MEMY-1805 harvest: vision-joined (part 24)

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vision-joined/court-04/b110b547c9d4ec60ef41179784e9e05610e1a08c8c3c6983882cffb3d9fe4c3b.md

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+Case 1:15-cv-07433-LAP Document 792-1 Filed 03/24/17 Page 1 of 4
+EXHIBIT D
+EFTA02803594
+
+Case 1:15-cv-07433-LAP Document 792-1 |
+Filed 03/24/17 Page 2 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+--X
+Declaration of Ghislaine Maxwell
+1, Ghislaine Maxwell, pursuant to 28 U.S.C. § 1746 declare as follows:
+1. 1am the defendant in the above captioned matter.
+2. I respectfully submit this Declaration in response to allegations and statements made
+in Plaintiff's Response to the Motions in limine to exclude the "Victim Notification" Letter,
+References to Crime Victims Rights Act Litigation, Jeffrey Epstein Plea and Non-Prosecution
+Agreement and Sex Offender Registration, and the Jane Doe 102 Complaint.
+3. It is my understanding that Plaintiff's Responses claim that I was aware or had
+knowledge of each of the documents or events at issue in the foregoing listed motions as of
+January 2015 when
+Gow issued Mr. Barden's statement on my behalf ("the January 2015
+Statement"). This is inaccurate.
+4. As I stated in my deposition on April 22, 2016, I had no knowledge, prior to this
+lawsuit, of the Non-Prosecution Agreement between Jeffrey Epstein and the United States
+EFTA02803595
+
+Case 1:15-cv-07433-LAP Document 792-1 Filed 03/24/17 Page 3 of 4
+government, other than reading in the press that
+was identified as an alleged co-
+conspirator. I had never, and still have not, seen the document or reviewed its contents.
+5.
+I was aware that Mr. Epstein served jail time. I had and have no knowledge of the
+specifics as to how or why that occurred. As stated in my deposition, I knew that Mr. Epstein
+was alleged to have hired an underage prostitute, but I was unaware of the nature or basis for his
+conviction. I have been informed that there is a plea agreement between Mr. Epstein and a
+governmental entity. Prior to the January 2015 Statement, and to date, I have never seen that
+document or reviewed its contents.
+6. Prior to the January 2015 statement, I had never seen any document, in any format,
+in which the Plaintiff in this case was listed or identified as a "victim" by any governmental
+agency or organization, including but not limited to, the U.S. Attorney's Office. This includes
+the document identified as the "Victim Notification" letter.
+7. Prior to the January 2015 Statement, I was unaware that the federal government
+conducted any investigation of Mr. Epstein. I was never contacted in connection with any such
+alleged investigation. I have no knowledge if such an investigation ever occurred, what might
+have been investigated, or the conclusions of such investigation.
+8. Prior to the January 2015 Statement, to the best of my recollection, 1 never reviewed
+a copy of the Complaint filed in the action captioned Jane Doe 102 v. Jeffrey Epstein.
+9. At the time the Jane Doe 3 Joinder Motion was filed, I had never previously heard of
+the litigation in which that document was filed. I do not recall receiving or reviewing an actual
+copy of the Joinder Motion. Rather, I was informed that the press was asking about the
+2
+EFTA02803596
+
+Case 1:15-cv-07433-LAP Document 792-1
+Filed 03/24/17
+Page 4 of 4
+allegations contained in a court filing, and I had read in the press descriptions of the allegations.
+I, through my attorney, was reacting to the press descriptions of the allegations. Prior to the
+January 2015 Statement being issued, I did not read the complete Joinder Motion.
+10. To this day, I am unaware of the reasoning or background of the "Crime Victim's
+Right Act" litigation. Prior to late December 2014, I did not know the case existed. After
+receiving press calls through my representatives, I was aware that there was a litigation. I was
+not aware of the nature of the litigation, the caption or title of the litigation, that it was referred to
+as the "Crime Victim's Rights Act" litigation, the legal basis for the claims, why plaintiff was
+filing a document in the litigation, or the overall purpose of the litigation.
+. I declare under penalty of perjury that the foregoing is true and correct.
+Executed on March 24, 2017.
+Ghislaine Maxwell
+3
+EFTA02803597

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vision-joined/court-04/b12c4c4c86beded1edc93c0d6e3a81f61ec1938756374772d32768192fa14118.md

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+Case 1:20-cr-00330-PAE
+Document 466
+Filed 11/15/21 Page 1 of 1
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+UNITED STATES OF AM
+USA / Plaintiff(s)
+Case No.: 20 CR 330
+GHISLAINE MAXWELL,
+Defendant(s)
+)
+NOTICE OF FILING OF OFFICIAL TRANSCRIPT
+INFERENC
+Notice is hereby given that an official transcript of a
+held on
+has been filed by the court reporter/transcriber in the above-captioned matter.
+11/1/21
+Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting
+the transcript is a judge or a member of the public or media.
+The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court
+any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also
+be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically
+available to the public without redaction after ninety (90) calendar days.
+This process may only be used to redact the following personal data identifiers: Social Security
+numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure
+5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information
+may proceed by motion.
+I (we) certify that the foregoing is a correct transcript from the record of proceedings in the above-
+entitled matter.
+mcdaniel
+Court Reporter/Transcriber
+Date
+EFTA02835017

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vision-joined/court-04/b13fe79a26e648b18b18fd0e9c7397da48e7a2c416bf2d1328b3815b20d7522f.md

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+Case 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 1 of 2
+LAW OFFICES OF BOBBI C. STERNHEIM
+212-243-1100 • Main
+917-306-6666 • Cell
+888-587-4737 • Fax
+33 West 19th Street - 4th Floor
+New York, New York 10011
+bc@sternheimlaw.com
+November 24, 2020
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC #:
+DATE FILED: _11/24/20
+Honorable Alison J. Nathan
+United States District Judge
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re: United States v. Ghislaine Maxwell
+20 Cr. 330 (AJN)
+Dear Judge Nathan:
+As counsel for Ghislaine Maxwell, I write in response to the government's letter, dated
+November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and
+confirming that she is currently in quarantine due to contact with a staff member, assigned to her
+isolation pod, who tested positive for COVID-19.
+The government recites a variety of allowances given Ms. Maxwell, including being
+permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
+total time allotted for showering, making personal calls, and using the CorrLinks email system to
+communicate with family and counsel. However, the letter presents an incomplete picture of
+Ms. Maxwell's conditions of confinement.
+The government fails to mention a variety of issues brought to the attention of the MDC,
+including but not limited to the fact: that all email correspondence between Ms. Maxwell and
+counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
+after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
+to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
+inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
+without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
+daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her
+of results of the COVID tests nor provided information in response to her inquiry regarding what
+she should do if she becomes symptomatic.
+The letter omits the fact that while staff are not supposed to enter Ms. Maxwell's
+isolation cell during quarantine, an unidentified man entered to take photographs and a guard
+entered to search. Further, while counsel assumed that an in-person legal visit scheduled for
+Saturday, November 21, would be canceled as a result of Ms. Maxwell's quarantine status, no
+notification was provided; and a request for a substituted legal call was not accommodated.
+EFTA02829677
+
+Case 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 2 of 2
+LAW OFFICES OF BOBBI C. STERNHEIM
+The government highlights what Ms. Maxwell is permitted but not what she is denied:
+equal treatment accorded other inmates in general population. Ms. Maxwell has spent the
+entirely of her pretrial detention in de facto solitary confinement under the most restrictive
+conditions where she is excessively and invasively searched and is monitored 24 hours per day.
+In addition to camera surveillance in her cell, a supplemental camera follows her movement
+when she is permitted to leave her isolation cell and is focused on Ms. Maxwell and counsel
+during in-person legal visits. And despite non-stop in-cell camera surveillance, Ms. Maxwell's
+sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether
+she is breathing.
+Ms. Maxwell is a non-violent, exemplary pretrial detainee with no criminal history, no
+history of violence, no history of mental health issues or suicidal ideation. She is overmanaged
+under conditions more restrictive than inmates housed in 10South, the most restrictive unit in the
+MCC; or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence
+ADMAX, the most restrictive facility operated by the BOP. The MDC concedes that it is unable
+to place her in general population for her safety and the security of the institution but fails to
+explain why she is deprived of all other opportunities provided to general population inmates.
+Stating that Ms. Maxwell "continues to have more time to review her discovery than any
+other inmate at the MDC, even while in quarantine" gives the unfair impression that she is being
+given a perquisite. However, given the voluminous discovery in this case, the most recent
+production alone being 1.2 million documents, the time accorded Ms. Maxwell remains
+inadequate for her to review and prepare the defense of her life.
+Due to the failure of MDC's Warden and Legal Department to respond to recurring
+problems and complaints, counsel have reached out to the government. While we appreciate any
+assistance provided by government counsel, it has done little to redress the many concerns
+regarding the disparate treatment of Ms. Maxwell.
+Rather than receive second-hand information from counsel, the defense requests that the
+Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms.
+Maxwell's conditions of detention.
+Your consideration is greatly appreciated.
+cc: All Counsel
+Very truly yours,
+Bobbi C. Sternheim
+BOBBI C. STERNHEIM
+SO ORDERED. 11/24/20
+Ali O. Natter
+Alison J. Nathan, U.S.D.J.
+2
+The parties are hereby ORDERED to meet
+and confer regarding Defendant's request
+that Warden Heriberto Tellez directly
+address Defendant's concerns regarding
+the conditions of her detention. The
+parties shall jointly submit a status update
+within one week of this Order.
+SO ORDERED.
+EFTA02829678

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vision-joined/court-04/b1892fe9a03940836da445990b89404312945a4355deec1a06541abffc147665.md

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+Case 1:15-cv-07433-LAP Document 363
+Filed 08/11/16 Page 1 of 18
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Index No. 15 Civ. 7433 (RWS)
+Plaintiff,
+-against-
+GHISLAINE MAXWELL,
+DECLARATION OF
+ALAN M. DERSHOWITZ
+Defendant.
+ALAN M. DERSHOWITZ declares under penalty of perjury that the following
+is true and correct:
+I am a Professor of Law, Emeritus, at Harvard Law School, where I taught
+criminal law, legal ethics and other subjects for 50 years. As a criminal defense attorney, I have
+also represented numerous individuals accused of crimes over the course of my career. I am
+personally familiar with the facts set forth in this declaration.
+2.
+I submit this Declaration in support of my motion for permissive intervention
+under Federal Rule of Civil Procedure 24(b), and to unseal certain judicial documents, or
+alternatively to modify the stipulated Protective Order in this. The documents I am seeking
+relate directly to me. The plaintiff in this case,
+through her counsel
+and in publicly-filed declarations, has accused me of having sex with her and other young girls.
+The allegation is utterly false—a fabrication from start to finish but, because I am a
+well-known law professor and lawyer, it has been widely covered and repeated in the press, both
+here and around the world. See 11 13-14, 26-27, infra.
+1
+EFTA02800161
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 2 of 18
+In this application, I am seeking modest and narrowly tailored relief: an Order
+unsealing three documents that were filed with the Court in this case. Specifically, I seek to
+unseal
+In the
+alternative, I seek an Order lifting the stipulated Protective Order with respect to these three
+documents (the "Requested Documents"). |
+are attached hereto collectively as Exhibit
+A,
+is attached hereto as Exhibit B, and
+is attached hereto as
+Exhibit M. In accordance with the Protective Order, I am filing the Requested Documents under
+seal, and redacting all substantive references to them, pending disposition of this application.
+Although I have erred on the side of strict confidentiality to avoid any semblance of violating the
+Court's Protective Order, I of course do not believe that these materials should remain sealed
+permanently. In the event the Court grants my application, I would also request that the Court
+unseal the Requested Documents along with all of the references to them in my motion papers
+that are being redacted from the public docket.
+4.
+2
+EFTA02800162
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 3 of 18
+5.
+I have been a lawyer and law professor in the public eye for more than 50 years,
+and I have been happily married for 30 years. Even as I have taken on unpopular causes and
+asserted controversial positions, I have always enjoyed a deserved reputation for rectitude in my
+personal life. The false allegations lodged by|
+and her lawyers have sullied my
+reputation unfairly. At nearly 78 years of age, I am determined to restore my reputation
+My Representation of Jeffrey Epstein
+6.
+Jeffrey Epstein, a financier who was accused of soliciting sex workers and having
+inappropriate sexual conduct with underage girls, was a client of mine. I first was introduced to
+Mr. Epstein by a friend,
+Forester de Rothschild, in 1997. Over the years, I attended a
+number of academic events where he and many others—including distinguished academies,
+business people, and others
+-were present. At no time-either then or after I became his
+lawyer did I ever see Mr. Epstein in the presence of underage girls, nor was I aware of any
+allegation of improper sexual conduct on his part prior to being retained as one of his lawyers.
+Mr. Epstein retained me as a criminal defense lawyer towards the end of 2006. 1
+was hired as part of a team of lawyers that included Roy Black, Gerald Lefcourt, Kenneth Starr,
+Weinberg, and several others. In 2008, Mr. Epstein pleaded guilty to certain offenses
+involving sex with minors.
+8.
+, the plaintiff in this action, has alleged that she was one
+of Mr. Epstein's vietims.
+has claimed that she was held as a "sex slave" and
+trafficked by Mr. Epstein, and that a number of men associated with Mr. Epstein had sexual
+3
+EFTA02800163
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 4 of 18
+encounters with her that Mr. Epstein facilitated. Mr. Epstein's criminal conviction involved his
+conduct with respect to other girls; he was neither charged nor convicted in connection with his
+conduct toward
+9.
+Years after Mr. Epstein's guilty plea, as detailed below,
+falsely
+claimed that I was one of the men to whom Mr. Epstein trafficked her. The actions that
+attributes to me did not occur. Indeed, they could not have: my travel, work, and cell
+phone records, together with other documentary evidence, prove that I could not have been in
+locations in which she claims to have had sexual contact with me, including Little St. James,
+New Mexico, Mr. Epstein's home in Palm Beach, and Mr. Epstein's private jet. These records
+and other evidence prove that I was not at any of those locations during the years
+says she was with Mr. Epstein.
+2006-2011:
+Does Not Accuse Me of Sexual Misconduct In Her Initial Accounts
+10. The first time
+publicly accused me of sexual misconduct was in
+December 2014 by her own account, more than 12 years after her last encounter with Jeffrey
+Epstein. In the intervening period, of course, a number of important things happened:
+had sued Mr. Epstein; she had been paid to sell her story to the media; she had drafted
+and sought to publish a "tell-all" memoir'; and Mr. Epstein had been investigated by law
+enforcement, charged, and pled guilty to offenses related to sex with minors. I discuss these and
+related circumstances because they reflect on
+lack of credibility when it comes to
+her allegations against me, and on the need for me to have unencumbered access to and use of
+the Requested Documents as I seek to restore my personal and professional reputation.
+' See Richard Shears &
+, Prince Andrew's 'sex slave'
+"is writing a tell-all memoir
+about their alleged trysts at home of US billionaire Jeffrey Epstein, ' DAILYMAIL.COM, Jan. 6, 2015
+memoir.html.
+4
+EFTA02800164
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 5 of 18
+11. During the criminal investigation of Mr. Epstein, which spanned the years 2006
+through 2008,
+was interviewed by law enforcement and provided details about Mr.
+Epstein's alleged criminal acts. At the time, I was one of Mr. Epstein's lawyers.
+did
+not allege to law enforcement that I engaged in sexual misconduct of any sort. According to the
+Assistant United States Attorney in charge of negotiating Mr. Epstein's plea arrangement, while
+he was at the U.S. Attorney's Office,
+never mentioned me as having been involved
+in any sexual misconduct, much less suggested that she had been trafficked to me by Mr.
+Epstein. The Assistant United States Attorney told me and my lawyer that, had such an
+allegation been lodged, the Government would not have permitted me to continue to represent
+Jeffrey Epstein, nor would I have been ethically permitted to do so.
+12. In
+filed a civil suit against Mr. Epstein, in which she
+alleged that Mr. Epstein required that she "be sexually exploited by Defendant's adult male
+peers, including royalty, politicians, academicians, businessmen, and/or other professional and
+personal acquaintances." Again, the 2009 lawsuit did not mention me as an alleged perpetrator.
+See Ex. C (Complaint, Jane Doe No. 102 v. Epstein, No. 09-80656 (S.D. Fla.)).
+13. In or around early 2011, Sharon Churcher, a reporter for the British tabloid The
+Daily Mail, contacted
+and then traveled to Australia to meet with her in person.
+(These contacts, and the existence of emails between
+Churcher in 2011,
+were discussed and disclosed in documents publicly filed in this case, see, e.g., ECF Nos.
+216-218, as part of the motion to quash Ms. Churcher's deposition subpoena.) Ultimately, the
+Daily Mail published a series of stories, under Ms. Churcher's by-line, about
+involvement with Mr. Epstein. Nowhere did the Churcher stories allege that I had engaged in
+5
+EFTA02800165
+
+Case 1:15-cv-07433-LAP Document 363
+Filed 08/11/16 Page 6 of 18
+sexual misconduct. As far as the published stories reveal,
+any of the interviews as someone with whom she had had sex.
+14.
+never mentioned me in
+December 2014 Forward:
+and Her Lawyers Accuse Me
+15.
+first made accusations against me after she retained
+and Paul Cassell as her attorneys.
+16. In December 2014,
+represented by Messrs.
+and Cassell,
+filed a motion to join an action that had been initially filed in the United States Distriet Court for
+the Southern District of Florida in 2008 by one of Mr. Epstein's alleged victims, who was
+designated as "Jane Doe." Jane Doe #1 v. United States (Doe v. United States), No. 08-80736-
+CIV-MARRA (S.D. Fla.). That action (the "CVRA Action"), which was brought under the
+federal Crime Victims' Rights Act, sought to challenge federal prosecutors' handling of plea
+negotiations with Mr. Epstein.
+17.
+Between late 2014 and early 2015,
+attorneys-two of the same
+lawyers who represent her in this case
+-alleged in court filings that I had had sex with |
+on numerous occasions while she was a minor, including in Florida, on Mr. Epstein's
+private planes, in the British Virgin Islands, in New Mexico, and in New York. They did not
+offer to prove these allegations or offer me an opportunity to dispute them; they simply inserted
+6
+EFTA02800166
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 7 of 18
+them in the pleadings. While
+attorneys could have made the filings under seal (as
+much of the case file is sealed already), they elected to make the accusations against me part of
+the public record, intending, I believe, that they be widely reported.
+18.
+The allegations lodged against me were detailed, horrific, and utterly false. In
+two further court filings in the CVRA Action in or around early 2015,
+provided
+perjurious declarations alleging that I had sex with her at least six times while when she was
+between the ages of sixteen and nineteen. She alleged that the sex occurred in New Mexico,
+New York, on Little St. James Island, in Mr. Epstein's house in Palm Beach, and on a private
+plane. She also falsely alleged that I had sex with other underage girls. Finally,
+claimed that I was so comfortable with the sex that was going on that I would chat with Epstein
+while she was giving him oral sex. All of this is categorically false.?
+19. In April 2015, U.S. District Judge Kenneth A. Marra, the judge presiding over the
+CVRA Action, struck the allegations against me from
+filings under to Federal Rule
+of Civil Procedure 12(f). Judge Marra called the allegations against me "immaterial and
+impertinent," and characterized "striking the lurid details from Petitioners' submissions" as a
+"sanction." See Ex. D (Order Denying Petitioners' Motion to Join Under Rule 21 and Motion to
+Amend Under Rule 15, Apr. 7, 2015, Doe v. United States, ECF No. 324).
+20.
+Since she first accused me of sexual misconduct in her filings in the CVRA
+has stood by these accusations against me and repeated them numerous
+Action,
+times.
+" Even some of
+that her father did not start working at the club until well after her sixteenth birthday.
+7
+EFTA02800167
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 8 of 18
+2015-2016: The Defamation Case Brought by
+Lawyers Against Me
+21.
+Having been falsely accused, in public documents, of sexual misconduct, I
+publicly defended myself, including by asserting that the lawyers representing
+had
+not properly investigated her (false) allegations against me. In January 2015,
+attorneys—Mr.
+and Mr. Cassell, two of the same lawyers who are representing her in
+the case at bar-sued me for defamation in a case styled as
+v. Dershowitz, Case No.
+CACE 15-000072 (Cir. Ct., Broward Cnty., Fla.) The lawyers alleged that I had defamed them
+by publicly stating that it was improper and unethical for them, as officers of the court, to accuse
+me of sexual misconduct in public court filings without having appropriately investigated |
+allegations. I countersued, alleging that their claims about my supposed sexual
+encounters with
+were defamatory.
+22.
+During discovery in the
+v, Dershowitz case, I subpoenaed
+requesting that she produce, among other items, "[a]ll statements, written or recorded, which you
+have provided to anyone that reference by name, Alan M. Dershowitz." See Ex. E (Subpoena to
+Attend and Produce, Req. No. 7).
+objected to this request and refused to comply,
+ultimately moving to quash the subpoena. See Ex. F (Motion to Quash) at 7-9 & n.2. On
+November 4, 2015, the judge in
+v. Dershowitz granted certain aspects of |
+motion to quash, but otherwise denied it, including with respect to Request 7. See Ex. N (Email
+Concerning Court Orders,
+v. Dershowitz, Case No. CACE 15-000072 (Cir. Ct.,
+Broward Cnty., Fla.)), Nov. 4, 2015).
+8
+EFTA02800168
+
+Case 1:15-cv-07433-LAP Document 363
+Filed 08/11/16 Page 9 of 18
+23.
+24.
+In April 2016, I settled the defamation lawsuit with Mr. Cassell and Mr.
+Pursuant to the settlement agreement, the parties released a joint statement in which Messrs.
+Cassell and
+admitted that it was a mistake to accuse me of sexual misconduct in their
+filings in the CVRA Action and withdrew those allegations. See Ex. H at 3 (Joint Statement).
+25. Also in April 2016, I released the results of a thorough investigation led by former
+FBI Director and federal judge Louis Freeh, which found that "the totality of the evidence"
+"refutes the allegations made against" me byl
+_. See Ex. I (Freeh Statement).
+EFTA02800169
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 10 of 18
+and Her Lawyers "Stand By" Her False Allegations Against Me - Even After
+the Settlement of
+v. Dershowitz
+26.
+Despite the settlement in the defamation case, Judge Marra's order striking the
+allegations in the CVRA Action, and the results of Judge Freeh's investigation,
+and
+her counsel have republished
+allegations against me. On April 8, 2016, just after
+the settlement of the
+case, Mr. Cassell and Mr.
+made a court filing that stated
+that
+"reaffirms" her allegations against me, and that their mistake in filing those
+allegations in the CVRA Action was merely "tactical." See Ex. J (Notice of Withdrawal). David
+Boies, another of
+attorneys in this case, was described as saying that
+"stands by her allegations" against me. See
+• Alan Dershowitz Extends Truce
+Offer to David Boies Amid Bitter Feud, BLOOMBERG LAW (Apr. 11, 2016),
+https://bol.bna.com/alan-dershowitz-extends-truce-offer-to-david-boies-amid-bitter-feud/.
+Reckless statements like these—which falsely imply that I am guilty of sexual misconduct-are
+highly injurious to my reputation, especially when they come from otherwise-credible lawyers. S
+27. The claim that I engaged in sexual misconduct with
+has also
+continued to receive attention in the press, despite the settlement and the joint statement released
+as a result thereof. See Ex. K (Compendium of News Stories). I am aware of at least two books
+that have been or will soon be published that discuss the allegations against me; one of these
+books, advertised in a press release just this week as "expos[ing] one of the most sordid human
+rights violation stories in the history of the United States," is being marketed as following "lo]n
+the heels of the sensational Alan Dershowitz defamation settlement case." Press Release,
+"TrafficKing":
+Human Trafficking Book Is Now Available, NEWSWIRE.COM,
+I have compiled records of my whereabouts for the years in question, and these records show that I could not have
+been in the places that
+alleges I was at the times she alleges.
+10
+EFTA02800170
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 11 of 18
+Aug. 9, 2016, https://www.newswire.com/news/conchita-sarnoffs-book-trafficking-is-now-
+available-1384303. See also Richard
+, Epstein Sex Scandal Book Clears Bill Clinton,
+Page Six, Dec. 1, 2015, http://pagesix.com/2015/12/01/epstein-sex-scandal-book-clears-bill-
+clinton/ (discussing a book about "the Jeffrey Epstein sex slavery scandal [that] will be published
+with the help of best-selling author James Patterson" and referring to "allegations that
+Dershowitz had sex with
+). And I have learned that following the filing of the false
+accusations against me
+sat for an interview with ABC News, as part of her efforts to
+increase public interest in (and the commercial value of) her "story." The interview was
+announced on social media by an organization with which Mr.
+is associated and was
+said to be slated to appear on ABC's Good Morning America, World News Tonight, and
+Nightline programs. While the ABC News interview has not yet run, there is no assurance that it
+will not run in the future. Moreover,
+willingness to sit for press interviews
+undermines any suggestion she might make that she has an ongoing interest in keeping her
+allegations of sexual abuse private.
+This Case, My Involvement as a Witness, and My Discovery of Exculpatory Materials
+28.
+As the Court knows, in 2015,
+• filed this action against Ghislaine
+Maxwell, a friend of Jeffrey Epstein. The suit alleges that Ms. Maxwell defamed
+by
+denying that she, Ms. Maxwell, facilitated the trafficking of
+and other girls and
+young women.
+29.
+In or about May 2016, I was named as a witness in this case by both plaintiff and
+defendant.
+EFTA02800171
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 12 of 18
+30.
+Thereafter, I was contacted by defense counsel Ms. Laura Menninger, who said
+that she wanted me to testify. Ms. Menninger informed me that a stipulated Protective Order
+(the "Protective Order") had been entered in this case, see Ex. L, under which discovery
+materials could be designated by either party as "confidential." She asked me to read the
+Protective Order and to agree in writing to abide by its terms, which I did. The Protective Order
+allows documents that were produced in discovery and that have been designated "confidential"
+to be shown to potential witnesses.
+31.
+To the best of my knowledge, the Protective Order is a "blanket" confidentiality
+agreement that has been so-ordered by this Court. Accordingly, it is likely that the documents
+designated as "confidential" under the Protective Order have not been individually scrutinized by
+this Court to determine whether the designation is proper and/or that they are truly entitled to
+confidential treatment under the law in this Circuit.
+32.
+33.
+12
+EFTA02800172
+
+Case 1:15-cv-07433-LAP Document 363
+Filed 08/11/16 Page 13 of 18
+35.
+36.
+37.
+13
+EFTA02800173
+
+Case 1:15-cv-07433-LAP Document 363
+Filed 08/11/16 Page 14 of 18
+38.
+14
+EFTA02800174
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 15 of 18
+41.
+Need for Public Access
+42.
+The Requested Documents I am seeking by this application are
+43.
+a.
+15
+EFTA02800175
+
+Case 1:15-cv-07433-LAP Document 363
+Filed 08/11/16 Page 16 of 18
+c.
+d.
+16
+EFTA02800176
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 17 of 18
+f.
+44.
+45.
+has long been a willing and active participant in the publication and
+dissemination of her accusations. Indeed, according to documents publicly filed in the
+case, she sold her story to the press for $160,000 in 2011. As relates to me,
+launched her continuing campaign of public character assassination by publicly filing false
+allegations of sexual abuse against me, knowing and intending, I believe, that they would be
+widely reported in the press. Most recently, she granted an interview to ABC News with the
+intent that it be broadcast on national television.
+sealing presumptively public court filings would be a perverse
+mockery of the judicial system, the First Amendment, and fundamental fairness.
+46. These materials are also essential to my defense against a motion to sanction me
+brought against me
+via her lawyers at Boies Schiller & Flexner LLP, in connection
+with the
+case. In that motion,
+and her lawyers argue that I should be
+sanctioned for submitting an affidavit and testifying (truthfully) about exculpatory comments
+made to me by David Boies. After the parties in
+reached a settlement,
+and
+her lawyers insisted on pressing their sanctions motion against me. The motion was denied by
+the trial judge, but
+and her counsel have noticed and are pursuing an appeal.
+17
+EFTA02800177
+
+Case 1:15-cv-07433-LAP Document 363 Filed 08/11/16 Page 18 of 18
+47. Because
+and her lawyers continue to publicly stand by
+allegations with regard to the accusations against me, I am entitled, under the First Amendment
+and the common law, to access the Requested Documents
+Dated: August 11, 2016
+Chilmark, Massachusetts
+ALAN M. DERSHOWITZ
+EFTA02800178

