EFTA00075055 - Dataset 9

Extracted Text #

Ces2e.29-12,407413r3cliAlienDtidutinEl t310282 if663615/233/2174ig Plage aoat 9
Haddon, Morgan and Foreman, P C
Ty Gee
HADDON 150 East 10th Avenue
MORGAN Denver, Colorado 80203
FOREMAN PH [Phone Redacted] HI [Phone Redacted]
www.hmllaw.com
[Email Redacted]
July 29, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Reconsideration of the Court's July 23 Ruling
Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order
and punish its violation. Ms. Maxwell's two deposition transcripts were designated
"Confidential" and subject to the protection of the Protective Order. Both transcripts ended
up in the hands of the government, which used them to bring an indictment against
Ms. Maxwell, charging her with, among other things, perjury in her deposition testimony.
This is a serious violation of the Protective Order, and merits the commencement of contempt
proceedings.
We also write to seek reconsideration of the Court's July 23, 2020 ruling concluding that the
transcripts of Ms. Maxwell's April 2016 deposition and Doe 1's deposition should be unsealed
in their entirety (with the exception of non-party names). We recognize that a reconsideration
motion is an extraordinary request, but we suggest it is appropriate under the circumstances.
There are new facts since Ms. Maxwell lodged her objections to the unsealing of the transcript
of her deposition, and there is a need to correct clear error or prevent manifest injustice
relating to the unsealing of the transcript.
We respectfully request that the Court keep sealed Ms. Maxwell's and Doe l's deposition
transcripts and any sealed or redacted order or paper that quotes from or discloses information
from the transcripts ("deposition material"). We do not seek unnecessary delay; however, if
the Court denies our request for reconsideration, we do wish to seek relief from the Second
Circuit. Accordingly, in the event the Court denies this reconsideration request, we ask that
the Court stay any unsealing of the deposition material for at least two business days to give us
time to apply to the Second Circuit for a stay of the unsealing order pending appeal. As the
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courts have recognized, temporary stays of unseal orders are appropriate so that "[t]he genie
is [not] out of the bottle," Gambale v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004),
before the interested parties have an opportunity to seek review of the orders. See, e.g., United
Staten. Martoma, No. Si 12 CR 973 PGG, 2014 WL 164181, at •8 (S.D.N.Y. Jan. 9, 2014)
("The Court stays immediate disclosure of these materials to permit Defendant to make
application to the U.S. Court of Appeals for the Second Circuit for a more extended stay.");
Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in
this matter).
1. There are new, intervening and significant facts since briefing closed on the first round
of review of sealed materials. After many months of relentless negative media coverage of
Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the
government secured an indictment against her. On July 2, one day after Ms. Maxwell filed her
reply in support of her objection to unsealing documents containing references to Does 1 and
2, the government staged a dramatic, forced entry at dawn into her home and arrested her.
EXHIBIT A, at 3.
Immediately after Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held a press
conference and made numerous comments attacking Ms. Maxwell's credibility and expressing
her opinion of Ms. Maxwell's guilt, e.g., that she was guilty of "l[ying]" in her deposition
"because the truth, as alleged, was almost unspeakable." M Plaintiff's counsel piled on,
offering their own opinions about Ms. Maxwell's guilt. For example, Mr. Edwards opined that
Ms. Maxwell was "a main facilitator" of Mr. Epstein's crimes who "started the whole thing."
M Ms. McCawley praised the prosecutors: "[They] have done an incredible job and they're
being very meticulous, they want to make sure that the Indictments stick. ... They took a lot
of time to be very careful and thoughtful and that gives me a lot of hope that [Ms. Maxwell]
will remain in prison for the remainder of her life. ... [Ms. Maxwell] was really the central
figure ...." Id. at 6.
Ms. Maxwell's motion for an order barring such extrajudicial comments led Judge Nathan to
admonish "counsel for all involved parties [to] exercise great care to ensure compliance with
this Court's local rules, including Local Criminal Rule 23.1, and the rules of professional
responsibility." ExHIBIT B. She further "warn[ed] counsel and agents for the parties and
counsel for potential witnesses that going forward it will not hesitate to take appropriate action
in the face of violations of any relevant rules." Id. judge Nathan said she would ensure "strict
compliance" with the rules and "ensure that the Defendant's right to a fair trial will be
safeguarded." Id.
On July 8 the government filed a superseding indictment alleging that Ms. Maxwell "assisted,
facilitated, and contributed" to Mr. Epstein's abuse of minors. The indictment quickly turned
to this civil action, alleging that in 2016 Ms. Maxwell made "efforts to conceal her conduct"
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by "repeatedly provid[ing] false and perjurious statements" in deposition testimony.
EXHIBIT Cl 8.
Quoting verbatim from Ms. Maxwell's April 2016 deposition transcript, the indictment alleges
Ms. Maxwell gave false testimony (a) when she testified "I don't know what you're talking
about" in response to a question whether Mr. Epstein "ha[d] a scheme to recruit underage
girls for sexual massages ... [i]f you know"; and (b) when she testified, "I'm not aware of
anybody that I interacted with [other than plaintiff] who was 17 at this point." Id.121. None
of these questions and answers was used in the summary judgment papers or released by the
Second Circuit. The transcript containing this testimony is sealed.
2. The Court should commence proceedings to vindicate the government and plaintiff's
violation of the Protective Order. Only two parties—plaintiff and Ms. Maxwell —and their
counsel had proper access to the transcripts of Ms. Maxwell's deposition. The transcripts,
which were designated "Confidential," were the subject of the Protective Order strictly
limiting the persons to whom the parties may disclose "Confidential"-designated documents.
