the Agreement. If the
+United States elects to assign this responsibility to an independent third-party, both the
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party prior to the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such victims subject to the provisions of paragraph C, infra.
+TC.
+Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
+if after consideration of potential settlements, an attorney representative elects to file a
+contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+EFTA02833309
+
+Case 1:10ąge 21386/833QBAFner₽qcgmente782-5n FEBD 6068205/17129903 págê 12 of 15
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to hilm. Epstein hereby, states that he understands the clarifications to the Non-
+Prosecution: Agreement and agrees to comply with them.
+Dated: 10/30/07
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+TAÀ.
+Jeffin Homan FAUSA
+VILLAPANA
+ASSISTANT U.S. ATTORNEY
+Dated:
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+LILLY ANN
+, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+EFTA02833310
+
+Case 1:10ąge 21386/833QBAFner₽qcgmente782-5n FEB 6068205/17129904 page 13 of 15
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER AÇOSTA
+UNITED STATES ATTORNEY
+Dated: 10/30/07
+By:
+бА.
+ILLAFAN
+ASSISTANT U.S. ATTORNEY
+Dated:_
+Dea 0/19/07
+JEFFREY EPSTEIN
+COUNSEL TO JEFFREY EPSTEIN
+Dated: __
+LILLY ANN
+_ ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+EFTA02833311
+
+Case 1:10ase 21386833@BAFner₽9cmenteł82 5n FEB∞| 006₴/205/17129905 |
+14 of 15
+By signing this Addendum, Epstein asserts and certifies that the above hes been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Non-
+Prosecution Agreement and agrees to comply with them.
+Dated: 10/30/07
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+X4 Horan FAUSA
+fA.
+VILLAFANA
+ASSISTANT U.S. ATTORNBY
+Dated:
+JEFFREY EPSTEIN
+Dated:_
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated: 10-29-07
+LILLY ANN SANCHEZ, ESQ.
+ATTORNEY FOR JEFFREY EPSTEIN
+EFTA02833312
+
+Case 1:10ągr 21386/833QBAFner₽9cgmente782-5n FEBD 6068205/17129906 páge 15 of 15
+DBc-DT-07
+04:55pg
+Froa-i
+Burnett
+3057888201
+P.003/064 • F-I78
+Afirmation
+I, Jeffrey B. Epstein do hertby ro affirm the Noo-Proscoption Agreement and Addendura in
+name dated October 30, 2007,
+Bate
+EFTA02833313