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vision-joined/court-04/b18993d596bf854caffa72501943cb8d17fbea2b05175b707ce1213944f82957.md

@@ -0,0 +1,398 @@
+Case 1:15-cv-07433-LAP Document 200-1 Filed 06/10/16 Page 1 of 11
+EXHIBIT 1
+EFTA02798079
+
+Case 1:15-cv-07433-LAP
+Document 200-1
+Filed 06/10/16 Page 2 of 11
+AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+Plaintiff
+V.
+Ghislaine Maxwell
+Civil Action No. 15-CV-07433-RWS
+Defendant
+SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
+To:
+RINALDO RIZZO
+c/o Robert Y. 1 l
+, Freeman Is LLP, 228 E. 45th Street, 17th Floor, New York, NY 10017 (212) 980-4050
+(Name of person to whom this subpoena is directed)
+• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
+deposition to be taken in this civil action. If you are an organization, you must designate one or more officers, directors,
+or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or
+those set forth in an attachment:
+PLEASE SEE ATTACHED EXHIBIT A.
+Place:
+Boies Schiller & Flexner LLP
+Date and Time:
+333 Main Street Armonk, NY 10504
+05/13/2016 9:00 am
+(954) 356-0011
+The deposition will be recorded by this method: Videography and Stenography
+• Production: You, or your representatives, must also bring with you to the deposition the following documents,
+electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the
+material:
+The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance;
+Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
+respond to this subpoena and the potential consequences of not doing so.
+Date:
+04/11/2016
+CLERK OF COURT
+OR
+Signature of Clerk or Deputy Clerk
+Attorney's signature
+The name, address, e-mail address, and telephone number of the attorney representing (name of party)
+, who issues or requests this subpoena, are:
+Sigrid S. McCawley, BSF, LLP, 401 E. Las Olas Blvd., #1200, Ft. Lauderdale, FL, 33301; 954-356-0011;
+smccawley@bsfllp.com
+Notice to the person who issues or requests this subpoen:
+if this subpoena commands the production of documents, electronically stored information, or tangible things, a notic
+and a copy of the subpoena must be served on each party in this case before it is served on the person to whom it is
+directed. Fed. R. Civ. P. 45(a)(4).
+EFTA02798080
+
+Case 1:15-cv-07433-LAP Document 200-1
+Filed 06/10/16 Page 3 of 11
+AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action (Page 2)
+Civil Action No. 15-CV-07433-RWS
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ, P. 45.)
+I received this subpoena for (name of individual and title, if any)
+On (date)
+• I served the subpoena by delivering a copy to the named individual as follows:
+on (date)
+; ог
+• I returned the subpoena unexecuted because:
+Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
+tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of
+$
+My fees are $
+for travel and S
+for services, for a total of S
+0.00
+I declare under penalty of perjury that this information is true.
+Date:
+Server's signature
+Printed name and title
+Server's address
+Additional information regarding attempted service, etc.:
+EFTA02798081
+
+Case 1:15-cv-07433-LAP Document 200-1
+Filed 06/10/16 Page 4 of 11
+AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action (Page 3)
+Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
+(c) Place of Compliance.
+(1) For a Trial, Hearing, or Deposition. A subpoena may command a
+person to attend a trial, hearing, or deposition only as follows:
+(A) within 100 miles of where the person resides, is employed, or
+regularly transacts business in person; or
+(i) disclosing a trade secret or other confidential rescarch, development,
+or commercial information: or
+(ii) disclosing an unretained expert's opinion or information that does
+not describe specifie occurrences in dispute and results from the expert's
+study that was not requested by a party.
+(C) Specifying Conditions as an Alternative. In the circumstances
+described in Rule 45(d)(3)(B), the court may, instead of quashing or
+transacts business in person, if the person
+(i) is a party or a party's officer, or
+(il) is commanded to attend a trial and would not incur substantial
+expense.
+(2) For Other Discovery: A subpoena may command:
+(A) production of documents, electronically stored information, or
+tangible things at a place within 100 miles of where the person resides, is
+employed, or regularly transacts business in person; and
+(B) inspection of premises at the premises to be inspected.
+(d) Protecting a Person Subject to a Subpoena; Enforcement.
+(1) Aroiding Undue Burden or Expense; Sanctions. A party or attorney
+responsible for issuing and serving a subpoena must take reasonable steps
+to avoid imposing undue burden or expense on a person subject to the
+subpoena. The court for the district where compliance is required must
+enforce this duty and impose an appropriate sanction---which may include
+lost earings and reasonable attorney's fees—on a party or attorney who
+fails to comply.
+(2) Command to Produce Materials or Permit Inspection.
+(A) Appearance Not Required A person commanded to produce
+documents, clectronically stored information, or tangible things, or to
+permit the inspection of premises, need not appear in person at the place of
+production or inspection unless also commanded to appear for a deposition,
+hearing, or trial.
+(B) Objections. A person commanded to produce documents or tangible
+things or to permit inspection may serve on the party or attorney designated
+in the subpoena a written objection to inspecting, copying, testing, or
+sampling any or all of the materials or to inspecting the premises—or to
+producing electronically stored information in the form or forms requested.
+The objection must be served before the carlier of the time specified for
+compliance or 14 days afler the subpoena is served. If an objoction is made,
+the following rules apply:
+(l) At any time, on notice to the commanded person, the serving party
+may move the court for the district where compliance is required for an
+order compelling production or inspection.
+nodifying a subpoena, order appearance or production under specifier
+onditions if the serving party
+(i) shows a substantial need for the testimony or material that cannot be
+otherwise met without undue hardship; and
+(ii) ensures that the subpoenaed person will be reasonably compensated.
+(c) Duties in Responding to a Subpoena.
+(I) Producing Documents or Electronically Stored Information. These
+procedures apply to producing documents or electronically stored
+infonnation:
+(A) Documents. A person responding to a subpoena to produce documents
+must produce them as they are kept in the ordinary course of business or
+must organize and label them to correspond to the categories in the demand.
+(B) Form for Producing Electronically Stored Information Not Specified.
+If a subpoena does not specify a form for producing electronically stored
+information, the person responding must produce it in a form or forms in
+which it is ordinarily maintained or in a reasonably usable form or forms.
+(C) Electronically Stored Information Produced in Only One Form. The
+person responding need not produce the same electronically stored
+information in more than one form.
+(D) Inaccessible Electronically Stored Information. The person
+responding need not provide discovery of electronically stored information
+from sources that the person identifies as not reasonably acoessible because
+of undue burden or cost. On motion to compel discovery or for a protective
+order, the person responding must show that the information is not
+reasonably accessible because of undue burden or cost. If that showing is
+made, the court may nonetheless order discovery from such sources if the
+requesting party shows good cause, considering the limitations of Rule
+26(by(2)(C). The court may specify conditions for the discovery.
+significant expense resulting from compliance.
+(3) Quashing or Modifying a Subpoena.
+(A) When Required On timely motion, the court for the district where
+compliance is required must quash or modify a subpoena that:
+(i) fails to allow a reasonuble time to comply;
+(il) requires a person to comply beyond the geographical limit:
+pecified in Rule 45(c);
+(B) When Permitted. To protect a person subject to or affected by a
+subpoena, the court for the district where compliance is required may, or
+motion, quash or modify the subpoena if it requires:
+(2) Claiming Privilege or Protection.
+(A) Information Withheld, A person withholding subpoenaed information
+under a claim that it is privileged or subject to protection as trial-preparation
+material must:
+(1) expressly make the claim; and
+(ii) describe the nature of the withheld documents, communications, or
+tangible things in a manner that, without revealing information itself
+privileged or protected, will enable the parties to assess the claim.
+(B) Information Produced If information produced in response to a
+subpoena is subject to a claim of privilege or of protection as
+trial-preparation material, the person making the claim may notify any party
+that received the information of the claim and the basis for it. After being
+notified, a party must promptly return, sequester, or destroy the specified
+information and any copies it has; must not use or disclose the information
+until the claim is resolved; must take reasonable steps to retrieve the
+information if the party disclosed it before being notified; and may promptly
+present the information under seal to the court for the district where
+compliance is required for a determination of the claim. The person who
+produced the information must preserve the information until the claim is
+resolved.
+(g) Contempt.
+The court for the district where compliance is required--and also, after a
+motion is transferred, the issuing court---may hold in contempt a person
+who, having been served, fails without adequate excuse to obey the
+subpoena or an order related to it.
+For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
+EFTA02798082
+
+Case 1:15-cv-07433-LAP
+Document 200-1
+Filed 06/10/16 Page 5 of 11
+To: Rinaldo Rizzo
+EXHIBIT A
+DEFINITIONS
+Wherever they hereafter appear the following words and phrases have the following
+meanings:
+1.
+another.
+"Agent" shall mean any agent, employee, officer, director, attorney, independent
+contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
+"Correspondence" or "communication" shall mean all written or verbal
+communications, by any and all methods, including without limitation, letters, memoranda,
+and/or electronic mail, by which information, in whatever form, is stored, transmitted or
+received; and, includes every manner or means of disclosure, transfer or exchange, and every
+disclosure, transfer or exchange of information whether orally or by document or otherwise,
+face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
+message, mail, personal delivery or otherwise.
+"Defendant" shall mean the defendant Ghislaine Maxwell and her employees,
+representatives or agents.
+4.
+"Document" incorporates the definition as set forth in Rule 26.3(c)(2), Southern
+District of New York Local Rules, and, therefore, is defined to be synonymous in meaning and
+equal in scope to the usage of the term "documents or electronically stored information in Fed.
+R. Civ. P. 34(a)(1)(A). A draft or non-identical copy is a separate document within the meaning
+of this term.
+5.
+"Employee" includes a past or present officer, director, agent or servant, including
+any attorney (associate or partner) or paralegal.
+6.
+"Including" means including without limitations.
+2
+EFTA02798083
+
+Case 1:15-cv-07433-LAP k
+Document 200-1
+Filed 06/10/16 Page 6 of 11
+To: Rinaldo Rizzo
+"Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
+Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein.
+8.
+"Ghislaine Maxwell" includes Ghislaine Maxwell and any entities owned or
+controlled by Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of
+Ghislaine Maxwell.
+"Person(s)" includes natural persons, proprietorships, governmental agencies,
+corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other
+legal or business entity.
+10.
+"You" or "Your" hereinafter means Rinaldo Rizzo and any employee, agent,
+attorney, consultant, related entities or other representative of Rinaldo Rizzo.
+INSTRUCTIONS
+Unless indicated otherwise, the "Relevant Period" for this Request is from 1999
+to the present. A Document should be considered to be within the relevant time frame if it refers
+or relates to communications, meetings or other events or documents that occurred or were
+created within that time frame, regardless of the date of creation of the responsive Document.
+2.
+This Request calls for the production of all responsive Documents in Your
+possession, custody or control without regard to the physical location of such documents.
+3.
+If any Document requested was in any defendant's possession or control, but is no
+longer in its possession or control, state what disposition was made of said Document, the reason
+for such disposition, and the date of such disposition.
+For the purposes of reading, interpreting, or construing the scope of these
+requests, the terms used shall be given their most expansive and inclusive interpretation. This
+includes, without limitation the following:
+3
+EFTA02798084
+
+Case 1:15-cv-07433-LAP Document 200-1 Filed 06/10/16 Page 7 of 11
+To: Rinaldo Rizzo
+a)
+b)
+e)
+Wherever appropriate herein, the singular form of a word shall be
+interpreted as plural and vice versa.
+"And" as well as "or" shall be construed either disjunctively or
+conjunctively as necessary to bring within the scope hereof any
+information (as defined herein) which might otherwise be construed to be
+outside the scope of this discovery request.
+"Any" shall be understood to include and encompass "all" and vice versa.
+Wherever appropriate herein, the masculine form of a word shall be
+interpreted as feminine and vice versa.
+"Including" shall mean "including without limitation."
+If You are unable to answer or respond fully to any document request, answer or
+respond to the extent possible and specify the reasons for Your inability to answer or respond in
+full. If the recipient has no documents responsive to a particular Request, the recipient shall so
+state.
+6. Unless instructed otherwise, each Request shall be construed independently and
+not by reference to any other Request for the purpose of limitation.
+7. The words "concern," "concerning," "concerns," or any other derivative thereof,
+as used herein is defined as meaning relating to, referring to, describing, evidencing or
+constituting, under Rule 26.3(c)(7), Southern District of New York Local Civil Rules.
+"Identify" (with respect to persons) incorporates the definition as set forth in Rule
+26.3(c)(3), Southern District of New York Local Rules. Therefore, when referring to a person,
+"to identify" means to give, to the extent known, the person's full name, present or last known
+address, and when referring to a natural person, additionally, the present or last known place of
+employment.
+Identify (with respect to documents) incorporates the definition as set forth in
+Rule 26.3(c)(4), Southern District of New York Local Rules. Therefore, when referring to
+4
+EFTA02798085
+
+Case 1:15-cv-07433-LAP Document 200-1 Filed 06/10/16 Page 8 of 11
+To: Rinaldo Rizzo
+documents "to identify" means to give, to the extent known, the (i) type of documents, (ii)
+general subject matter; (iii) date of the documents; and (iv) author(s), addressee(s) and
+recipients). In the alternative, the responding party may produce the documents, together with
+identifying information sufficient to satisfy Fed. R. Civ. P. 33(d).
+10.
+In producing Documents, if the original of any Document cannot be located, a
+copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same
+manner as the original.
+11. Any copy of a Document that is not identical shall be considered a separate
+document.
+12.
+If any requested Document cannot be produced in full, produce the Document to
+the extent possible, specifying each reason for Your inability to produce the remainder of the
+Document stating whatever information, knowledge or belief which You have concerning the
+portion not produced.
+13.
+If any Document requested was at any one time in existence but are no longer in
+existence, then so state, specifying for each Document (a) the type of document; (b) the types of
+information contained thereon; (c) the date upon which it ceased to exist; (d) the circumstances
+under which it ceased to exist; (e) the identity of all person having knowledge of the
+circumstances under which it ceased to exist; and (f) the identity of all persons having
+knowledge or who had knowledge of the contents thereof and each individual's address.
+14.
+All Documents shall be produced in the same order as they are kept or maintained
+by You in the ordinary course of business.
+15.
+You are requested to produce all drafts and notes, whether typed, handwritten or
+otherwise, made or prepared in connection with the requested Documents, whether or not used.
+5
+EFTA02798086
+
+Case 1:15-cv-07433-LAP Document 200-1 Filed 06/10/16 Page 9 of 11
+To: Rinaldo Rizzo
+16. Documents attached to cach other shall not be separated.
+17. Documents shall be produced in such fashion as to identify the department,
+branch or office in whose possession they were located and, where applicable, the natural person
+in whose possession they were found, and business address of each Document's custodian(s).
+18.
+If any Document responsive to the request is withheld, in all or part, based upon
+any claim of privilege or protection, whether based on statute or otherwise, state separately for
+each Document, in addition to any other information requested: (a) the specific request which
+calls for the production; (b) the nature of the privilege claimed; (c) its date; (d) the name and
+address of each author; (e) the name and address of each of the addresses and/or individual to
+whom the Document was distributed, if any; (f) the title (or position) of its author; (g) type of
+tangible object, e.g., letter, memorandum, telegram, chart, report, recording, disk, etc.; (h) its title
+and subject matter (without revealing the information as to which the privilege is claimed); (i)
+with sufficient specificity to permit the Court to make full determination as to whether the claim
+of privilege is valid, each and every fact or basis on which You claim such privilege; and (i)
+whether the document contained an attachment and to the extent You are claiming a privilege as
+to the attachment, a separate log entry addressing that privilege claim.
+19.
+If any Document requested herein is withheld, in all or part, based on a claim that
+such Document constitutes attorney work product, provide all of the information described in
+Instruction No. 18 and also identify the litigation in connection with which the Document and the
+information it contains was obtained and/or prepared.
+20.
+Plaintiff does not seek and does not require the production of multiple copies of
+identical Documents.
+6
+EFTA02798087
+
+Case 1:15-cv-07433-LAP Document 200-1 Filed 06/10/16 Page 10 of 11
+To: Rinaldo Rizzo
+21.
+This Request is deemed to be continuing. If, after producing these Documents,
+You obtain or become aware of any further information, Documents, things, or information
+responsive to this Request, You are required to so state by supplementing Your responses and
+producing such additional Documents to Plaintiff.
+7
+EFTA02798088
+
+Case 1:15-cv-07433-LAP Document 200-1 Filed 06/10/16 Page 11 of 11
+To: Rinaldo Rizzo
+DOCUMENTS TO BE PRODUCED PURSUANT TO THIS SUBPOENA
+2.
+3.
+All documents concerning Jeffrey Epstein from 1999 - present.
+All documents concerning Ghislaine Maxwell from 1999 - present.
+All documents concerning or describing any work you performed with Jeffrey
+Epstein, Ghislaine Maxwell, or any affiliated entity from 1999 - present.
+All video tapes, audio tapes, photographs or any other print or electronic media
+concerning Jeffrey Epstein or Ghislaine Maxwell.
+All documents concerning calendars, schedules or appointments for you from
+1999 - present that relate to visits with, or communications with, either Jeffrey Epstein or
+Ghislaine Maxwell.
+interacted with Jeffrey Epstein.
+interacted with Ghislaine Maxwell.
+6. All documents concerning any females that you know who provided massages or
+All documents concerning any females that you know who provided massages or
+All documents concerning Jeffrey Epstein or Ghislaine Maxwell's interactions
+8.
+with females.
+8
+EFTA02798089

vision-joined/court-04/b18cb172c189c2a499ecf88a7b23ae0ac18baac0895e6672ba86821908bd5a4b.json

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+}

vision-joined/court-04/b18cb172c189c2a499ecf88a7b23ae0ac18baac0895e6672ba86821908bd5a4b.md

@@ -0,0 +1,127 @@
+Case 1:15-cv-07433-LAP Document 539
+Filed 01/06/17 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+Declaration of Laura A. Menninger in Support of'
+Defendant's Motion For Summary Judgment
+1, Laura A. Menninger, declare as follows:
+1. 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 in this action. I respectfully submit this Declaration in support of
+Ms. Maxwell's Motion for Summary Judgment.'
+2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher
+entitled "Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,"
+DAILY MAIL, dated March 2, 2011.
+• At trial, defendant intends to produce either the custodian of record relevant to any
+disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902.
+ee Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition
+locuments herein were either produced by plaintiff or obtained with releases signed by plaintifi
+EFTA02801609
+
+Case 1:15-cv-07433-LAP Document 539 Filed 01/06/17 Page 2 of 7
+3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher
+entitled "Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill
+Clinton," DAILY MaIl, dated March 5, 2011.
+4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms.
+Maxwell dated March 9, 2011.
+5. Attached as Exhibit D (filed under seal)
+6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join
+Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marral
+(S.D. Fla. Apr. 7, 2016).
+7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms.
+Maxwell dated January 2, 2015.
+8. Attached as Exhibit G (filed under seal) I
+9. Attached as Exhibit H (filed under seal) |
+10. Attached as Exhibit I (filed under seal) I
+2
+EFTA02801610
+
+Case 1:15-cv-07433-LAP Document 539 Filed 01/06/17 Page 3 of 7
+11. Attached as Exhibit J (filed under seal)
+12. Attached as Exhibit K (filed under seal)
+13. Attached as Exhibit L (filed under seal)
+14. Attached as Exhibit M (filed under seal) [
+15. Attached as Exhibit N (filed under seal) [
+16. Attached as Exhibit O (filed under seal) |
+17. Attached as Exhibit P (filed under seal) |
+18.
+Attached as Exhibit Q (filed under seal)
+3
+EFTA02801611
+
+Case 1:15-cv-07433-LAP Document 539
+Filed 01/06/17 Page 4 of 7
+19. Attached as Exhibit R (filed under seal)
+20. Attached as Exhibit S (filed under seal)
+21. Attached as Exhibit T (filed under seal)
+22. Attached as Exhibit U (filed under seal) |
+23. Attached as Exhibit V (filed under seal) |
+24. Attached as Exhibit W (filed under seal) [
+25. Attached as Exhibit (filed under seal)
+26. Attached as Exhibit Y (filed under seal) |
+27. Attached as Exhibit Z (filed under seal)
+4
+EFTA02801612
+
+Case 1:15-cv-07433-LAP Document 539 Filed 01/06/17 Page 5 of 7
+28. Attached as Exhibit AA (filed under seal)
+29. Attached as Exhibit BB (filed under seal)
+30. Attached as Exhibit CC (filed under seal)
+31. Exhibit DD left intentionally blank.
+32. Attached as Exhibit EE (filed under seal) |
+33. Attached as Exhibit FF (filed under seal [
+34. Attached as Exhibit GG (filed under seal)
+35. Attached as Exhibit HH (filed under seal)
+36. Attached as Exhibit II (filed under seal)
+5
+EFTA02801613
+
+Case 1:15-cv-07433-LAP Document 539 Filed 01/06/17 Page 6 of 7
+37. Attached as Exhibit JJ (filed under seal) |
+38. Attached as Exhibit KK (filed under seal)
+39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc.
+Articles of Incorporation dated December 23, 2014, GIUFFRE001064-5.
+40. Attached as Exhibit MM (filed under seal)
+I declare under penalty of perjury that the foregoing is true and correct.
+Executed on January 6, 2017.
+s/ Laura A. Menninger
+Laura A. Menninger
+6
+EFTA02801614
+
+Case 1:15-cv-07433-LAP Document 539 Filed 01/06/17 Page 7 of 7
+CERTIFICATE OF SERVICE
+certify that on January o. 201
+certify that on anuary 6, 2017, I electronically served this Declarion flour A. Menning
+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
+1. JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L..
+425 North Andrews Ave.., Ste. 2
+Ft. Lauderdale, FL 33301
+brad@pathtojustice.com
+/s/ Nicole
+Nicole
+7
+EFTA02801615

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+}

vision-joined/court-04/b1920173c99bf1bca5a07c59615231ba4eb35f4ceda3fb8e2d2915d88af2a09f.md

@@ -0,0 +1,79 @@
+Case 1:15-cv-07433-LAP Document 631 Filed 02/17/17 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+--X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+:
+------
+DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN
+TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR USE AT TRIAL
+Laura A. Menninger
+Jeffrey S. Pagliuca
+Ty Gee
+HADDON,
+150 East 10" Avenue
+Denver, CO 80203
+303.831.7364
+AND
+P.C.
+EFTA02802196
+
+Case 1:15-cv-07433-LAP Document 631 Filed 02/17/17 Page 2 of 4
+PAGES 1-7
+REDACTED
+EFTA02802197
+
+Case 1:15-cv-07433-LAP Document 631 Filed 02/17/17 Page 3 of 4
+CONCLUSION
+For the forgoing reasons, and those set forth in the Defendant's Motion In Limine To
+Exclude In Toto Certain Depositions Designated By Plaintiff For Use At Trial, Ms. Maxwell
+requests that the relief requested therein be granted
+Dated: February 17, 2017
+Respectfully submitted,
+Is/ 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.
+EFTA02802198
+
+Case 1:15-cv-07433-LAP Document 631 Filed 02/17/17 Page 4 of 4
+CERTIFICATE OF SERVICE
+I certify that on February 17, 2017, I electronically served this Defendant's Reply In
+Support Of Motion In Limine To Exclude In Toto Certain Depositions Designated By Plaintiff
+For Use At Trial 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
+Sour 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
+/s/ Nicole
+Nicole |
+EFTA02802199

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vision-joined/court-04/b1976178d01e31392dff05887a3fe19e8da26248fd9d70b0d4705e7d7be59614.md

@@ -0,0 +1,82 @@
+JUN-06-2016 98A b6:5gYP7A330 ABREMRocument 197
+FF*9806933201age 1 of 2
+P. 06
+HADDON
+FOREMAN
+RECORDERE
+ind Foreman, P.
+laddea sang burg a. Menninger
+JUN 0 72016
+L50 East 1pIn Avenue
+Denver, Colorado 80203
+JUDGE SWEET CHAMBER 303.832.2628
+www.hmflaw.con
+menninger@nmflaw.com
+June 6, 2016
+Via Facsimile (212) 805-7925
+Hon. Robert W. Sweet
+Uniled States District Judge
+United States District Court
+Daniel
+Moynihan Courthouse
+Southern District of New York
+500 Pearl Street, Room 1940
+New York, New York 10007-1312
+Re:
+Dear Judge Sweet:
+USDC SDNY
+DOCUMENT
+ELECTRONICAL! FILED
+DOC#:
+BATE FILED: 61716
+y. Maxwell, 15-cv-07433-RWS
+This is a letter motion to file Ms. Maxwell's exhibit A to the Declaration In
+Support of Defendant's Response in Opposition to Motion to Exceed Presumptive
+Ten Deposition Limit under seal pursuant to this Court's Protective Order (Doc. #
+62).
+The Protective Order states:
+Whenever a party seeks to file any document or material containing
+CONFIDENTIAT. INFORMATION with the Court in this matter, it shall be
+accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic
+Case Filing Rules & Instructions for the Southern District of New York.
+See Protective Order (Doc. # 62) signed on March 17, 2016, at p.4. The deposition
+has been designated as Confidential.
+Ms. Maxwell requests permission to file the Confidential information under seal.
+Sincerely,
+Soozenatesa, i
+67-16
+AND FOREMAN, P.C.
+EFTA02798069
+
+U 2016 i di% 73i hemlocument 197 is 51831401 Page 2012
+P. 07
+Hon. Robert W. Sweet
+June 6, 2016
+Page 2
+/s/ Laura A. Menninger
+Laura A. Menninger
+CERTIFICATE OF SERVICE
+I certify that on June 6, 2016, I electronically served this LETTER MOTION
+via ELECTRONIC MAIL on the following:
+Sigrid S. MoCawley
+Meridith
+BOlES, SCHILLER & FLExNEr, LL.P
+401 East Las Olas Boulevard, Ste. 1200
+Ft. Lauderdale, FL 33301
+smccawley@bsfllp.com
+Paul G. Cassell
+S.J. Quinney College of Law, University of
+Utah
+383 S. University Street
+Salt Lake City, UT 84112
+cassellp@law.utah.edu
+mschultz@bsfllp.com
+J. Stanley Pottinger
+JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L.
+425 North Andrews Ave., Ste. 2
+Ft. Lauderdale. FL 33301
+brad@pathtojustice.com
+/s/ Nicole
+Nicole
+EFTA02798070

vision-joined/court-04/b1b3a1714def949accdaa8708f478336ac46c351ad42a0d4280f655bc1c84428.json

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+  "sha": "b1b3a1714def949accdaa8708f478336ac46c351ad42a0d4280f655bc1c84428"
+}

vision-joined/court-04/b1b3a1714def949accdaa8708f478336ac46c351ad42a0d4280f655bc1c84428.md

@@ -0,0 +1,185 @@
+Case 1:15-cv-07433-LAP Document 353
+Filed 08/10/16 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+--X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+:
+------X
+Motion to Strike Plaintiff's Supplement to Motion for
+Adverse Inference Instruction Based on New Information
+Laura A. Menninger
+Jeffrey S. Pagliuca
+HADDON,
+East 10" Avenue
+Denver, CO 80203
+303.831.7364
+, AND
+. P.C.
+EFTA02799922
+
+Case 1:15-cv-07433-LAP Document 353 Filed 08/10/16 Page 2 of 7
+On July 22, 2016 this Court Ordered the parties to submit proposed search terms to the
+Court and any briefing related to Plaintiff's Motion for an Adverse Inference Instruction, DE-
+279, and the briefing schedule set forth in the Court's Order, DE-287, was adjourned. See, DE-
+301.
+In direct contravention to the Court's Order, on August 8, 2016, Plaintiff filed a
+document captioned "Plaintiff's Supplement to Motion for Adverse Inference Instruction Based
+on New Information". DE-338 . The motion is neither a "supplement" nor "based on new
+information," but rather a rehashing of issues previously litigated, repetitive and misleading
+arguments, and new, highly speculative arguments that are not based in fact. Plaintiff claims that
+Ms. Maxwell is withholding information when she is not and engages in ad hominin, scurrilous
+attacks on Ms. Maxwell and her lawyers. The document should be stricken because it violates
+the Court's Order of July 22, 2016; it violates basic rules of pleading, and is not a supplement to
+anything.
+A. The Pleading Violates the Court's Order
+There was nothing unclear about the Court's July 22, 2016 order which adjourned the
+briefing schedule on the Plaintiff's motion for an adverse inference instruction as directed by the
+Court: "A briefing schedule and submission date will be set after search terms are determined."
+The Plaintiff, without the permission of the Court, has simply attempted to again additional
+briefing on a subject. To prevent a free-for-all motion practice in which the parties can violate
+Orders and the basic rules of civil procedure, the "Supplement" and related documents should be
+stricken.
+B.
+The Pleading is Not a Supplement
+The Federal Rules of Civil Procedure do not define a "supplement" or "supplemental
+authority" outside of the context of a "pleading," which is defined in Rule 7(a). A motion is not
+1
+EFTA02799923
+
+Case 1:15-cv-07433-LAP Document 353 Filed 08/10/16 Page 3 of 7
+a pleading. See, Advisory Committee Note 1 to F.R.C.P. 7. A pleading may only be
+supplemented by leave of Court. Fed. R. Civ. P. 15(d). The Rules of Civil Procedure contain no
+authority for the filing of a supplement to a motion. See, F.R.C.P. 7(b).
+Rule 28() of the Federal Rules of Appellate Procedure allows parties to provide
+"pertinent and significant" supplemental authorities during an appeal where the "pertinent and
+significant" authorities came to the party's attention after the brief was filed. District Courts
+have relied on this rule when evaluating whether a purported filing was a "supplement" as
+opposed to an impermissible reply or sur-reply. See, Ormand v. Anthem, Inc.., 2008 WL 906157,
+at *1, n.2 (S.D. Ind. Mar. 31, 2008) (granting motion to strike notice of supplemental authority
+under the criteria set forth in Fed. R. App. P. 28()).
+Courts throughout the country have regularly granted motions to strike improper filings
+(such as improper supplemental authorities or improper sur replies), to control their own dockets.
+See, Ormand, supra, 2008 WL 906157, at *1, n.2 (striking improper supplemental authorities);
+Gen. Elec. Co. v. Latin Am. Imports, S.A., 187 F. Supp. 2d 749, 752 n. 1 (W.D. Ky. 2001)
+(striking notice of supplemental authority as improper sur reply: "A rebuke is in order here. ***
+This is an improper filing, as proper motion practice under the local rules contemplates only
+motions, responses, replies and memoranda; the court's inadvertent attention to these "notices"
+occurred only after careful investigation of the record. This "Notice of Filing Supplemental
+Authority" is properly construed as a motion for leave to file a sur reply, which is routinely
+denied by this court. Moreover, such a motion, when utilized for the purpose of supplementing
+argument on pending motions, should be used sparingly and for new, controlling case law—not
+for recently discovered case law, nor for arguments which the parties did not think to make in
+their pleadings."); E.T.I. Euro Telecom Int'l N. V. v. Republic of Boliva, 2008 WL 4129987, at *1
+2
+EFTA02799924
+
+Case 1:15-cv-07433-LAP Document 353 Filed 08/10/16 Page 4 of 7
+n.2 (S.D.N.Y. Sept. 4, 2008) (Swain, J.) ("disregard[ing]" improper sur reply); Pirnie v. Key
+Energy Servs., LLC, 2009 WL 1386997 (D. Colo. May 15, 2009) (striking improper sur reply:
+"Plaintiffs never asked for leave of court to file their sur reply brief; nor did they argue that a sur
+reply brief was necessary under the circumstances of the case. Plaintiffs did not show that
+Defendant had presented new material in the reply brief that it had not included in the original
+motion for summary judgment. Thus, the Court finds that Plaintiffs' sur-reply brief is improper
+and should be stricken."); Lust v. Dedicated Res., Inc., 2004 WL 5483695 (S.D. Fla. Oct. 14,
+2004) (striking improper sur reply).
+The "Supplement" filed by Plaintiff is simply more argument on a topic that the Court
+has yet to set a briefing schedule. It is improper and should be stricken.
+C. The Improper Pleading Misrepresents the Facts
+More significantly, Plaintiff's Supplement completely misrepresents the facts. Ms.
+Maxwell has run Plaintiff's name as a search term on all of her devices and all of her email
+accounts and has produced all responsive non-privileged documents. See Declaration of Laura
+A. Menninger of August 1 and Ex. F (search terms run on Ms. Maxwell's devices include:
+", jenna*, jena*, genna*) (Doc. # 321-1).
+The defense, however, has not run Plaintiff's name on defense counsel's entire system of
+computers, servers, hard-drives and email accounts, as Plaintiff has requested. Plaintiff's
+Request for Production 12 requested that "You" (defined as Ms. Maxwell or her agents or
+attorneys) "[p]roduce all documents concerning
+(a/k/a
+whether or not they reference her by name." A search of the attorneys' files for all documents
+that "concern" Plaintiff is the search to which the defense has objected (repeatedly, in writing
+and on the phone) and about which counsel has stated, correctly, such a search term is
+inappropriate because it is "guaranteed" to generate "thousands of hits." See, Supplement at 4.
+3
+EFTA02799925
+
+Case 1:15-cv-07433-LAP Document 353 Filed 08/10/16 Page 5 of 7
+With the exception court filings and discovery in this case (which the Plaintiff already has), the
+results would be all privileged documents.
+Plaintiff has conflated the issue of searching Ms. Maxwell's devices and email accounts
+with the issue of searching the attorneys' files and has based her entire Supplement on this
+fundamental misrepresentation.
+Likewise, Plaintiff misconstrues and misrepresents many other facts concerning Ms.
+Maxwell's communications with other witnesses and with regard to her email accounts. The
+Court has limited, for example, discovery of communications with certain enumerated witnesses
+post-2000 to those related to "sexual trafficking," see Order of April 15, 2016, not to mention
+Plaintiff has never issued a discovery request for communications with witness
+And Ms. Maxwell has only used her
+account as a
+account since the mid-
+2000's, when she opened her "
+account. Unsurprisingly, documents from the early
+2000's do not still exist on the
+account (Plaintiff also has produced not a single
+document from the 2000-2008 timeframe and has confessed to having a
+with responsive documents).
+Responding to each and every one of Plaintiff's misrepresentations is a waste of precious
+resources for defense counsel and this Court, especially as to a matter for which this Court has
+issued an adjournment of briefing.
+WHEREFORE, Ms. Maxwell respectfully requests the Court to strike docket entries 338,
+338-1 and 338-2, filed by Plaintiff on August 8, 2016.
+4
+EFTA02799926
+
+Case 1:15-cv-07433-LAP Document 353 Filed 08/10/16 Page 6 of 7
+Dated: August 10, 2016
+Respectfully submitted,
+Is/ Jeffrey S. Pagliuca
+Laura A. Menninger (LM-1374)
+Jeffrey S. Pagliuca (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.
+5
+EFTA02799927
+
+Case 1:15-cv-07433-LAP Document 353 Filed 08/10/16 Page 7 of 7
+CERTIFICATE OF SERVICE
+I certify that on August 10, 2016, I electronically served this Motion to Strike Plaintiff's
+Supplement to Motion for Adverse Inference Instruction Based on New Information via ECF on
+the following:
+Sigrid S. McCawley
+Meredith
+BOIES, SCHILLER & FLEXNER, LLP
+401 East Las Olas Boulevard, Ste. 1200
+Paul G. Cassell
+383 S. University Street
+Salt Lake City, UT 84112
+cassellp@law.utah.edu
+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
+J. Stanley Pottinger
+49 Twin Lakes Rd.
+South Salem, NY 10590
+StanPottinger@aol.com
+/s/ Nicole
+Nicole
+6
+EFTA02799928

vision-joined/court-04/b1b9893a9758cff13c17c63d8c6008376caef84665127d85561dce318d02d602.json

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vision-joined/court-04/b1b9893a9758cff13c17c63d8c6008376caef84665127d85561dce318d02d602.md

@@ -0,0 +1,84 @@
+Case 1:15-cv-07433-LAP Document 673
+Filed 03/03/17 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 in Limine to Exclude Deposition Testimony
+and
+or Any Witness
+Invoking Their Fifth Amendment Privilege
+Laura A. Menninger
+Jeffrey S. Pagliuca
+Ty Gee
+HADDON,|
+AND
+150 East 10" Avenue
+Denver, CO 80203
+303.831.7364
+. P.C.
+EFTA02802412
+
+Case 1:15-cv-07433-LAP Document 673 Filed 03/03/17 Page 2 of 4
+PAGES 1-3
+REDACTED
+EFTA02802413
+
+Case 1:15-cv-07433-LAP Document 673
+Filed 03/03/17 Page 3 of 4
+CONCLUSION
+Dated: March 3, 2017
+Respectfully submitted,
+Is/ 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.
+4
+EFTA02802414
+
+Case 1:15-cv-07433-LAP Document 673 Filed 03/03/17 Page 4 of 4
+CERTIFICATE OF SERVICE
+I certify that on March 3, 2017, I electronically served this Defendant's Motion in Limine to
+Exclude Deposition Testimony of
+or Any Witness Invoking
+Their Fifth Amendment Privilege 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
+J.
+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
+5
+EFTA02802415

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vision-joined/court-04/b1c5b346547b09b400d153147bdb76bf02082273a8141729b2911bbefebcc0b6.md

@@ -0,0 +1,4 @@
+Case 1:15-cv-07433-LAP Document 907-4 Filed 05/05/17 Page 1 of 1
+EXHIBIT 4
+(File Under Seal)
+EFTA02804755

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vision-joined/court-04/b1e7b89fcd0dfeb5ca1501a9b5e89b83f56049946f8283ad51ca83ee11847d51.md

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+Case 1:15-cv-07433-LAP Document 249-7 Filed 06/22/16 Page 1 of 6
+EXHIBIT 7
+EFTA02799041
+
+Case 1:15-cv-07433-LAP Document 249-7 Filed 06/22/16 Page 2 of 6
+Case 1:15-cv-07433-RWS Document 161-4 Filed 05/25/16 Page 2 of 6
+NO. 980
+P. 1
+MAY. 24. 2016 4:50PM
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+LITI
+Plaintiff
+V.
+Ghislaine Maxweil,
+, Defendant
+Civil Action No. 15-CV-07433-RWS
+AFFIDAVIT
+Douglas G. Mercer, being duly sworn deposes and stafes:
+1. I am employed as the Chief Investigator by Alpha Group Investigations, an
+investigative and security services compeny. I supervised the service of subpoenas
+upon Jeffrey Epstein,
+2. On Monday, April 25h
+", 2016 Alpha Group's Research Coordinator Enza |
+conducted research to determine current reported addresses in New York Tor Jeffrey
+Epstein,
+and
+determined the
+following:
+Jefirey Epstein:
+457 Madison Avenue, Apt 4, New York, New York 10022
+9 E. 74" Street, New York, New York 10021
+301E. 66" Street, Apt 10F, New York, New York 10065
+Street, Front 2, New York, New York 10012
+9E.
+Street, New York, New York, 10012
+301 E. 68" Street, Ap: 14G, New York, New York 10065
+301 E. 56" Street, Apt 11E/10N, New York, New York 10065
+3. On Tuesday, April 26",
+, at12:21pm, Alpha Group Investigator Kevin
+92
+Street, New York, New York to attempt to serve a subpoena on
+Investigator
+was advised by a doorman that
+resides at the location, in Penthouse 2, but had not been staying at the
+location due to construction.
+arrived at
+4. On Tuesday, April 26°
+, 2016 at 1:44 pm, Investigator Kevin
+Latived at 457
+Madison Avenue, New York. New York to attempt to serve a subpoena on Jeffrey
+Epstein. Investigator
+1 observed that the location was called the Trunk Club,
+which was a private clothing retailer, not a resicence.
+EFTA02799042
+
+Case 1:15-cv-07433-LAP Document 249-7
+Filed 06/22/16 Page 3 of 6
+Case 1:15-Cv-07433-RWS Document 161-4 Filed 05/25/16 Page 3 of 6
+NAY. 24. 2016 4:50PM
+NO. 980''
+P. 2
+5. On Tuesday, April 26", 2016, at 2:10 pm, Investigator Kevin
+arrived at E.
+68" Street, New York, New York to attempt to serve subpoenas on Jeffrey Epstein,
+and i
+Investicator
+was informed by a
+dooman that the doorman had observed:
+earlier in the day. The
+doorman called
+apartment,
+but no one answered the phone.
+The doorman did not recognize the names of Jeffrey Epstein, or
+6. On Tuesday, April 26", 2016, at 2:34 pm, Investigator Kevin
+arrived at 9 E.
+71% Street, New York, New York to attempt to serve subpoenas on Jeffrey Epstein
+and
+Investigator
+knocked on the door and rang the beli
+and he finally spoke to an Asian Male, 40-45 years of age, 5'5'-58 tall, 150 pounds,
+who fold the investigator that neither jeffrey Epstein, nor
+were
+at the rasidence.
+7 On Thursday, April 28", 2016, at 6:00 pm, Investigator Kevin (
+arrived at 301E.
+66" Streot, New York, New York to attempt to serve subpoenas on Jeffrey Epstein,
+and
+_ A doorman at the location called
+apartment 14G for
+but no one answered the phone. The
+doorman would not supply Investigator
+I with any additional information.
+8. On Thursday, April 28", 2016 at 8:17 pm, Irvestigator Kevin
+arrived at 9E.
+71% Street, New York. New York to attempt to serve subpoenas on Jeffrey Epstein
+and
+- Investigator i
+was advised by an unknown female
+on the intercom that Jeffrey Epstein was not home, but would return to the residence
+sometime on Monday, May 2°9, 2016.
+9.
+On Thursday, April 28", 2016 at 6:56 pm, Investigater Kevin
+arrived at 92
+Street, New York, New York to attempt to serve a subpoena on !
+A poorman at the building called several phone numbers to contact
+and after apparently speaking to
+L the doorman
+advised Investigator
+that
+was no: nome.
+10. On Saturday, April 30°, 2016, at 2:11 pm, Investigator Kevin
+arrived at 301 E
+66"* Street, New York, New York to attempt to serve subpoenas on Jeifrey Epstein,
+Hand
+- Investigator
+was informed by e
+doorman that the doorman had seen
+earlier in the day at the
+building, The investigator was informed by the doorman that the doorman believed
+that
+uses an office and an apartment at the bullding. The
+investigator was informed by the doorman that no one answered the phone in
+apartment. Tho doorman could not provide any further information
+regarding Jeffrey Epstein, or Nadia Marolnkova.
+11 On Saturday, April 30%
+2018, at 2:20 pm Investigator Kevin |
+arrived at 9 E.
+71* Street, New York, Now York to attempt to serve subpoenas on Jeffrey Epstein
+and
+Investigator
+rang the doorbell and knocked on the
+door. An unknown femalo responded to investigator
+on the intercom and the
+Temale advised that Jeffrey Epstein was not home, but would retum to the location
+sometime on Monday, May 2°
+, 2016.
+12. On Saturday, April 30"
+, 2016 at 3:17 pm, Investigator Kevin
+arrived at 92
+Street, New York, New York to attempt to serve a subpoena on |
+EFTA02799043
+
+Case 1:15-cv-07433-LAP Document 249-7
+Filed 06/22/16 Page 4 of 6
+Case 1:15-cv-07433-RWS Document 161-4 Filed 05/25/16 Page 4 of 6
+MAY. 24. 2016 4:50PM
+NO. 980
+P. 3
+The investigator was informed by a clooman that no one was staying in
+Penthouse 2 due to construction, Investigator
+was advised that the doorman
+had not seen
+for several weeks.
+13. On Tuesday, May 37, 2016, at 7:40 am, Investigator
+Dorilio arrived at 9 E.
+719 Street, New York. New York to atlempt to serve subpoenas on Jeffrey Epstein
+and
+Investigator Dorilio knocked on the door and rang the
+doorbell several times, but no one from within the residens responded. Investigator
+Dorilio served subpoenas for Jeffrey Epstein and
+by taping the
+subpoenas to the front door.
+14. On Tuesday, May 3°, 2016, at 8:05 am, Investigator
+Dorilio arrived at 301 E
+66" Street, New York, New York to attempt to serve subpoenas on Jeffrey Epstein,
+and Nedia Marcinkova. Investigator Dorilio was advised by a
+supervisor named Andrew, to leave the subpoenas with the doorman, rather than
+taping them to the front door. Investigator Dorille then served subpoenas for Jeffrey
+Epstein,
+and
+1 by leaving them with the
+doorman at the location.
+15. On Tuesday, May 3"%
+2016 at 8:45 am, Investigator I
+| Dorilio arrived at 92
+Street, New York, New York to attempt to serve a subenera op
+lill
+L. Investigator Dorilio was informed by a doorman that
+had not been at the localion for several months due to construction. Invostigator
+Dorilio then servod a subpoena for
+to the doorman, Mike, who
+acvised that he would contac!
+and give her the subpoena.
+16. On Tuesday, May 5°, 2018, the deponent mailed copies of subpoenas to the
+following:
+Jeffrey Epstein:
+9E. 71% Street, New York, New York 10021
+301 E. 66" Street, Apt 10F, New York, New York 10065
+92
+| Street, Front 2, New York, New York 10012
+9E. 71
+Street, New York, New York, 10012
+301 E. 66" Street, Apt 140, New York, New York 10065
+Nadia Marcinkova:
+301 E. 66 Street, Apt 11E/10N, New
+A witness fee check in the amount of !
+Marcinkova.
+17 On Saturday, May 14*,
+New York 10065
+was attached to the subpoena for Nodia
+EFTA02799044
+
+Case 1:15-cv-07433-LAP Document 249-7 Filed 06/22/16 Page 5 of 6
+Case 1:15-CV-07433-RWS Document 161-4 Filed 05/25/16 Page 5 of 6
+MAY 24. 2016 4:50PM
+NO. 980
+P. 4
+the building at 301 E. 66" Sireet New York. New York to attempt to serve the
+subpoenas for Jeffrey Epstein, :
+and
+• The
+doorman would not provide any information About the three subjects.
+18. On Saturday, May 14", 2018 at 9:10 am, Investigator Anna Intriago arrived al 9 E.
+71" Street, New York, New York to attempt to serve subpoenas on Jeffrey Epstein
+and
+Investigator intriago rang the beil and knocked on the
+door, but no one responded.
+19. On Monday, May 16°, 2016 at 6:30 am Investigator Anna Intriago arrived at 301 E
+66" Street, New York, New York to altempt to serve subpoenas on Jeffrey Epstein,
+, Investigator Intriago spoke to a doorman
+resided within the building, but travels a lot. The
+doorman advised Investigator Intriago that
+at that time. The dooman advised Investigator Intriago that Jeffrey Epstein dues not
+reside in the building, but owns apartments. The doorman advised Investigator
+Vickers no longers resides within the building; that
+moved about two years ago.
+20. On Monday, May 18'
+", 2016 at 11:25 am Investigator Anna Intriago arrived at 9 E. 71,
+Street, New York, New York to attempt to serve subpoenas on Jeffrey Epstein and
+Investigator Intriage rang the doorbell and knocked on the door.
+An unknown male responded on the intercom and advised thet neither Jeffrey
+Epstein, nor
+were at the residence. The unknown male would
+not tell Investigator Intriago when Jeffrey Eostein and
+were
+expected to return to the residence.
+21 On Monday, May 16"
+", 2016 at 12:00 pm Investigator Anna Intriago returned to 301 E.
+68" Street, New York, New York to ascertain # Nadia Marcinkova had retumed to the
+rosidence, Investigator Intriago was advised by the doorman that
+had not retumed to the residence. The doorman advised Investigator Intrago that no
+one was permitted to enter the building unless permission was given by a resident.
+22. On Tuesday, May 17", 2016, at 4:06 pm Investigator Anna Intriago arrived at 301 E.
+66" Street. New York, New York to attempt to serve subpoenas on Jeffrey Epstein,
+and Nadia Marcinkova, At 5:00pm, after Investigator Intriago did
+not obeerve Jeffrey Epstein,
+Lor
+enter or
+leave the building, Investigator Intriago critered the building and spoke to a doorman.
+The doorman would not provide any information about any resident.
+23. On Tuesday, May 17"
+responded to 9 E. 71% 2016, shortly after 5:00 pm Investigator Anna Intriago
+Street, New York, New York to attempt to locate and serve
+subpoenas on Jeffrey Epstein and
+The investigator did not
+observe Jeffrey Epstein, or
+|||||| I||| Center or leave the residence.
+24. On Tuesday, May 17", 2016 at 6:21 pm, at 301 E. 86* Street, New York, New York
+Investigator Anna Intriago served subpoence for Jeffrey Epstein,
+and Nadia Marcinkova by delivering the subpoenss to Jose Pepin, a dooman atthe
+301 E. 66" Street, New York, New York.
+EFTA02799045
+
+Case 1:15-cv-07433-LAP Document 249-7 Filed 06/22/16 Page 6 of 6
+Case 1:15-cv-07433-RWS Document 161-4 Filed 05/25/16 Page 6 of 6
+MAY. 24. 2016 4:51PM
+NO. 980
+P. 5
+25. On Tuesday, May 17", 2016 at 6:39 pm, at 9 E. 71" Street, New York, New York
+Investigator Anna Intriago had attempted to serve subpoenas for Jeffrey Epstein and
+py ringing the doorbell and knocking on the door. An unknown
+remale answered on the intercom and advised investigator Intriago that neither Jeffrey
+Epstein, nor :
+were at the residence. The unknown female
+advised that she could not accept the subpoenas for Jeffrey Epstein, or !
+Investigator intriago then served the subpoenas for Jeffrey Epsten and
+by taping the subpoenas to the front door.
+26. On Wednasday, May 18°, 2016 the deponent mailed copies of subpoenas to the
+following:
+Jeffrey Fostein:
+9 E. 71# Street, New York, New York 10021
+301 E. 66ª Street, Apt 10F, New York, New York 10055
+A witness fee check in the amount of $41.10 was attached to the subpoena for Jeffrey
+Epstein
+9 E. 71" Street, New York, New York, 10012
+301 E. 66" Street, Apt 14G, New York, New York 10065
+A witness fee check in the amount of $41.10 was attached to the subpoena for li
+Nadia Marcinkova;
+301 E. 66" Stroot, Apt 11E/10N, New York, New York 10085
+A witness fee check in the amount of $41.10 was attached to the subpoena for
+Sworn to before me this
+229t Day of May, 2016.
+Coconne Sone
+Enza Miller
+ROSANNE GiATE
+Notary Public
+FOSINHEGIESE
+EFTA02799046

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vision-joined/court-04/b1ed40e9eee51efbcdfd0e3a7b7d9e203c858db8389a45751131c9e2388123e7.md

@@ -0,0 +1,53 @@
+CG
+Casest: 2020F003388DAGN Document 278 Freet109500221 Pagage afat 1
+& GRESSER LLP
+Christian R. Everdell
++1 (212) 957-7600
+ceverdell@cohengresser.com
+USDC SDNY
+DOCUL
+ELECTRONICALLY FILED
+DOC#:_
+DATE FILED:_ 5/10/21
+800 Third Avenue
+New York, NY 10022
++1 212957 7600 phone
+www.cohengresser.com
+May 7, 2021
+VIA ECE
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+40 Foley Square
+New York, New York 10007
+5/10/21
+The Government is hereb
+ORDERED to propose anc
+justify any redactions by
+May 12, 2021.
+SO ORDERED.
+SO ORDEREI
+ALISON I. NATHAN, US.DI.
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+On behalf of our client, Ghislaine Maxwell, we will be filing our Omnibus Memorandum
+in Support of Ms. Maxwell's Supplemental Pretrial Motions Relating to the S2 Superseding
+Indietment with accompanying exhibits.
+The memorandum and exhibits contain Confidential Information produced in discovery
+that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our
+prior practice, we will not file the supplemental motions on the public docket until we are
+instructed to do so by the Court. Instead, we will submit the supplemental motions by email to
+the Court and the government under seal pursuant to Rule 2(B) of the Court's individual rules
+of criminal practice to give the government the opportunity to propose and justify any
+redactions it deems necessary.
+Please contact us with any questions.
+Your consideration is greatly appreciated.
+Respectfully submitted,
+/s/ Christian R. Everdell
+Christian R. Everdell
+& GRESSER LLP
+800 Third Avenue, 21st Floor
+New York, New York 10022
+(212) 957-7600
+cc: All counsel of record (via email)
+EFTA02831949

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vision-joined/court-04/b20267430c9510fb4a07071f8d82e1ef9d7f87c62201a5d1e165941493d4ef00.md

@@ -0,0 +1,79 @@
+Case 1:15-cv-07433-LAP Document 260
+Filed 06/28/16 Page 1 of 3
+United States District Court
+Southern District of New York
+Plaintiff,
+V.
+Ghislaine Maxwell,
+Defendant.
+Case No.: 15-cv-07433-RWS
+DECLARATION OF SIGRID S. MCCAWLEY IN PLAINTIFF'S OPPOSITION TO
+DEFENDANT'S MOTION TO REOPEN DEPOSITION OF PLAINTIFE
+I, Sigrid S. McCawley, declare that the below is true and correct to the best of my
+knowledge as follows:
+I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly
+licensed to practice in Florida and before this Court pursuant to this Court's September 29, 2015
+Order granting my Application to Appear Pro Hac Vice.
+I respectfully submit this Declaration in Opposition of Defendant's Motion to
+Reopen Deposition of Plaintiff.
+Attached hereto as Sealed Exhibit 1 is a true and correct copy o
+Attached hereto as Sealed Exhibit 2 is a true and correct copy of l
+I declare under penalty of perjury that the foregoing is true and correct.
+Is/ Sigrid S. McCawley
+Sigrid S. McCawley, Esq.
+EFTA02799159
+
+Case 1:15-cv-07433-LAP Document 260 Filed 06/28/16 ]
+Page 2 of 3
+Dated: June 28, 2016.
+Respectfully Submitted,
+BOIES, SCHILLER & FLEXNER LLP
+By: Is/ Sigrid McCawley
+Sigrid McCawley (Pro Hac Vice)
+Meredith
+(Pro Hac Vice)
+Boies Schiller & Flexner LLP
+401 E. Las Olas Blvd., Suite 1200
+Ft. Lauderdale, FL 33301
+(954) 356-0011
+David Boies
+Boies Schiller & Flexner LLP
+333 Main Street
+Armonk, NY 10504
+(Pro Hac Vice)
+L JAFFE, WEISSING,
+_, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Paul G. Cassell (Pro Hac Vice)
+S.J. Quinney College of Law
+University of Utah
+383 University St.
+Salt Lake City, UT 84112
+' This daytime business address is provided for identification and correspondence purposes only and is
+not intended to imply institutional endorsement by the University of Utah for this private representation.
+2
+EFTA02799160
+
+Case 1:15-cv-07433-LAP Document 260 Filed 06/28/16 Page 3 of 3
+CERTIFICATE OF SERVICE
+THEREBY CERTIFY that on the 28th day of June, 2016, I electronically filed the
+foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
+foregoing document is being served to all parties of record via transmission of the Electronic
+Court Filing System generated by CM/ECF.
+Laura A. Menninger, Esq.
+Jeffrey Pagliuca, Esg.
+HADDON
+&
+150 East 10" Avenue
+Denver, Colorado 80203
+Tel: (303) 831-7364
+Fax: (303) 832-2628
+Email: Imenninger@hmflaw.com
+jpagliuca@hmflaw.com
+P.C.
+Is/ Sigrid S. McCawley
+Sigrid S. McCawley
+3
+EFTA02799161

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vision-joined/court-04/b204c8af41175c7e1c03e7395471da6e58e9725ba5e1c33b9ccde709494ee6ae.md

@@ -0,0 +1,1020 @@
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 1 of 30
+Exhibit V
+EFTA02829918
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 2 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+Ghislaine Maxwell
+Opinion on
+Extradition Law
+OVERVIEW
+• This report was written pursuant to a request from Olivier Laude, a partner at the
+firm Laude Esquier Champey acting on behalf of
+& Gresser LLP as counsel for
+Ms Ghislaine Maxwell, in the context of ongoing bail proceedings involving the latter
+in the United States of America (hereafter "USA"), where Ms Ghislaine Maxwell is
+being detained pre-trial on charges relating to her alleged role in sexual activities
+between Jeffrey Epstein and certain minor girls, from 1994 to 1997.
+• Olivier Laude has instructed me to draft an opinion regarding the
+extradition
+procedure and the possibility for Ms Ghislaine Maxwell to be extradited from France to
+the USA if she were to flee to France after being released on bail in the USA.
+• As requested, I have attached a resume. (See Exhibit A).
+EXECUTIVE SUMMARY
+• The principle against the extradition of
+nationals does not constitute a binding
+rule of international law and is not considered a constitutional principle under
+law.
+• The extradition of
+nationals can be prohibited under the terms of an international
+treaty. However, the existing Extradition Treaty between France and the USA of 23
+April 1996 does not contain such prohibition. As a result, the extradition of a
+national to the USA is legally permissible under
+law.
+In order to assure the US authorities that she will not attempt to contest her extradition
+as a
+citizen or otherwise, we are informed that Ms Maxwell is about to execute
+an irrevocable waiver of her right to seek the protection of the
+Courts to fight
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+1
+EFTA02829919
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 3 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+any extradition request from the US Government to the competent
+("The Waiver"). (See Exhibit B).
+Authorities
+• All extradition requests from the USA to France must be examined by the Investigating
+Chamber of the competent Court of appeal, which has jurisdiction over the legality of
+extradition requests in France.
+• Under the circumstances of this case, where Ms Maxwell would have fled from the USA
+to France prior to her trial in violation of her bail conditions, it is highly likely that Ms
+Maxwell would be placed in custody in France from the earliest stages of the extradition
+proceedings.
+• As the principle against the extradition of nationals is not part of the Extradition Treaty
+between the USA and France, the Investigating Chamber of the Court of appeal would
+not oppose the extradition of Ms Ghislaine Maxwell on the ground that she is a
+citizen.
+• The final decision to extradite and its execution would ultimately be a matter for the
+executive.
+• In the recent past, I am not aware that the |
+authorities would have had to address
+the situation in which the United States sought extradition of a L
+_ citizen who was
+also a United States citizen. Thus, there is no precedent to draw from in that
+regard. However, it is our view that under the specific and unique facts of this case, it
+is highly unlikely that the
+government would refuse to issue and execute an
+extradition decree against Ms Maxwell because of several critical factors, namely: her
+United States citizenship; the fact that she has signed an irrevocable Waiver in the USA;
+the fact that in the present situation, the only way the issue would be raised in France is
+if Ms. Maxwell would have already fled to France in violation of very strict bail
+conditions, and the fact that a failure by
+• authorities to grant extradition would
+result in an obligation to try
+courts for the conduct described
+in the Indictment. Finally, France would be inclined to preserving the interests of the
+USA for obvious diplomatic reasons.
+• With regard to timing, if the requested person has consented to extradition, the
+Investigating Chamber must deliver its ruling no later than 14 working days after the
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+2
+EFTA02829920
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 4 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+person has first appeared before the Public Prosecutor'. If the legal conditions of
+extradition are satisfied, the Investigating Chamber must issue a positive opinion to
+extradition, which is not subject to appeal. Following the Investigating Chamber's
+ruling, there is no specified time frame within which the government must issue an
+extradition decree. However, if the requesting State emphasizes the urgent nature of the
+request, the extradition decree is generally issued in only a few weeks. Therefore, the
+overall procedure is likely to be disposed of expediently under these circumstances.
+' The 14 days period is divided as follows: the requested person must appear before the Public Prosecutor within
+2 days of arrest, he or she must be heard by the Investigating Chamber no later than 5 working days after appearing
+before the Public Prosecutor, and the Investigating Chamber must then deliver its final opinion on the legality of
+the extradition request within 7 days. This procedure will be explained in more details in Part I of this opinion.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+3
+EFTA02829921
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 5 of 30
+William JULIE
+avocat à la cour - attorney at law
+Table of Contents
+Background
+Part 1 - The
+Extradition Procedure
+A. Request for temporary arrest
+B. Application for extradition (Ministerial phase)
+C. Arrest and presentation before the Prosecutor General (beginning of the
+judicial phase)
+D. Decision of the Investigating Chamber of the competent Court of appeal
+E. Decision of the L
+government (Extradition Decree)
+F. Possible application before the European Court of Human Rights
+Part I1 - The likely outcome of an extradition request from the United States of America
+to France in the case of Ms Ghislaine Maxwell
+A. General bars to extradition
+B. The protection of nationals from extradition under
+law and the
+Extradition Treaty between the USA and France: Lack of an absolute
+protection
+Conclusion
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+4
+EFTA02829922
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 6 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+Background
+1. At the bail hearing of Ms Ghislaine Maxwell on 14 July 2020, the US Government made
+the following point in support of its motion to detain the defendant:
+"The government has spoken with the Department of Justice attachés in the
+United Kingdom and France. With respect to France, we have been informed
+that France will not extradite a
+_ citizen to the United States as a
+matter of law, even if the defendant is a dual citizen of the United States. "*.
+2. The international ties of Ms Ghislaine Maxwell and her
+of the grounds for which bail was denied by the Court, which found that:
+nationality appear as one
+"Ms Maxwell's history and characteristics support the position of her posing a risk of
+flight. Ms Maxwell has substantial international ties and could facilitate living abroad
+if she were to flee the United States. She holds multiple foreign citizenships, has familial
+and personal connections abroad, and owns at least one foreign property of significant
+value. In particular, she is a citizen of France, a nation that does not appear to
+extradite its citizens".
+3. The present report intends to evaluate whether the contention that France is a nation that
+does not extradite its citizens is correct as a matter of law.
+4. It will first set out the various steps of the
+extradition procedure (Part I), and
+then outline the grounds on which extradition requests are analyzed under |
+law,
+and especially the status of the rule against extradition of nationals, in order to assess the
+application of these principles to an extradition request made by the USA, in particular
+where, as in this case, the requested person has executed an irrevocable waiver of his/her
+right to contest extradition and is present in France only because she fled the United
+States in violation of her bail conditions. (Part II).
+" At p. 27 of the transcript.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+5
+EFTA02829923
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 7 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+Part I - The
+Extradition Procedure
+5. Extradition requests between the United States and France are governed by the
+Extradition Treaty between the USA and France signed in Paris on 23 April 1996°, the
+Agreement on Extradition between the United States of America and the European
+Union signed in Washington on 25 June 2003*, and the Instrument Amending the Treaty
+of 23 April 1996 between the United States of America and France signed in the Hague
+on 30 September 2004'.
+6. For matters not covered in these agreements, extradition requests made by the USA are
+governed by provisions of the
+Code of Criminal Procedure (Articles 696 et seq.).
+A. First stage: Request for temporary arrest
+7. Under Article 13.1 of the Extradition Treaty between the USA and France, in case of
+urgency, the requesting State may seek the provisional arrest of the person sought
+pending the presentation of the request for extradition°.
+8. This procedure can be summarized as follows:
+- Based on a request for provisional arrest, the Prosecutor General may order the
+arrest of the requested person.
+- Upon arrest, the requested person must appear within 48 hours before the Prosecutor
+General, who informs him/her of the existence and contents of the request for
+temporary arrest and of his/her rights.
+- The Prosecutor may decide to release the requested person, based on the relevant
+flight risks.
+- If the Prosecutor considers that the requested person should be detained, the
+requested person appears before the 1" President of the Court of appeal, who can
+decide to order either his/her release (without any control, or under judicial
+3 The Extradition Treaty between the USA and France entered into force in France on February 1, 2002 (by Decree
+n° 2002-117 of 29 January 2002).
+* The object of this agreement is "to provide for enhancements to cooperation in the context of applicable
+extradition relations between the Member States and the United States of America governing extradition of
+offenders" (Article 1).
+" The Instrument Amending the Treaty of April 23, 1996 between the USA and France entered into force in France
+on February 1, 2010 (by Decree n° 2010-490 of 12 May 2010).
+" A request for provisional arrest may be transmitted directly between the United States Department of Justice
+Republic, through INTERPOL or the diplomatic
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+6
+EFTA02829924
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 8 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+supervision, or under house arrest with electronic surveillance) or incarceration at
+the remand prison of the Court of appeal in which jurisdiction he/she has been
+apprehended.
+- The decision of the 1" President of the Court of Appeal can be challenged before
+the Investigating Chamber of the Court of Appeal.
+- In case of incarceration, the requested person can file an application for release
+before the Investigating Chamber of the Court of appeal at any time during the
+extradition procedure.
+9. Under Article 13.4 of the Extradition Treaty between the USA and France, if, within 60
+days of arrest, the government of the requested State has not received from the requesting
+State the formal extradition request as well as supporting documents required by the
+Treaty, the requested person is discharged from custody. If the government has received
+the relevant documents, the normal extradition procedure may begin.
+10. If the person has been discharged from custody pursuant to Article 13.4 of the Treaty,
+such release does not preclude a subsequent re-arrest if an extradition request and
+supporting documents are delivered at a later date (Article 13.5).
+B. Second stage: Application for extradition (Ministerial phase)
+11. Article 10.1 of the Extradition Treaty between the USA and France provides that "all
+requests for extradition shall be submitted through the diplomatic channel".
+12. The Extradition Treaty between the USA and France does not specify which internal
+procedures must be followed in each contracting State following the transmission of the
+extradition request through the diplomatic channel pursuant to Article 10. We must
+therefore refer to provisions of the
+Code of Criminal Procedure to outline the
+procedure followed by
+institutions upon receipt of an extradition request made
+by the USA.
+13. Under Article 696-9 of the
+in France is as follows:
+Code of Criminal Procedure, the procedure followed
+" Article 10 of the Extradition Treaty between the USA and France
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+7
+EFTA02829925
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 9 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+- The Minister of Foreign Affairs first verifies that the file is properly constituted in
+accordance with the requirements of the Extradition Treaty. The Minister of Foreign
+Affairs only verifies that the request contains all the required documents.
+- The file is then transmitted to the Minister of Justice, which verifies the regularity
+of the request. At this stage, the
+nationality of the requested person does not
+influence the control of the Minister of Justice.
+- The Minister of Justice must then forward the file to the Prosecutor General. This
+obligation to transmit the file to the Prosecutor General is binding, as Article 696-9
+uses imperative language requiring the Minister of Justice to do so.
+C. Third stage: Arrest and presentation before the Prosecutor General (beginning of
+the judicial phase)
+14. Any person arrested pursuant to an extradition application must be transferred to the
+territorially competent Prosecutor General within 48 hours after the arrest.
+15. The Prosecutor General informs the requested person, in a language he or she
+understands, of:
+- the existence and the content of the extradition application;
+- the right to be assisted by an advocate and to have an interview with this advocate
+immediately;
+- the right to consent to or to oppose his or her extradition, and the legal consequences
+of consenting to extradition;
+- the right to waive the principle of specialty (according to which the person who is
+extradited can be prosecuted only for the crimes specified in the extradition request),
+and the legal consequences of such renunciation.
+16. The Prosecutor General hears the statements of the person and his or her counsel, and in
+particular, the consent or opposition to extradition, which shall be officially recorded.
+17. The Prosecutor General decides whether to release the requested person or not. If he
+considers that the requested person should remain in detention, the requested person then
+appears before the 1 President of the Court of appeal, who may order the person's
+release (without any control, or with judicial supervision, or under house arrest with
+electronic surveillance) or his/her incarceration. The 1" President's decision may be
+" Article 696-10 of the
+Code of Criminal Procedure.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+8
+EFTA02829926
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 10 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+appealed before the Investigating Chamber of the Court of appeal, by the Prosecutor
+General or the requested person.
+D. Fourth stage: Decision of the Investigating Chamber of the competent Court of
+appeal
+18. Once the requested person has declared to the Prosecutor General whether he consents
+or not to extradition, the Investigating Chamber is immediately seized of the case. This
+phase varies depending on whether the requested person consents to extradition.
+19. If the requested person has declared to the Prosecutor General that he or she consents to
+extradition, Article 696-13 of the
+Code of Criminal Procedure provides that he
+or she must appear before the Investigating Chamber within 5 working days from the
+date of presentation before the Prosecutor General. The same provision states that the
+requested person may also decide to waive the rule of specialty before the Prosecutor
+General.
+20. If, at this appearance, the requested person confirms his or her consent to be extradited
+and the legal conditions for extradition are fulfilled, the Investigating Chamber informs
+the person of the legal consequences of such consent and formally acknowledges this
+consent within 7 days from the date of appearance, unless additional investigations have
+been ordered®.
+21. The rules of this simplified extradition procedure must be read in light of Article 11 of
+the Agreement on Extradition between the European Union and the USA of 25 June
+2003 ("Simplified extradition procedures"), which states that "if the person sought
+consents to be surrendered to the requesting State, the requested State may, in
+accordance with the principles and procedures provided for under its legal system,
+surrender the person as expeditiously as possible without further proceedings. The
+consent of the person sought may include agreement to waiver of protection of the rule
+of specialty!!. This provision, together with Article 696-13 of the
+Code of
+Criminal Procedure, demonstrates that extradition law is considerate of the requested
+° Article 696-14 of the
+Code of Criminal Procedure.
+1° Such Article 11 of the Agreement on Extradition between the European Union and the USA of 25 June 2003
+has been directly incorporated in the Extradition Treaty between the USA and France signed in Paris on 23 Apri
+1996 by the Instrument Amending the Treaty of 23 April 1996 between the United States of America and France
+signed in the Hague on 30 September 2004.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+9
+EFTA02829927
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 11 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+person's intentions and recognizes that the person may legally waive some of the rights
+that attach to extradition proceedings.
+22. Where the requested person has consented to extradition, the Investigating Chamber's
+ruling is not subject to appeal or any other legal challenge'.
+23. If the requested person has declared to the Prosecutor General that he or she does not
+consent to extradition, he or she must appear before the Investigating Chamber within a
+period of 10 working days from the date of presentation before the Prosecutor!?.
+24. If the requested person reiterates to the Investigating Chamber that he or she does not
+consent to extradition, the Court delivers a reasoned opinion on the extradition request.
+Unless additional investigations have been ordered, the Court delivers its opinion within
+one month from the requested person's appearance before it'?.
+25. The Investigating Chamber may authorize the requesting State to participate in the
+hearing. This possibility is expressly provided for in the Agreed Minute on
+Representation annexed to the Extradition Treaty between the USA and France.
+26. The Investigating Chamber issues a positive opinion if it considers that the legal
+requirements of extradition are satisfied.
+E. Fifth stage: Decision of the
+government
+27. Extradition is authorized by a decree of the
+Prime Minister upon the advice of
+the Minister of Justice.
+28. The decree may impose conditions to authorize extradition, such as guarantees not to
+seek or impose the death penalty against the requested person.
+29. The decree of extradition can only intervene after the end of the judicial phase.
+" Id.
+12 Article 696-15 of the
+1 Id.
+Code of Criminal Procedure.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+10
+EFTA02829928
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 12 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+30. The requested person has to be handed over by the agents of the requested State within
+one month after the extradition decree has been notified to the requesting State'.
+14 Article 15.4 of the Extradition Treaty between the USA and France of 23 April 1996.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+11
+EFTA02829929
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 13 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+F. Sixth stage: Possible application before the European Court of Human Rights
+31. Once all domestic remedies have been exhausted, it is possible to file a written
+application against France before the European Court of Human Rights, within six
+months from the date of the final decision at the domestic level, alleging the violation of
+human rights protected by the European Convention of Human Rights, such as the rights
+to life, to a fair trial, not to be tortured, etc.
+32. An application before the European Court of Human Rights may be accompanied by a
+written request for interim measures, pursuant to Rule 39 of the Rules of Court, such as
+a request to suspend the extradition of the applicant pending the outcome of the
+proceedings.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+12
+EFTA02829930
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 14 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+Part II - The likely outcome of an extradition request from the United States of
+America to France in the case of Ms Ghislaine Maxwell
+33. In this case, if an extradition request were to be transmitted by the USA against Ms
+Ghislaine Maxwell, the
+judicial authorities would most certainly decide that she
+has to remain in custody given her flight from the USA and the violation of her bail terms
+and conditions in this requesting State.
+34. Having outlined the different stages of the
+extradition procedure, the second part
+of this opinion will examine the likely outcome of an extradition request against the
+person of Ms Ghislaine Maxwell, if she were to be released on bail and decided to flee
+from the USA to France. It will first outline the general bars to extradition (A), and then
+analyze the status of the protection of nationals from extradition in the
+legal
+system and in the Extradition Treaty between the USA and France (B). It will conclude
+that Ms Ghislaine Maxwell's extradition from France to the USA would not be legally
+barred by her
+citizenship, and that it is highly unlikely, under the specific and
+unique circumstances of this case, that
+authorities will refuse to enforce an
+extradition decree.
+A. General bars to extradition
+35. Several bars to extradition may classically be invoked before |
+courts, namely (i)
+a claim that the requested person would be at risk of human rights violations in the
+requesting State (with regards to the right to a fair trial and the right to be free from
+torture, inhumane or degrading treatment); (ii) the dual criminality rule; and (iii) a claim
+that the extradition request is politically motivated.
+(i)
+Human rights bars
+36. Under the case law of the
+Cour de cassation, the Investigating Chamber of the
+Court of appeal must consider allegations of human rights violations pertaining to the
+conditions of trial and detention in the requesting State'S. These claims center on the
+right to a fair trial (Article 6 ECHR) and the right to be free from torture, inhumane
+15 Cass. Crim., 26 March 2019, nNo. 19-81731.
+1° Einhorn v. France, 16/10/2001, Application No. 71555/01.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+13
+EFTA02829931
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 15 of 30
+William JULIE
+avocat à la cour - attorney at law
+and degrading treatments in custody (Article 3 ECHR)'?. If the Investigating Chamber
+finds that the requested person would face a risk of being subject to violations of their
+Article 3 rights, or that there is a risk of a "flagrant denial of justice" in the requesting
+State, it must deliver a negative opinion to the extradition request.
+37. In the recent years, human rights bars to an extradition request made by the United States
+of America are only the subject to in-depth scrutiny by |
+courts when the requested
+person faces the imposition of the death penalty! or the imposition of a life
+imprisonment sentence without the possibility of parole in the USA. We understand that
+this is not the case here. It can be underlined that, when needed, the USA can commit
+not to impose such a sentence and that such a commitment suffices to allow extradition.
+38. As long as the |
+government receives necessary assurances related to human rights
+when requested, such an argument would be very likely to be rejected in this case.
+(ii)
+Dual criminality
+39. A further possible bar to extradition is the dual criminality rule, which requires the
+conduct in respect of which extradition is sought to constitute a criminal offense in the
+law of both requested and requesting States.
+40. Article 2.1 of the Extradition Treaty between the USA and France expressly states that
+"[alets shall be extraditable if they are punished under the laws in both States by
+deprivation of liberty for a maximum of at least one year or by a more severe penalty. If
+extradition is requested for purposes of enforcing a judgment, the time remaining to be
+served must be at least six months."
+41. There is no doubt that the conduct referred to in the Grand Jury charges against Ms
+Ghislaine Maxwell, contained in the Superseding Indictment S1 20 Cr. 330 (AJN), filed
+on July 8,
+, 2020, also constitutes criminal conduct under
+law, as the crime of
+"proxénétisme"
+42. Article 225-5 of the |
+Criminal Code defines the crime of "proxénétisme" as "the
+fact, by anyone, in any manner whatsoever: 1° To aid, assist or protect the prostitution
+' Soering v United Kingdom, 07/07/1989, Application No. 14038/88; Cass. Crim., 26 March 2019, No. 19-81731.
+18 In this regard, see Article 7 of the Extradition treaty between France and the USA.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+14
+EFTA02829932
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 16 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+of others; 2° To profit from the prostitution of others, to share the proceeds of
+prostitution or to receive subsidies from a person habitually engaged in prostitution; 3°
+To hire, entice or divert a person to engage in prostitution or to exert pressure on him
+or her to engage or continue to engage in prostitution. '9» Article 225-6 of the
+Criminal Code provides that the crime is also established by "the fact, by whoever, in
+any way whatsoever: 1° To act as an intermediary between two persons, one of whom
+engages in prostitution and the other exploits or remunerates the prostitution of
+others-"'
+43. In
+law, the conduct charged in all four counts?! would qualify as the crime of
+"proxénétisme" under Articles 225-5 and 225-6 of the L
+Criminal Code.
+44. When committed against a minor, Article 225-7 of the |
+Criminal Code provides
+that the crime is punished by an enhanced sentence, namely a statutory maximum of 10
+years imprisonment (as opposed to 7 years, when committed against an adult)?.
+45. Thus, dual criminality would not constitute an obstacle to Ms Ghislaine Maxwell's
+extradition from France to the USA.
+(iii)
+Political offense and manifest inconsistency
+46. Finally, the requested person may argue that the extradition request is politically
+motivated, or that the charges contained in the extradition request are manifestly
+inconsistent with the conduct thereunder.
+, « Le proxénétisme est le fait, par quiconque, de quelque manière que ce soit : 1° D'aider, d'assister
+ou de protéger la prostitution d'autrui : 2° De tirer profit de la prostitution d'autrui, d'en partager les produits ou
+de recevoir des subsides d'une personne se livrant habituellement à la prostitution ; 3° D'embaucher, d'entraîner
+ou de détourner une personne en vue de la prostitution ou d'exercer sur elle une pression pour qu'elle se prostitue
+20 In|
+_ « Est assimilé au proxénétisme et puni des peines prévues par l'article 225-5 le fait, par quiconque,
+de quelque manière que ce soit : J° De faire office d'intermédiaire entre deux personnes dont l'une se livre à la
+prostitution et l'autre exploite ou rémunère la prostitution d'autrui [...] ».
+'' Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts; Enticement of a Minor to Travel to Engage
+in Illegal Sex Acts; Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity;
+Transportation of a Minor with Intent to Engage in Criminal Sexual Activity.
+12 "Proxénétisme is punishable by ten years imprisonment and a fine of 1,500,000 euros when committed: 1° With
+regard to a minor (...) . In L
+_« Le proxénétisme est puni de dix ans d'emprisonnement et de 1 500 000 euros
+d'amende lorsqu'il est commis : 1° A l'égard d'un mineur ».
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+wj@wjavocats.com-
+www.wjavocats.com - palais C1652
+15
+EFTA02829933
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 17 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+47. Article 4 of the Extradition Treaty between the USA and France provides that
+"[e]xtradition shall not be granted by France when the offense for which extradition is
+requested is considered by France as a political offense or as an offense connected with
+a political offense or as an offense inspired by political motives".
+48. A political motivation claim requires the Investigating Chamber to examine, to some
+extent, the merits of the case. The Court is also required to look into the merits of the
+case where the requested person argues that there is a manifest inconsistency between
+the conduct and the legal offenses in respect of which the extradition is sought?.
+49. The conduct described in the indictment does not appear to be manifestly inconsistent
+with the offenses charged therein.
+50. As to political motivation,
+courts have never opposed extradition requests from
+the USA on this ground?4. In fact, in the past ten years, only one published decision of
+the Cour de cassation has denied an American extradition request, on the ground that
+the Investigating Chamber had not verified that the criminal conduct described in the
+request constituted a crime in France at the time of commission?
+. All other published
+decisions which have ruled on a request from the USA have granted extradition?®
+51. In light of the elements contained in the Superseding Indictment, Ms Ghislaine Maxwell
+could not oppose her extradition to the USA on the basis of a political motivation claim,
+that would have no serious ground, and therefore the Investigating Chamber would not
+look into the merits of the case against her.
+B. The protection of nationals from extradition under
+Treaty between the USA and France: Lack of an absolute protection
+law and the Extradition
+23 Cass. Crim., 21 November 2007, No. 07-87540.
+24 See by contrast, a 2016 recent decision of the Conseil d'Etat to deny extradition to Russia of a prominent figure
+of the Kazakh opposition, Moukhtar Abliazov, on the ground that the request was politically motivated (available
+at: https://www.legifrance.gouv.fr/ceta/id/CETATEXT000033581187/).
+25 Cass. Crim., 14 October 2015, No. 15-84426.
+* Cass. Crim., 11 March 2020, No. 19-84023 ; Cass. Crim., 21 February 2017, No. 16-87102 ; Cass. Crim., 23
+February 2010, No. 09-88021 ; Conseil d'Etat - 2ème et 7ème SSR, 15 April 2016, No. 390860 ; Conseil d'État
+- 2i et Time SSR, 19 October 2018, No. 421762 ; Cass. Crim., 4 June 2019, No. 18-84398 ; Cass. Crim., 26
+November 2019, No. 19-80274 ; Conseil d'Etat - Zime et 7ime SSR, 1 June 2011, No. 342419 ; Cass. Crim., 21
+June 2016, No. 16-81981 ; Cass. Crim., 4 October 2016, No. 16-84450 ; Cass. Crim., 11 May 2011, No. 11-
+80942, No. 11-80943 ; Cass. Crim., 10 May 201, No. 11-80989 ; Conseil d'Etat, - 2ime et Zine SSR, 7 May
+2012, No. 352573 ; Cass. Crim, 13 February 2008, No. 07-88009 ; Cass. Crim., 3 March 2015, No. 14-88308 ;
+Cass. Crim., 11 June 2013, No. 13-81979.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+16
+EFTA02829934
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 18 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+52. Chapter V of the
+Code of Criminal Procedure (Articles 696 to 696-47-1) sets out
+legislative provisions pertaining to extradition.
+53. The rule against the extradition of nationals is set out under Article 696-4, which states
+that extradition shall not be granted when the requested person is a
+national, and
+that nationality shall be assessed at the time of the facts in respect of which extradition
+is sought (« Extradition is not granted: 1° When the person sought has the
+nationality, the latter being assessed at the time of the offence for which extradition is
+requested. »2).
+54. The rule under Article 696-4 only applies "in the absence of an international
+convention stipulating otherwise"". Therefore, we must determine whether the rule
+against the extradition of nationals contained in the
+Code of Criminal
+Procedure applies in respect of an extradition request made by the USA.
+55. Extradition requests between the United States and France are governed by the
+Extradition Treaty between the USA and France 19962°, which supersedes
+law
+as mentioned explicitly in Article 696 of the |
+Code of Criminal Procedure.
+56. Article 3(1) of the Extradition Treaty between France and the United States provides:
+"There is no obligation upon the Requested State to grant the extradition of a
+person who is a national of the Requested State, but the executive authority of the
+United States shall have the power to surrender a national of the United States if.
+in its discretion, it deems it proper to do so. The nationality of the person sought
+shall be the nationality of that person at the time the offense was committed".
+17 In
+: « L'extradition n'est pas accordée : 1° Lorsque la personne réclamée a la nationalité française, cette
+dernière étant appréciée à l'époque de l'infraction pour laquelle l'extradition est requise ».
+1% Article 696 of the
+Code of Criminal Procedure: "In the ahsence of an international convention stipulating
+atherwise, the conditions, procedure and effects of extradition shall be determined by the provisions of this chapter.
+These provisions shall also apply to matters which would not have been regulated by international conventions". (In
+_ « En l'absence de convention internationale en stipulant autrement, les conditions, la procédure et les
+effets de l'extradition sont déterminés par les dispositions du présent chapitre. Ces dispositions s'appliquent
+également aux points qui n'auraient pas été réglementés par les conventions internationales »).
+29 The Extradition treaty between the USA and France was signed in Paris on April 23, 1996 and entered into force
+on February 1, 2002 (by Decree No. 2002-117 of 29 January 2002).
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+wj@wjavocats.com
+www.wjavocats.com - palais C1652
+17
+EFTA02829935
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 19 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+57. If extradition is refused solely on the basis of the nationality of the person sought, Article
+3(2) requires the requested State to submit the case to its authorities for prosecution, if
+so requested by the requesting State.
+58. Consequently, the Extradition Treaty between France and the USA does not
+contain any prohibition on the extradition of nationals. Instead, it merely states that
+there is no obligation upon the requested State to grant the extradition of a person who
+is one of its nationals.
+59. The Extradition Treaty between France and the USA must therefore be distinguished
+from several international agreements on extradition ratified by France, which, by
+contrast, contain a clear rule against the extradition of
+citizens?.
+60. For example, France has made the following declaration pursuant to Article 6 of the
+European Convention on Extradition 1957, which gives Contracting States "the right to
+refuse extradition of nationals":
+"Extradition shall be refused when the person sought had
+of the alleged offence"!.
+nationality at the time
+61. Therefore, France does not surrender
+Extradition 2
+citizens under the European Convention on
+62. The Extradition Treaty between France and the USA is similar to other international
+agreements signed by France which also do not contain a prohibition against the
+extradition of nationals. These are generally treaties signed with Common law
+jurisdictions, which do not oppose the extradition of their nationals"3
+30 See, for example, the Extradition treaty between France and Morocco, or the Extradition treaty between France
+and China.
+"' See France's instrument of ratification of the European Convention on Extradition, deposited on 10 February
+1986.
+32 The European Convention on Extradition 1957 is an instrument of the Council of Europe which was signed in
+Paris on December 13", 1957 and came into force on April 18', 1960. The European Convention on Extradition
+is open to signature by non-Council of Europe States, as such it was ratified by South Africa, Israel, and the
+Republic of Korea. It was ratified by France on February 10°, 1986.
+' For example, the Extradition Treaty between France and Canada, signed in Ottawa on 17 November 1988,
+contains a similar provision to the United States Treaty: "The requested State shall not be bound to extradite its
+own nationals. Nationality shall be determined as of the date of the offence for which extradition is requested"
+(Article 3).
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+18
+EFTA02829936
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 20 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+63. The wording of these international agreements, which do not contain a prohibition on
+the extradition of nationals, raises some important questions. In particular, could France
+decide to extradite its nationals on the basis of these international agreements without
+violating applicable international law, European law, or
+constitutional law?
+64. In order to determine whether the
+government may grant an extradition request
+relating to a l
+citizen under the Extradition Treaty between France and the USA, it
+is thus necessary to evaluate the strength and status of the prohibition of the extradition
+of nationals under (i) applicable international law, (ii) European law, and (iii) L
+constitutional law.
+International law
+(i)
+65. As outlined, international treaties pertaining to extradition generally leave Contracting
+States a right not to extradite their nationals, and State practice largely varies in this
+regard. Some States are strongly committed to the rule against the extradition of nationals
+and have conferred the principle constitutional status (Germany, Poland, Greece,
+Portugal, Estonia, Austria). Others have codified the principle in their national legislation
+(France, Lebanon, Chili, Qatar, Slovenia). By contrast, many States - in particular,
+Common law jurisdictions, including the United Kingdom, Australia, and the USA,
+extradite their own citizens.
+66. Thus, there is no uniform rule regarding the extradition of nationals under international
+law.
+(ii)
+European law
+67. European law does not prohibit the extradition of nationals either. As mentioned, Article
+6 of the European Convention on Extradition 1957 provides States with a discretionary
+right on whether or not to extradite their own citizens.
+68. More interestingly, the European Arrest Warrant Framework Decision of 13 June 2002
+(hereafter, "EAW FD"), which governs extradition matters between Member States of
+the European Union, does not allow Member States the possibility to refuse the surrender
+of their nationals when the EAW is issued for the purpose of conducting a criminal
+prosecution. In fact, the surrender of a national who is the subject of criminal proceedings
+in another Member State of the European Union is at the cornerstone of the EAW FD.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+19
+EFTA02829937
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 21 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+69. Articles 3 and 4 of the EAW FD set out a number of grounds for refusing the enforcement
+of a EAW, that are respectively mandatory and optional. Article 4(6) on optional grounds
+provides that a Member State may refuse the execution of a EAW « issued for the
+purposes of execution of a custodial sentence or detention order, where the requested
+person is staying in, or is a national or a resident of the executing Member State and that
+State undertakes to execute the sentence or detention order in accordance with its
+domestic law ». This article is the only provision in the EAW FD that allows Member
+States to consider nationality in the execution of a EAW. As such, nationality can only
+act as a bar to the execution of a EAW issued for the purpose of executing a custodial
+sentence, not conducting a criminal prosecution.
+70. It follows that European Union law does not prohibit the extradition of nationals.
+(ili)
+constitutional law
+71. As regards the status of the protection of nationals from extradition under
+law,
+the fact that France did not have to change its Constitution or domestic laws regarding
+the extradition of nationals to incorporate the EAW FD effectively means that the
+prohibition against the surrender of a
+citizen to foreign authorities does not
+constitute an absolute prohibition per se under
+law34
+72. The Conseil Constitutionnel (
+constitutional Court) has long considered that France
+could not ratify an international amendment which went against the Constitution, thereby
+necessitating a modification of the text of the Constitution prior to the ratification of the
+purported international treaty. For example, the Constitution had to be amended prior to
+the ratification of the Rome Statute, to create an exception to the rule that the President of
+the Republic cannot be found criminally liable in respect of acts committed during his
+mandate. By contrast, the provisions of the Rome Statute which require Contracting Parties
+to surrender their nationals when the jurisdiction of the International Criminal Court is
+established did not trigger an amendment to the
+] Constitution. Like the EAW FD,
+the example of the Rome Statute must be taken as evidence that there is no constitutional
+principle against the extradition of nationals in France.
+34 By contrast, several Member States of the EU such as Germany, Poland or Cyprus, had to amend their national
+constitutions prior to incorporating the EAW FD, following constitutional courts' rulings.
+35 Décision No. 98-408 DC, 22 Janvier 2009.
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+20
+EFTA02829938
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 22 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+73. The Conseil d'Etat was once asked by the
+government to deliver an opinion
+precisely on this point. It stated that the government's practice of refusing the extradition
+of nationals "finds no basis in a principle of constitutional value. None of the rights and
+liberties of the citizen, as proclaimed by the Declaration of the Rights of Men and
+Citizens of 1789 and by the preamble of the Constitution of 1946, implies that nationals
+cannot be extradited [...] No doubt the laws adopted and the international conventions
+signed by France attest to the authority of the rule that nationals are not extradited. But,
+in support of this rule, there are no grounds for considering it as a fundamental principle
+recognized by the laws of the Republic, having constitutional value by virtue of the
+Preamble to the Constitution of 1946. »3
+74. Therefore, the
+citizens.
+Constitution does not prevent the executive from extraditing
+75. It follows from this opinion and the above that the decision to apply the principle against
+the extradition of nationals is a matter for the executive, which could choose not to
+enforce it and thus choose to extradite a national without violating|
+constitutional
+law, European law or international law, taking into account the provisions of the
+Extradition Treaty between the USA and France of 23 April 1996 which supersede
+law and do not prohibit the extradition of
+nationals.
+Conclusion
+76. In the event that Ms Ghislaine Maxwell were to flee to France and become the subject
+of an extradition request, and where she has already executed an irrevocable waiver of
+her right to contest extradition, the Investigating Chamber would have to rule on the
+legality of the extradition request in accordance with the procedure described in Part I.
+Because the extradition of
+nationals is not prohibited by the Constitution or the
+Extradition Treaty between the USA and France, the Investigating Chamber would not
+be legally bound to oppose to the extradition request. It would then become a matter for
+the
+government to decide on whether or not to issue an extradition decree against
+Ms Ghislaine Maxwell.
+77. In the recent past, I am not aware that the
+situation in which the United States sought extradition of a
+authorities have had to address the
+citizen who was also
+36 « Avis Consultatif, Conseil d'Etat, 24 November 1994, No. 356-641 », available at https://www.conseil-
+etat.fr/jadefile/avisadm/356641.pdf
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com -
+21
+EFTA02829939
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 23 of 30
+William JULIÉ
+avocat à la cour - attorney at law
+a United States citizen. Thus, there is no precedent to draw from in that
+regard. However, it is our view that under the specific and unique facts of this case, it is
+highly unlikely that the
+government would refuse to issue and execute an
+extradition decree against Ms Maxwell because of several critical factors.
+78. First, under the applicable Extradition Treaty between the USA and France, a State party
+may refuse extradition on the basis of nationality, however if it does so, it is obliged to
+prosecute the requested person itself, on the basis of the conduct and the allegations
+contained in the request. In the case of Ms Ghislaine Maxwell, it is highly unlikely that the
+government would be inclined to conducting such prosecution, considering that all
+the relevant facts were committed in the USA, a long time ago, and that witnesses are also
+located in the USA.
+79. Secondly, France is mindful to preserve its good extradition relations with the United
+States, as evidenced by a number of recent cases we reviewed or conducted in which
+competent authorities proved highly cooperative with US authorities. If Ms
+Ghislaine Maxwell were to flee to France, and the USA decided to issue an extradition
+request, it would be difficult for
+authorities - from a diplomatic point of view - to
+deny such an extradition request, considering that no legal bar applies.3?
+80. Thirdly, the fact that Ms Ghislaine Maxwell also holds American nationality, and has
+substantial ties to the USA, would, in all likelihood, be taken into account by the
+government as one more element weighing in favor of extradition.
+81. Similarly, and fourthly, the fact that Ms Ghislaine Maxwell signed a legally binding
+Waiver under US law, and would have subsequently fled to France in violation of her bail
+conditions, could equally be taken into account by the
+I government as an incentive
+not to grant Ms Ghislaine Maxwell the benefit of her
+nationality as a ban to
+extradition.
+William Julié
+51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81
+www.wjavocats.com - palais C1652
+wj@wjavocats.com-
+22
+EFTA02829940
+
+Case 1:20-Cr-00330-AJN Document 97-22 Filed 12/14/20 Page 24 of 30
+Exhibit A
+EFTA02829941
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 25 of 30
+WILLIAM JULIE
+AVOCAT
+51, rue Ampère, 75017 Paris
+Date of birth: 16.07.1973
+English and German national
+Set up my own practice in 2002
+Marathon Runner (Paris, 2013, 2h57)
+0033678374713
+wj@wjavocats.com
+www.wjavocats.com
+EMPLOYMENT
+Since 2002
+Founding partner of William Julié Avocats
+INTERNSHIPS & LAW STUDIES
+2000-2002
+Internships specialized in human rights and criminal law:
+•
+Henri Leclere (President of the
+_Ligue des Droits de l'Homme)
+•
+Eric Plouvier (Human Rights barrister)
+2000
+1999
+Admitted to the Paris Bar
+Postgraduate Specialization Diploma: Criminal Law and Criminal Justice
+Policy in Europe
+Thesis Supervisor Mme Delmas Marty, University of Paris Sorbonne
+1999
+Certificate of criminal sciences, University of Paris Assas
+EXTRADITION LAW
+•
+Extradition cases in and outside the EU, including USA, Saudi Arabia, China, Russia,
+South Korea, Japan, Irak, Iran, Lebanon, India
+•
+Regularly appears as
+judicial expert before Common law courts on extradition issues
+and prison detention conditions (UK, Hong Kong, USA)
+• Mutual legal assistance: cooperation with various investigation authorities on international
+cases (DEA, FBI, SFO, OCTRIS), cross-border penitentiary law (repatriation)
+• Obtained in 2017 a major change in L
+extradition law (right to challenge European arrests
+warrants issued against foreigners - Michael Ofsowitz case)
+CRIMINAL LAW
+• Testified before the Parliamentary Enquiry into miscarriages of justice during the Outreau trial
+• Fraud cases, including Emmanuel Henning 40 million pounds mobile phone VAT fraud in the
+UK, and Marseilles 385 Million carbon gas fraud
+• Business criminal law (money laundering, bribery and corruption, misappropriation of public
+funds, misuse of company assets, offenses related to public tenders,
+exchange law)
+• Important drug cases involving international issues and organized crimes (Morocco, Lebanon,
+Holland, Germany, GB), including 4 tons cocaine Tobago clipper case
+EFTA02829942
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 26 of 30
+LEGAL ADVICE
+• Presidential party members and officials in Dakar, Senegal
+• Former Tunisian Ambassador in Paris and prominent Tunisian diplomats
+• Members of the family of Saudi Arabia
+• Members of leading Lebanese political party
+• Opposition leaders in Irak and Lybia
+• Italian State
+MEMBERSHIPS
+• International criminal law Officer of the IBA (International Bar Association)
+• Member of DELF (Defense extradition Lawyers Forum, UK)
+• Co-Chair of the criminal committee of the corporate firms lawyers association (France)
+• Member of the ECBA (European Criminal Bar association)
+• Member of the Franco British Lawyers Society
+EFTA02829943
+
+Case 1:20-Cr-00330-AJN Document 97-22 Filed 12/14/20 Page 27 of 30
+Exhibit B
+EFTA02829944
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 28 of 30
+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, Mark S.
+Land 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
+EFTA02829945
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 29 of 30
+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.
+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 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
+EFTA02829946
+
+Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 30 of 30
+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
+EFTA02829947

vision-joined/court-04/b2204cdb8dbda93381145ad2017e0180cc3964ca85884c4354287adca111d563.json

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vision-joined/court-04/b2204cdb8dbda93381145ad2017e0180cc3964ca85884c4354287adca111d563.md

@@ -0,0 +1,140 @@
+Case 1:20-cr-00330-PAE Document 355
+Filed 10/18/21 Page 1 of 5
+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
+October 18, 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, New York 10007
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+The Government respectfully submits this letter pursuant to the Court's Order dated
+October 14, 2021 (Dkt. No. 343) directing the Government to respond to the defendant's motion
+for an order granting limited counsel-conducted voir dire and individual sequestered voir dire (Dkt.
+No. 341).
+I.
+Attorney Voir Dire Is Not Warranted
+None of the defendant's arguments warrant departing from the well-settled practice in this
+District of Court-led voir dire. The Court is well-equipped to thoroughly question prospective
+jurors and to appropriately filter questions prepared by the parties.
+It is well established that "[a] district court is 'accorded ample discretion in determining
+how best to conduct ... voir dire.'" United States v. Lawes, 292 F.3d 123, 128 (2d Cir. 2002)
+(quoting Rosales-
+v. United States, 451 U.S. 182, 189 (1981)); accord United States v.
+Quinones, 511 F.3d 289, 299 (2d Cir. 2007). As a general matter, "[vJoir dire is necessarily a
+matter in which the trial court has extremely broad discretion," and "federal trial judges are not
+required to ask every question that counsel even all counselbelieves is appropriate." Lawes,
+EFTA02833088
+
+Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page 2 of 5
+Page 2
+292 F.3d at 128; see also United States v. Kyles, 40 F.3d 519, 524 (2d Cir. 1994) (stating that a
+district court has "broad discretion whether to pose a defendant's requested voir dire questions").
+Although the Federal Rules of Criminal Procedure contemplate that district courts may exercise
+that discretion by permitting counsel to conduct the questioning of potential jurors, see Fed. R.
+Crim. P. 24(a), the usual practice is for the court to conduct its own questioning, and federal courts
+generally have resisted efforts by counsel to expand their own role. See, e.g., Lawes, 292 F.3d at
+128 (noting the "long struggle between bench and bar" over juror questioning and observing that
+"federal courts have successfully resisted such attempts" by counsel to have a greater role). Courts
+are generally resistant to such efforts because "Ic Jourt and counsel have somewhat different goals
+in voir dire." Id. As the Second Circuit has observed:
+The court wants a fair and impartial jury to be chosen and to move
+expeditiously to the presentation of evidence. Counsel want a jury
+favorable to their cause-—fair or not—and voir dire aids them in
+exercising
+peremptory challenges and challenges for cause.
+Counsel have an additional purpose in voir dire moreover and that
+involves exposing jurors to various arguments they intend to make
+at trial. Counsel view voir dire as an opportunity for advocacy
+similar to, albeit not the equivalent of, openings or summations.
+Id.; see also United States v. Barnes, 604 F.2d 121, 138 (2d Cir. 1979) ("IT]he purpose of the voir
+dire is to ascertain disqualifications, not to afford individual analysis in depth to permit a party to
+choose a jury that fits into some mold that he believes appropriate for his case." (quotation marks
+and citation omitted)).
+The defendant offers no persuasive reason to abandon the customary practice in this
+District,' and of federal courts generally, and to adopt an alternative procedure for this case. The
+' See, e.g., United States v. Saipov, No. 17 Cr. 722 (VSB), 2020 WL 958527, at *1 (S.D.N.Y. Feb.
+27, 2020) (rejecting defendant's arguments for attorney conducted voir dire in capital case)
+United States v. Barone, No. 09 Cr. 91 (NRB), 2010 WL 2976505, at *1 (S.D.N.Y. July 9, 2010)
+(declining to permit attorney-conducted voir dire); United States v. Wilson, 571 F. Supp. 1422,
+EFTA02833089
+
+Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page 3 of 5
+Page 3
+defendant claims that because this case has received significant pretrial publicity and the charges
+involve a "sensitive subject matter," the Court "should grant a limited period of attorney-conducted
+voir dire after the Court's general voir dire," but she does not identify what information she
+believes that her attorneys would be more capable of discovering than the Court. (Dkt. No. 342 at
+1, 10). Even if counsel identify specific or additional issues the defendant believes her attorneys
+should be able to explore in light of, as the defendant claims, the attorneys' "more in-depth
+knowledge of the case" (id. at 11), counsel are free to propose additional questions that the Court
+may ask, and the Court is in the best position to consider whether such inquiry is appropriate and,
+if so, how to pose such questions in a way that is fair to the interests of all parties and the potential
+jurors. Even if counsel attempt to ask their additional questions in an even-handed way, counsel
+may easily and inadvertently step over the line and significantly prejudice the other side. See
+Saipov, 2020 WL 958527, at *1 (holding that court-conducted voir dire "assures that the parties
+do not stray into impermissible areas that could potentially taint the prospective jurors answers or
+point of view [and] permits each party the opportunity to evaluate the questions proposed by their
+adversary").
+The defendant claims that "questioning conducted exclusively by the Court further
+hampers the ability to uncover important information about jurors because it places jurors in a
+subordinate position heightening their reluctance to be candid." (Dkt. No. 342 at 13). The
+defendant's motion does not expand upon this conclusory assertion, but instead cites "research"
+that appears to broadly recommend in-depth voir dire. (Id. at 13-14). But there is no reason to
+1428 (S.D.N.Y. 1983) (rejecting defense request for attorney-conducted voir dire and noting that
+court-conducted voir dire has resulted in the "empanelling of fair and impartial juries"; "And this
+has been true of cases that have attracted in advance of trial the widest publicity in the news media
+over extended periods of time.").
+EFTA02833090
+
+Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page 4 of 5
+Page 4
+believe that counsel will be better than the Court at identifying bias, nor that counsel will be more
+interested than the Court in removing biased jurors. Indeed, it is unlikely that attorney-led
+questioning will yield a significant change in the candidness and openness of prospective jurors if
+the Court also limits those questions to one minute per juror, as the defense also proposes. (Id. at
+14). Given that prospective jurors are likely to "respond honestly to questions directed to them by
+a federal judge," Saipov, 2020 WL 958527, at *1, Court-led voir dire remains appropriate in this
+case.
+Accordingly, the Government respectfully submits that the well-established practice in this
+District of Court-led voir dire should be followed. Counsel can address potential bias by proposing
+questions for the Court to ask (as it already has) and engaging in the strike process, as is customary
+and appropriate here.
+II. Individual "Sequestered" Voir Dire Is Not Warranted
+The Government respectfully submits that the well-established practice in this District
+should be followed; that is, the Court should ask most questions in open court and ask sensitive
+questions, such as those that relate to sexual abuse and media exposure, at sidebar. The defendant
+argues that individual sequestered voir dire is necessary in light of the nature of the charges in this
+case, which she claims are "particularly inflammatory and of great concern to communities from
+which jurors are drawn," and her concern that "a discussion of pretrial publicity in front of the
+entire jury pool will contaminate those few jurors who have not been subjected to the publicity."
+(Dkt. No. 342 at 8-9). Of course, under the typical practice in the District, prospective jurors would
+not be asked to describe their experiences with sexual assault or the details of pretrial publicity in
+front of the rest of the venire. That questioning would happen at sidebar, in an "individual,
+sequestered" setting. But not every prospective juror may need additional questions on those
+EFTA02833091
+
+Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page 5 of 5
+Page 5
+topics, and other topics can safely be discussed in the group setting. Accordingly, it is more
+efficient to conduct voir dire following the usual practice in this District.
+Respectfully submitted,
+DAMIAN |
+United States Attorney
+By: _
+/s
+Alison Moe
+Lara Pomerantz
+Andrew Rohrbach
+Assistant United States Attorneys
+Southern District of New York
+Cc: Defense counsel (By ECF)
+EFTA02833092

vision-joined/court-04/b23aae1490e1365c21987a9f5b5ee864a37cadb9f33228b8c6c4f8ca9196a115.json

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vision-joined/court-04/b23aae1490e1365c21987a9f5b5ee864a37cadb9f33228b8c6c4f8ca9196a115.md

@@ -0,0 +1,72 @@
+Case 1:15-cv-07433-LAP
+Document 219
+Filed 06/16/16
+Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Plaintiff,
+-against-
+Ghislaine Maxwell Defendant.
+15 c...
+07433 (RWS)
+MOTION FOR ADMISSION
+PRO HAC VICE
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern
+Districts of New York, 1
+Gregory I. Poe
+hereby move this Court
+for an Order for admission to practice Pro Hac Vice to appear as counsel for
+Non-party Jeffrey Epstein
+in the above-captioned action.
+1 am in good standing of the bar(s) of the state(s) of
+the District of Columbia
+Land there are no pending disciplinary proceedings against
+me in any state or federal court.
+Dated:
+Respectfully Submitted,
+Applicant Signature
+Applicant's Name:
+Gregory I. Poe
+Firm Name: Lamp
+Law Offices of Gregory I. Poe PLIC
+Address: 1030 15th St., NW, Suite 580W
+City / State / Zip: Washington, DC 20005
+Telephone / Fax: 202-583-2500
+E-Mail:_
+gpoe@gpoelaw.com
+EFTA02798296
+
+Case 1:15-cv-07433-LAP Document 219 Filed 06/16/16 Page 2 of 2
+CERTIFICATE OF SERVICE
+I hereby certify that, on this 16th day of June, 2016, I caused a true and correct copy of
+Gregory L. Poe's Motion for Admission Pro Hac Vice and supporting documents to be served via
+the Court's CM/ECF system on the following:
+Sigrid S. McCawley
+Meridith
+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
+1. JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L
+425 North Andrews Ave., Ste. 2
+Ft. Lauderdale, FL 33301
+brad@pathtojustice.com
+Laura A. Menninger
+Jeffrey S. Pagliuca
+HADDON, L
+AND
+150 East 10th Avenue Denver, CO 80203
+Phone: 303.831.7364
+Fax:
+303.832.2628
+Imenninger@hmflaw.com
+. P.C.
+/s/ Rachel S. Li Wai Suen
+Rachel S. Li Wai Suen
+EFTA02798297

vision-joined/court-04/b23cad2b950b14652ca08d4decd3c4bc953cfa32dde828d037ece2dfdc32da4b.json

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vision-joined/court-04/b23cad2b950b14652ca08d4decd3c4bc953cfa32dde828d037ece2dfdc32da4b.md

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+Case 1:15-cv-07433-LAP Document 317 Filed 08/01/16 Page 1 of 4
+Case 1:15-cv-07433-RWS Document 302 Filed 07/25/16 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+-X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+--X
+PROPOSED DISCOVERY AND CASE MANAGEMENT DEADLINES AND
+REQUEST TO MODIFY PRETRIAL SCHEDULING ORDER
+R
+ECEIVE
+wL 292919
+JUDGE SWEET
+=
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:
+DATE FILEN: 811110
+EFTA02799670
+
+Case 1:15-cv-07433-LAP Document 317 Filed 08/01/16 Page 2 of 4
+Case 1:15-cv-07433-RWS Document 302 Filed 07/25/16 Page 2 of 4
+The Parties, through their respective counsel, propose the following discovery and case
+management deadlines and request that the Court enter an order modifying its Order filed
+October 30, 2015, ECF #13, for the following reasons:
+The parties have been actively engaged in completing fact discovery in this case. On
+June 23, 2016 the Court extended the time to complete non-expert fact discovery to July 29,
+2016. At that time the Court recognized that the extension of fact discovery depositions would
+impact other deadlines in the case and directed that the parties confer regarding a proposed
+modified scheduling order.
+Various discovery motions are pending and it is unlikely that those motions will be
+resolved before the close of fact discovery. In addition, it is anticipated that certain depositions
+may need to be scheduled after July 29, 2016 to accommodate the schedules of counsel and the
+witnesses. The parties anticipate that there will be a number of legal issues that will need to be
+addressed prior to trial.
+Accordingly, in an attempt to fashion a schedule that allows the parties and the Court to
+efficiently manage outstanding discovery and legal issues the parties propose the following
+schedule:
+Pursuant to this Court's Order of June 23, 2016, the parties have conferred and, subject to
+the Court's approval and availability propose the following schedule:
+The tentative jury trial scheduled for October 17, 2016 be rescheduled to begin on
+December 12, 2016;
+Fact depositions shall be completed by July 29, 2016 unless otherwise agreed to by the
+parties or for good cause shown;
+Expert Disclosures per 26(a)(2)(A) and (B) shall be made by August 31, 2016;
+Expert Disclosures per 26(a)(2)(D) shall be made by September 30, 2016;
+Expert depositions shall be concluded by October 14, 2016;
+Dispositive Motions and 702 Motions shall be filed by October 28, 2016;
+Initial designation of deposition testimony to be used at trial shall be made by November
+10, 2016;
+Objections to deposition designations shall be filed by November 21, 2016;
+Counter-designations to initial deposition designations shall be made by November 21,
+2016;
+Motions in Limine/other motions shall be filed by November 21, 2016;
+1
+EFTA02799671
+
+Case 1:15-CV-07433-LAP Document 317 Filed 08/01/16 Page 3 of 4
+Case 1:15-cv-07433-RWS Document 302 Filed 07/25/16 Page 3 of 4
+The Joint Pre-trial Order shall be submitted by November 21, 2016;
+Objections to any counter-designations shall be made by November 30, 2016;
+Proposed agreed upon/disputed Jury Instructions and Verdict forms shall be submitted by
+November 30, 2016;
+Proposed jury questions shall be submitted by November 30, 2016.
+WHEREFORE, the parties request that the Court adopt the proposed schedule and
+modify the Court's Order of October 30, 2015 to reflect the above deadlines.
+Dated: July 25, 2016
+Respectfully submitted,
+1 JAFFE, WEISSING, |
+FISTOS & LEHRMAN, P.L.
+425 North Andrews Ave., Ste. 2
+Ft. Lauderdale, FL 33301
+brad@pathtojustice.com
+Attorney for
+Is/ Jeffrey S. Pagliuca
+Laura A. Menninger (LM-1374)
+Jeffrey S. Paeliuca (pro hac vice)
+HADDON, I
+LAND
+_ P.C.
+150 East 10" Avenue
+Denver, CO 80203
+Phone: 303.831.7364
+Fax:
+303.832.2628
+Imenninger@hmflaw.com
+Attorneys for Ghislaine Marwell
+2
+EFTA02799672
+
+Case 1:15-CV-07433-LAP Document 317 Filed 08/01/16 Page 4 of 4
+Case 1:15-cv-07433-RWS Document 302 Filed 07/25/16 Page 4 of 4
+CERTIFICATE OF SERVICE
+I certify that on July 25, 2016, I electronically served this PROPOSED DISCOVERY AND
+CASE MANAGEMENT DEADLINES AND REQUEST TO MODIFY PRETRIAL SCHEDULING
+ORDER via ECF on the following:
+Sigrid S. McCawley
+Meridith
+BOIES, SCHILLER & FLEXNER, LLP
+401 East Las Olas Boulevard, Ste. 1200
+Ft. Lauderdale, FL 33301
+smccawley@bsfllp.com-
+mschultz@bsfllp.com
+JAFFE, WEISSING, I
+FISTOS & LEHRMAN, P.L.
+425 North Andrews Ave., Ste. 2
+Ft. Lauderdale, FL 33301
+brad@pathtojustice.com
+Paul G. Cassell
+S.J. Quinney College of Law, University of
+Utah
+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
+EFTA02799673

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vision-joined/court-04/b244c965c6b4102aca05a115fdaeff53c83e153e7749d9e93b76450e0580857a.md

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+Case 1:15-cv-07433-LAP Document 690-1 Filed 03/03/17 Page 1 of 1
+COMPOSITE
+EXHIBIT 1
+(FILE UNDER SEAL)
+EFTA02802554

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+}

vision-joined/court-04/b26b0de732efefe400b5918e001dcd221aa9894915278d0d7630b02428f6ca89.md

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+Case 1:15-cv-07433-LAP Document 1331-33 Filed 01/05/24 Page 1 of 3
+EXHIBIT G
+EFTA02794999
+
+A Home
+YAHOO!
+MAIL
+E Compose
+Add Gmail, Outicok,
+AOL and more
+Inbox (3993+)
+Drafts (7)
+Sent
+Archive
+Spam (115)
+Trash
+• Smart views
+Important
+Unread
+Starred
+Al
+FW:
+Saran se
+CONFIDEN HAI
+irom ny (6)
+Search web
+Home
+03/02/07 at 1:04 AM
+Ramina H
+To:
+Sent: Feb 2
+Subject: Fw
+от пу
+Tol
+Sen
+Subject:
+6:58 PM
+rom ny
+Hey Sarra
+Miss u Wanted to see how things r going wu. Hope ur having a good time in UK...Wanted to
+contact u for a while but didn't have ur email
+I am good Pretty busy but productive
+Write back let me know what ur up to... When ru gonna b ready for south africa trip and then
+miami hopefully U lucky gin :) ... Anyways don't disappear Write back Let me know what ur up to
+Hugs and Kisses
+Natalie
+Sent via BlackBerry from Cingular Wireless
++ Reply
+• Reply to All → Forward ** More
+Important
+Unread
+Starred
+People
+Social
+Shopping
+Travel
+Finance
+} Folders
+7 Recent
+04/02/07 3t-4:91PM *
+05/02/07 at 10:09 PM *
+06/02:07 al 2:00 AM *
+08/02/07 at 5:12 PM *
+08-0207 at 9:22 FM *
+Hey Sweetie
+Glad to hear ur doing th
+mail something to me?
+Hugs and kisses Natalie
+Sent via BlackBerry from Cingular Wireless
+for fil When ra planning to come to ny? Did u need my adress to
+Don't worry about fight w J
+From
+To:
+Date: Thu, 8 Feb 2007 12:12:3
+Subject: Re: Re: Fw: Natalie from ny
+Hey sweetie
+How are you?l am busy writing my essay for
+FIT. What funcHad a bit of a fight with Jeffrey
+well what can you do?l ment to ask you in my last
+email, can you please emal me your address? Looks
+like I am not going to Miami ether Well at least 1
+will be back in NY. Hope you are well and lock forward
+to seeing you soon. Please tell Jenifer I say hi
+Lots of hugs and kisses
+EXHIBIT
+Oft 9
+2117/17
+JEREMY RICHMAN
+Need Mail bonding?
+EFTA02795000
+
+Case 1:15-cv-07433-LAP
+• Home
+Document 1331-33
+Calebrity
+Style
+Weather
+Filed 01/05/24
+Answers
+Flickr
+Mobile
+Page 3 of 3
+YAHOO!
+MAIL
+All
+E Compose
+Add Ornail, Outice
+AOL and more
+Inbox (9909+)
+Drafts (7)
+Sent
+Archive
+(115)
+Trash
+~ Smart views
+important
+Unread
+Starred
+People
+Social
+Shopping
+Travel
+Finance
+Important
+Unread
+Starred
+People
+Social
+Shopping
+Travel
+Finance
+3 Folders
+• Recent
+Pranch "tai
+CONFIDENT
+Search web
+Trom n (6)
+03/02/07 st 1:01 AM
+Original Messag
+Subject: F
+5:58 PM
+rom ny
+Miss u Wanted to see how things r going wu. Hope ur having a good time in UK. Wanted to
+contact u for a while but didn't have ur email
+I am good Pretty busy but productive
+Write back let me know what ur up to... When ru gonna b ready for south africa trip and then
+miami hopefully U lucky girl 3 .. Anyways dont disappear Winte back Let me know what ur up to
+Hugs and Kisses
+Natalie
+Sent via BlackBerry from Cingular Wireless
++ Reply
+4 Reply to All Forward *** More
+01/02/07 al 4:01 PM *
+didgred
+Finding fabulous fares is fun.
+Let Yshool FareChase search your favorite travel sites to find fight and hotel bargains.
+* Reply Reply to All → Forward *** More
+05/02:07 a 10:09 PM *
+Hey Natale
+It was Great to here from you. replied yesterday but
+the whole email got deleted somehow when I pressed
+send. I was super irritated. Everything is going well
+here. In south Alrica and i have to say it is
+wonderful being with my family. I will take lots and
+lots of photos to show you where 1 come from.
+Still determined about going to Miami and then
+studying in NY. I wil be leaving here on the 27th and
+then meeting up with Jeffey where ever he may be...
+Well that is the plan as far as i know. I do however
+need to phone him this week. I am getting a bif
+nervous about evetthing now. diet is still going well
+1am 57 kg now, I however dont want to loose anymore.
+Hav you started gymn yet. You will definitly have a
+partner when I get back. Spoaking of which have you
+found a super nice man yet? My beautiful friond you
+deserve the best. So what else is happening? Are you
+still doing your intemship and how is that going?
+Babes 1 really miss you and 1 am so happy that you
+emailed me. Hope to hear from you soon.
+Lots of hugs and kisses
+EFTA02795001

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vision-joined/court-04/b283d604b4db6db0c866bc8f7d33c54f60ee107c82cdba5deae6d8fb4a54c0b2.md

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+Case 1:20-cr-00330-PAE |
+Document 427 Filed 11/09/21 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOCH:_
+DATE FILED: 11/9/21
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+ORDER
+Defendant.
+ALISON J. NATHAN, District Judge:
+Attached is the Court's revised draft preliminary remarks to be recorded and played
+before each voir dire session. The Court is in receipt of the Government's letter approving of the
+remarks, Dkt. No. 420, and the Defendant's proposed additions, Dkt. No. 419. The revised
+remarks adopt all but one of the Defendant's proposals because the Court's subsequent revisions
+eliminated that portion of the script. In particular, the Court has made three additional changes
+in order to accurately explain the logistics of voir dire. Each of these changes is reflected in
+redline.
+The parties are ORDERED to indicate by letter on or before November 11, 2021 at 12:00
+p.m. whether or not they have any objections or suggestions the Court's revised preliminary
+remarks to be played before each voir dire session.
+Attached is also the Court's revised draft voir dire in redline. The Court's revisions
+simplify the phrasing of questions 1, 2, 3, 10, 13, 25, and 37 in an effort to maximize the time
+dedicated to questioning each prospective juror. The revision to question 11 reflects the Court's
+oral ruling on November 1, 2021 regarding the use of pseudonyms for certain witnesses. The
+revisions to questions 9, 13, 14, 15, 20, 21, and 33 are non-substantive changes to question
+1
+EFTA02834150
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 2 of 16
+numbers in order to accurately reference the corresponding question numbers on the jury
+questionnaire or are grammatical changes.
+Attached is also the Court's draft instruction sheet for those jurors who are not struck for
+cause and will return for the exercise of peremptory strikes, as discussed at the November 1
+conference.
+The parties are FURTHER ORDERED to indicate by letter on or before November 12,
+2021 whether or not they have any objections or suggestions to the revised voir dire and draft
+instruction sheet.
+Finally, the parties are ORDERED to jointly submit the list of individuals and locations
+who may be mentioned at trial for questions 11 and 12 of the voir dire on or before November
+14, 2021.
+SO ORDERED.
+Dated: November 9, 2021
+New York, New York
+Alia Q. Notor
+ALISON J. NATHAN
+United States District Judge
+2
+EFTA02834151
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 3 of 16
+Draft Pre-Voir Dire Remarks - November 8, 2021
+2
+United States v. Maxwell, 20cr330
+Preliminary Remarks Prior to Voir Dire
+To be recorded and played on 11/16-11/19
+4
+Introduction
+5
+Welcome back to the Southern District. Thank you again for your time and service. As I
+6
+mentioned in my remarks to you when you filled out the questionnaire, I'm Judge Nathan and I
+7 am the judge who will preside over this case. The questionnaire you previously filled out was the
+8
+first step in the jury selection process. Today will be the second step. Some of you will be
+• excused today and will not have to return for this case, although you may be directed to go
+10 through a similar process in another case. Others may be directed to return tomorrow-al
+11
+additional day this week if necessary. And ultimately, some of you will return for the third and
+12
+final step in the process. That will take place on November 29.
+13
+In any event, after you complete this step of the process today, you will receive
+14
+instructions on next steps that are particular to you.
+15
+As you know from my prior remarks to you and from the questionnaire, we're here today
+16
+to select a jury to serve in a criminal case, called the United States against Ghislaine Maxwell. As
+17 you read in the questionnaire, the Indictment alleges that Ghislaine Maxwell conspired with and
+18
+aided and abetted Jeffrey Epstein to entice minor females to travel to engage in criminal sex
+19
+activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking
+20
+of a minor. Ms. Maxwell has pled not guilty to all charges. Ms. Maxwell is presumed innocent,
+21
+and before she can be found guilty on any charge, the jury must find that the Government has
+22
+proven each element of that crime beyond a reasonable doubt.
+23
+Thank you for participating in this process. The process of selecting a jury in a criminal
+24
+case is a critical part of our justice system. The purpose of this process is to select those jurors who
+EFTA02834152
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 4 of 16
+can be fair and impartial to both sides in this case. Some people find that they can be fair and
+2 impartial in one kind of case, but for various reasons, related to their own life experiences or views,
+3 can't be fair in another kind of case. The process that we use is designed to help us figure out
+4 whether you can be fair and impartial to both sides in this case.
+5
+If during the course of this process you come to believe that because of something that
+6 you have experienced or because of something you've heard or read that you cannot be fair and
+7 impartial—that is that you would favor either the Government or the Defendant regardless of
+8
+what the evidence shows then you must tell me. It's not unusual, and there's no reason to be
+9 embarrassed about it.
+10
+But the system only works if all of our citizens are willing and prepared to serve as jurors
+11
+when they can do so fairly and impartially. I do not expect that anybody would seek to avoid this
+12 important duty for any but the most compelling reasons.
+13
+As I mentioned in my prior remarks, the Court has taken a number of steps to help ensure
+14
+the process for selected jurors is as safe and easy as possible. We have masking and distancing
+15
+protocols. We have reconfigured courtrooms to enhance safety measures. The Court will
+16
+provide transportation for selected jurors to and from the courthouse each day. Breakfast,
+17
+snacks, and lunch will be provided for you.
+18
+And please note that you are not required to be vaccinated to serve on the jury or required
+19
+to disclose your vaccination status. However, if you are selected to return for the final phase of
+20
+jury selection, a courthouse staff member will ask you before you leave today to fill out a form
+21
+regarding your COVID-19 vaccination status. If you are comfortable disclosing, the information
+22
+will solely be used by courthouse staff to ensure compliance with the District's COVID-19
+23
+distancing protocols. The information will not be provided to the attorneys or anyone involved in
+2
+EFTA02834153
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 5 of 16
+the case, and the information will not affect whether or not you are selected to serve as a juror in
+2
+this case. Finally, the form will be destroyed at the conclusion of trial.
+3
+To conduct the next phase of the process, I will ask each of you some questions
+4 individually. We'll do that in a separate courtroom where 1 and the lawyers and the Defendant
+5 are sitting now. You all will be brought in the courtroom one at a time. Bear in mind that this is
+6 a public courtroom. To protect your privacy, 1 will only refer to you by your juror number.
+7 Please do not state any identifying information. For example, if we talk about your job you
+could say that you are a sales clerk at a large retail store, without stating the specific name of
+9 your employer. This is to protect your privacy. Even with those privacy protections in place, if
+10 there is something that would be too difficult or embarrassing for you to say on the public record,
+11 please let me know. And please keep in mind that if you are selected as a juror, we will continue
+12 to refer to you only by your juror number throughout the process.
+13
+Now, if you are selected as a juror, your job is going to be to listen to the evidence and to
+14
+my instructions on the law and to make a determination that's based only on the law. So I want to
+15 speak to you generally about some things to keep in mind.
+16
+The first thing is, as Ms. Maxwell sits here now, she's presumed to be innocent. She is
+17 presumed innocent until and only if the jury finds that she is guilty beyond a reasonable doubt.
+18
+As I just explained to you, she's been indicted for a number of crimes, but an indictment is just
+19
+an accusation. It is not evidence and it doesn't mean that Ms. Maxwell is guilty of anything. You
+20
+can't assume that she is guilty or more likely to be guilty just because she's been charged in an
+21
+indictment and alleged to have committed the crimes charged. with committing these crimes.
+22
+That's the reason we have trials, to determine whether the Government can prove a defendant's
+23
+guilt beyond a reasonable doubt. A defendant in a criminal case does not have to prove that she
+3
+EFTA02834154
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 6 of 16
+is not guilty. That means a defendant does not have to testify, or to put on any evidence and a
+2 juror can't hold that against a defendant if she makes that choice.
+3
+The next thing is that as jurors you must follow the law as I give it to you, even if you
+4 don't agree with it or if you think the law should be different.
+5
+You also have to base your verdict on the evidence, not on something that you've read in
+6 the newspapers or the internet or seen on television or heard about on social media or in
+7 discussions with friends, family, or colleagues. And you can't base your decision in this case on
+8
+something that you might have read or heard about another case.
+9
+As I said before, there is significant media interest in this case. As jurors you are not
+10 permitted to read any news about this case. You cannot read or watch or listen to any accounts
+11 of this case at all. If you see something in the paper or online, you're just going to have to turn
+the page or close the browser. You can't read it.
+13
+Equally important, you're not permitted to discuss this case with anyone else while the
+14
+case is going on. Even with your fellow jurors, you can't discuss the case until you've heard all
+15
+the evidence and I've given my instructions on the law. Again, that's because you can only
+16
+consider the evidence that you hear in the courtroom, not anything outside of the courtroom. You
+17 have to keep an open mind. Nor may you discuss the case with friends or family until after your
+18
+jury service is complete. You can tell them that you are a juror in a criminal case in federal court
+19
+and that the judge has told you that you are not permitted to say anything further.
+20
+Similarly, until you are excused from jury service, you cannot post anything about your
+21
+experience as a juror on Facebook, Twitter, Instagram, TikTok or any kind of social media.
+22
+Another instruction, you can't look up or google or do any other kind of research or search in any
+23
+manner about anything related to the case or anyone involved in the case.
+4
+EFTA02834155
+
+Case 1:20-cr-00330-PAE
+Document 427 Filed 11/09/21 Page 7 of 16
+The reason for these rules, as I am sure you understand, is they protect the integrity of the
+2 trial and assure that both sides receive a fair trial.
+3
+Jurors in criminal cases base their verdicts on the evidence that they hear in the
+4 courtroom, not on something that somebody else tells you, not on something that you see on TV
+or on social media. That's why if you're selected as a juror, I'll be reminding you of these rules
+6 regularly. You can't watch news accounts, look anything up or speak to anybody else about the
+7
+case. You would be violating the oath you have taken as jurors and you would be violating my
+8
+orders if you were to do that.
+9
+Finally, you must report to me through my court deputy any effort by any person to speak
+10
+with you about the case or to influence you about the case or to get information about the case.
+11
+The attorneys and their assistants have been instructed by me not to speak to you or otherwise
+12
+engage with you. They are not being rude or indifferent. They are merely following my
+13
+instructions.
+14
+I do want to thank all of you for the time you've invested already in this process. Our
+15 system cannot function unless we have good people like you who are willing to give up their
+16
+time and to serve as jurors.
+17
+Please sit quietly until your number is called and you are brought into the courtroom for
+18
+questioning by me. Please follow all the instructions of the courtroom staff. Although you may
+19
+use your eleetronie devices while you are waiting (bearing in mind of course all of my
+20
+instruetions that forbid you to de any research or engage in any communieations about the ease
+21
+through any means), you must turn off' and hand over any electronie devices to the Jury
+22
+Department staff before you are brought into the courtroom. I look forward to meeting each of
+23
+you in person soon. Thank you.
+5
+EFTA02834156
+
+Case 1:20-cr-00330-PAE Document 427
+Filed 11/09/21 Page 8 of 16
+DRAFT - November 8, 2021
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+---- - -
+- - X
+UNITED STATES OF AMERICA
+- V. -
+GHISLAINE MAXWELL,
+Defendant.
+:
+:
+:
+:
+- - - x
+S2 20 Cr. 330 (AJN)
+[DRAFT] EXAMINATION OF PROSPECTIVE JURORS
+EFTA02834157
+
+Case 1:20-cr-00330-PAE |
+Document 427 Filed 11/09/21 Page 9 of 16
+Introductien
+[PLACEHOLDER FOR INTRODUCTORY REMARKS]
+EFTA02834158
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 10 of 16
+INDIVIDUAL QUESTIONS
+Ability to Follow Instructions
+1. As I instructed you earlier, one of the important principles of criminal law is that a
+defendant in a criminal case is presumed to be innocent. Like anyone accused of a crime
+in this country, Ms. Maxwell is; and must be, presumed innocent of any and all charges
+made against her unless and until the Government proves her guilt beyond a reasonable
+doubt. It is the Government's burden to prove guilt beyond a reasenable doubt and the
+Government's burden of proof alone. The defendant has no burden to prove her
+innocence or to present any evidence. Are you able to follow these instructions?
+2. As I instrueted you earlier| also instructed you earlier that - until you are excused from
+this case, you may not consume any media of any kind reports of this case of any
+typeaboutof thisthe case-of any kind time (- including social media), research the case-it
+in any manner, or discuss the caseit with anyone. read, listen to, or watch any accounts of
+this case reported on television, the radio, or over the Internet or social media. Jurers are
+also not allowed to do any research regarding this case, whether over the Internet, on
+social media, or in any other manner. The ease must be decided solely on the basis of the
+evidence presented in the courtroom. Would you have any difficulty following these
+rules, which are binding on every juror?
+3.
+When Since the time you filled out your questionnaire, you were instructed that you
+would have to follow these rules. Have you done so anyway? hHave you failed to
+follow these rules in any way? Such as consuming any social media, googling the case,
+or discussing it-you seen any reports, including on secial media, googled the case, or
+discussed the case with any person you were told not to research, read, or watch anything
+EFTA02834159
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 11 of 16
+about the case or learn anything about the case. Have you, even though you were
+instrueted not to do that, done that anyway? Have you looked things up on the internet,
+even if you just Googled it? If you have, now is the time to tell me.
+General Ability to Serve
+4. On your questionnaire, you stated that you do not have any unmovable commitments
+between November 29 and approximately January 15. Does that continue to be accurate?
+Prior Knowledge of Ms. Maxwell
+5. [If Juror HAS HEARD of Ms. Maxwell] In your questionnaire, you reported that you
+had heard of Ms. Maxwell before starting this process. Have you formed an opinion or
+heard, read, or seen anything about Ms. Maxwell that might make it difficult for you to
+be a fair and impartial juror in this case?
+6. [If Juror HAS NOT heard of Ms. Maxwell] In your questionnaire, you reported that you
+had not heard of Ms. Maxwell before starting this process. Is that accurate?
+Prior Knowledge of Jeffrey Epstein
+7. [If Juror HAS HEARD of Epstein] In your questionnaire, you reported that you had
+heard of Jeffrey Epstein before starting this process. Have you formed an opinion or
+heard, read, or seen anything about Mr. Epstein that might make it difficult for you to be
+a fair and impartial juror in this case?
+8. [If Juror HAS NOT heard of Epstein] In your questionnaire, you reported that you had
+not heard of Jeffrey Epstein before starting this process. Is that accurate?
+EFTA02834160
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 12 of 16
+Nature of Charges
+9. You reported in your questionnaire that [insert question number of any YES answers for
+question 487, 498, or 5049]. Would that experience affect your ability to serve as a fair
+and impartial juror in this case?
+Knowledge of the Trial Participants
+10. In the-your questionnaire, listed the names of all the trial partieipants and you indicated
+that you did not know any of those-the trial participants individuals by name. I'll ask you
+to also-look around now and let me know if you recognize anyone in the courtroom.
+11. I will now read aPlease read this list of individuals who may be mentioned during the trial,
+or who may be witnesses in this case:
+[Names to be supplied]
+Do you know any of those people? Have you had any dealings, direetly or indireetly, with
+any of these individuals? To your knowledge, have any of your relatives, friends, or
+associates had any dealings with any of these individuals?
+Knowledge of Location
+12. Events in this case are alleged to have taken place at the following locations:
+[List to be supplied]
+Are you particularly familiar with any of those locations?
+Prior Jury Service
+13. [For jurors who answered YES to question 187] On your questionnaire you said that you
+have served as a juror. In what court did you serve and was it a civil or criminal case?
+4
+EFTA02834161
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 13 of 16
+What type of case was it? Without telling us what the verdict was, did the jury reach a
+verdict?
+14. [For jurors who answered YES to question 198] On your questionnaire you said that you
+have served as a grand juror. When and where?
+15. [For jurors who answered YES to either question] Is there anything about your prior
+experiences as a juror that would prevent you from acting as a fair and impartial juror in
+this case?
+Relationship with, and View of, Government, Defense, and Others
+16. Have you, either through any experience you have had or anything you have seen or
+read, developed any bias or prejudice or other feelings for or against the United States
+Department of Justice, the United States Attorney's Office for the Southern District of
+New York, the FBI, or the NYPD?
+17. Do you have any opinions about prosecutors or criminal defense attorneys generally that
+might make it difficult for you to be a fair and impartial juror in this case?
+18. Do you have any opinion about the criminal justice system generally or the federal
+criminal justice system in particular that might make it difficult for you to be a fair and
+impartial juror in this case?
+19. Do you have any opinion about people who are wealthy or have luxurious lifestyles that
+might make it difficult for you to be a fair and impartial juror in this case?
+5
+EFTA02834162
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 14 of 16
+Experience as a Witness, Defendant, or Crime Victim
+20. [For jurors who answered YES to question 2019] On your questionnaire you said that [you
+or a friend/family member] has/have participated in a state or federal court case. What
+kind of case? And, what was your/their role in that case? Is there anything about that
+experience that would prevent you from acting as a fair and impartial juror in this case?
+21. [For jurors who answered YES to question 2524] On your questionnaire you said that [you
+or a friend/family member] has/have been a victim of a crime. Please describe the
+circumstances, including the type of crime, when it happened, and the outcome of any law
+enforcement action. Is there anything about that experience that could affect your ability
+to be fair and impartial in this case?
+Juror's Background
+22. How old are you?
+23. Please state your current county of residence and list each county of residence during the
+past ten years.
+24. How far did you go in school? And what did you study?
+25. If you work, what kind of work do you do? Describe the type of your employer (for
+example, a private company, government entity, non-profit-organization, etc). (If retired
+or unemployed, describe your last employment.)
+26. How long have you been employed in your current position? What work did you
+previously do?
+27. Who are the members of your household?
+28. If the members of your household work, what kind of work do they do?
+29. What newspapers or magazines do you typically read and how often?
+6
+EFTA02834163
+
+Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page 15 of 16
+30. Do you typically read any websites? If so, do you post comments or information on these
+websites?
+31. Do you regularly use social media? If so, what social media do you regularly use?
+32. Do you regularly watch any television shows? If so, what shows?
+33. Do you regularly listen to any radio programs- or podcasts? If so, which?
+34. What are your hobbies, major interests, recreational pastimes, and leisure-time activities?
+35. Have you ever followed a criminal case in the media? If so, what case?
+36. Are you a member of any clubs or organizations to which you contribute time or money?
+FINAL QUESTION
+37. I have tried to direct your attention in these questions and through the questionnaire you
+filled outthroughout this process to possible reasons why you might not be able to sit as a
+fair and impartial juror. Apart from any prior question, do you have the slightest doubt in
+your mind, for any reason whatsoever, that you will be able to serve conscientiously, fairly,
+and impartially in this case and to render a true and just verdict without fear, favor,
+sympathy, or prejudice, and according to the law as it will be explained?
+7
+EFTA02834164
+
+Case 1:20-cr-00330-PAE
+Document 427
+Filed 11/09/21
+Page 16 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+INSTRUCTION SHEET
+Defendant.
+Dear Juror:
+You have been selected to return for the next phase of jury selection. You are
+required to return on Monday, November 29, 2021 at 8:30 a.m.
+You are instructed to report to Courtroom
+Marshall U.S. Courthouse, 40 Foley Square, New York, New York.
+of the Thurgood
+Your juror number is:
+you return.
+• Please bring this instruction sheet with you when
+Remember, you are required to follow the Judge's instructions regarding
+information about this case and the case participants:
+(1) You are not permitted to discuss this case with anyone. This includes
+friends, family, and colleagues.
+(2) You cannot post anything about this case or your experience during jury
+selection on social media. This includes Facebook, Twitter, Instagram,
+TikTok, etc.
+(3) You cannot perform any research on this case. This includes any kind of
+internet search or Google search.
+(4) You cannot read/watch/listen to any media, news reports, or any other
+discussion of this case.
+Thank you for your service.
+EFTA02834165

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+Case 1:15-cv-07433-LAP Document 271 Filed 07/12/16 Page 1 of 1
+BOIES, SCHILLER & FLEXNER LLP
+40I EAST LAS OLAS BOULEVARD • SUITE 1200 • FORT LAUDERDALE, FL 3330I - 22i1 • PH. 954.356.00|:* FAX 954.356.0022
+Meredith
+, Esq.
+Email: mschultz@bsfllp.com
+July 12, 2016
+Via CM/ECF
+Honorable Judge Robert W. Sweet
+District Court Judge
+United States District Court
+500 Pearl Street
+New York, NY 10007
+Re:
+v. Maxwell
+Case no. 15-cv-07433-RWS - Regarding Protective Order
+Dear Judge Sweet,
+This is a letter motion to file
+Plaintiff's Motion for Leave to File a Sur-
+Reply and accompanying exhibit under seal pursuant to this Court's Protective Order (DE 62).
+The Protective Order states:
+Filing Rules & Instructions for the Southern District of New York.
+See Protective Order (DE 62) signed on March 17, 2016, at p. 4.
+Numerous materials have been marked as confidential in this case. As
+Motion for Leave to File a Sur-Reply and accompanying exhibit contain material that the parties
+have designated as confidential, she seeks leave to file it under scal.
+Respectfully submitted,
+unt Pack
+Meredith
+1, Esq.
+cc: Laura Menninger and Jeffrey Pagliuca via CM/ECF
+WWW.BSFLLP.COM
+EFTA02799282

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+Case 1:15-cv-07433-LAP Document 607-2 Filed 02/10/17 Page 1 of 1
+EXHIBIT 2
+(File Under Seal)
+EFTA02802091

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+EXHIBIT 2
+REDACTED
+EFTA02797795

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vision-joined/court-04/b2f26c8fc3ff7651795f6afeaa0e08d545b1476e22b8893b4aec27e750ed696b.md

@@ -0,0 +1,76 @@
+Case 1:15-cv-07433-LAP Document 423
+Filed 09/06/16
+Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+---X
+Plaintiff,
+V.
+GHISLAINE MAXWELL,
+Defendant.
+15-cv-07433-RWS
+--X
+Declaration of Laura A. Menninger in Support of
+Defendant's Renewed Motion to Compel Settlement Agreement
+1, Laura A. Menninger, declare as follows:
+1. 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 in this action. I respectfully submit this Declaration in support of
+Ms. Maxwell's Renewed Motion to Compel Settlement Agreement.
+2. Attached as Exhibit A (filed under seal) is a true and correct copy of Plaintiff's
+Response And Objections To Defendant's First Set Of Discovery Requests To Plaintiff, served
+March 16, 2016.
+3.
+Attached as Exhibit B (filed under seal) are true and correct copies of conferral
+communication between counsel, including a true and correct copy of Jeffrey Epstein's written
+EFTA02800811
+
+Case 1:15-cv-07433-LAP Document 423 Filed 09/06/16 Page 2 of 3
+waiver of claims concerning settlement agreement's confidentiality provision dated August 16,
+2016.
+4. Attached as Exhibit C (filed under seal) is a true and correct copy of the Complaint
+in Jane Doe 102 v. Jeffery Epstein, Case 9:09- cv-80656- KAM, filed in the United States
+District Court for the Southern District of Florida, on May 4, 2009.
+5. Attached as Exhibit D (filed under seal) is true and correct copy of Plaintiff's Fourth
+Revised Rule 26(a) Disclosures served on June 24, 2016.
+I declare under penalty of perjury that the foregoing is true and correct.
+Executed on September 6, 2016.
+s/ Laura A. Menninger
+Laura A. Menninger
+CERTIFICATE OF SERVICE
+I certify that on September 6, 2016, I electronically served this Declaration of Laura A.
+Menninger in Support of Defendant's Renewed Motion to Compel Settlement Agreement via ECF
+on the following:
+2
+EFTA02800812
+
+Case 1:15-cv-07433-LAP Document 423
+Filed 09/06/16
+Page 3 of 3
+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
+/s/ Nicole
+Nicole
+3
+EFTA02800813