For example, the parties could only disclose such documents to "attorneys actively working
on this case" and "persons regularly employed or associated with the attorneys who are
working on this case." Doc.62, quoted in Doc.1071 at 3. This language was negotiated by the
parties to specifically exclude an exception for investigations by law enforcement.
On February 26, 2016, counsel for plaintiff proposed protective order language that would
have allowed for a "law enforcement" exception: Paragraph I(a)4 of plaintiff's draft proposed
that: "CONFIDENTIAL information shall not be disclosed or used for any purpose except the
preparation and trial of this case and any related matter, including but not limited to,
investigations by law enforcement." See Exhibit D at 3. This language was rejected by Ms.
Maxwell because of her concerns that plaintiff and her lawyers were acting as either express or
defacto agents of the Government. The language agreed upon, and made an Order of this
Court specifically excluded an exception for law enforcement. Had the language not been
made an order of the Court, Ms. Maxwell would have proceeded in a different fashion. She
relied on this language and the protection afforded to her by this Court under established
Second Circuit law.
In its Order dated July 1, 2020, the Court said it was "troubled" to learn that plaintiff's
successor counsel, Cooper & Kirk, had received from plaintiff's former counsel, Boies Schiller
Fierier, various discovery materials that were subject to the Protective Order. Doc.1071 at 4.
The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material:
[W]hatever Cooper & Kirk's intentions in requesting and obtaining the
Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly
provides that (1) discovery materials designated CONFIDENTIAL cannot be
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disclosed or used outside of the Maxwell action and (2) that properly designated
discovery materials may only be disclosed to speaficgroups of individuals,
including attorneys "actively working on" the Maxwell litigation.
Doc.1071 at 4-5 (emphasis supplied)
Five things are plain. One, as the indictment and superseding indictment establish, the
government has a copy of the transcripts from Ms. Maxwell's April and July 2016 depositions,
both of which were designated "Confidential." Two, the government had no ability legally to
obtain the deposition transcripts. In Martindell v. International Telephone and Telegraph Corp.,
594 F.2d 291, 293 (2d Cir. 1979), cited with approval in In re Teligent, Inc., 640 F.3d 53, 58 (2d
Cir. 2011), the government moved in a civil action to which it was not a party for access to
transcripts of depositions twelve witnesses, including some of the civil defendants. The
government said it was investigating possible violations of federal criminal laws, including
perjury, subornation of perjury, obstruction of justice and conspiracy. The government:
speculated that the pretrial deposition testimony might be relevant to its
investigation into matters similar to those that had been the subject of the
Martindell action and might be useful in appraising the credibility, accuracy and
completeness of testimony given by witnesses in the Government's
investigation or might provide additional information of use to the
Government. The Government, moreover, feared that unless it could obtain
the deposition transcripts, it would be unable to secure statements from the
witnesses because they would claim their Fifth Amendment rights in any
investigative interviews by the Government.
594 F.2d at 293. The district court denied the government's request, holding that "the
deposition testimony had been given in reliance upon the protective order, thus rendering
unnecessary invocation by the witnesses of their Fifth Amendment rights, that the requested
turnover would raise constitutional issues, and that principles of fairness mandated
enforcement of the protective order." Id The Second Circuit affirmed:
In the present case the deponents testified in reliance upon the Rule 26(c)
protective order, absent which they may have refused to testify.... [T]he
witnesses were entitled to rely upon the terms of a concededly valid protective
order and Judge Conner did not abuse his discretion in refusing to vacate or
modify that order.
Id at 296-97.
Three, the government did not obtain a copy of the deposition transcripts from Ms. Maxwell
or her counsel. Four, following plaintiff's counsel's admitted violation of the Protective Order
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earlier this month, it is clear now that there has been a second violation of the Protective Order
in a manner consistent with the plaintiff's intent and goals—namely, the prosecution of
Ms. Maxwell and the pursuit of a sentence that would imprison her "for the remainder of her
life," EXHIBIT A, at 3. Five, no one should be permitted to violate this Court's Protective
Order with impunity.
As it did in connection with plaintiff's violation of the Protective Order via her attorneys, the
Court should enter orders to determine the nature and extent of the violation of the Order,
identify those persons who violated the Order, and impose appropriate sanctions. Until this
process is completed, the Court should stay any disclosure of the transcripts of Ms. Maxwell's
deposition and deposition material. We respectfully submit that in the event the Court finds a
violation of the Protective Order, this Court should direct the government to return to the
Court any copies of the deposition transcripts and enter an order to show cause why the
person(s) who violated the Order should not be held in contempt. See, e.g., Blum v. Schlegel,
108 F.3d 1369 (2d Cir. 1997); Hunt v. Enzo Biochem, Inc., 904 F. Supp. 2d 337, 340 (S.D.N.Y.
2012).
3. The indictment provides a compelling reason not to unseal the transcript of
Ms. Maxwell's deposition. That Ms. Maxwell was under criminal investigation, the Court
ruled, "is not entitled to much weight here." Tr. ofJuly 23 Hearing, at 5. The Court said
Ms. Maxwell had not explained how the sealed material could inappropriately influence
potential witnesses or victims. Id The effect of Ms. Maxwell's indictment, arrest, upcoming
trial and ofJudge Nathan's efforts to ensure a fair trial was not discussed in our objections
since none of these things had happened before briefing was closed.
Two cases are instructive. In each the courts indicated that in deciding whether to unseal
materials it was important to give weight to the impact on a criminal defendant's right to a fair
trial. In Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978), a number of media moved
the district court to release audio tapes admitted into evidence in the trial of four of President
Nixon's former advisors. The media intended to copy the tapes for broadcasting and sale to
the public. District Judge Sirica denied the motion, principally on the ground that the rights of
the four defendants, who had been convicted and had filed notices of appeal, would be
prejudiced if they prevailed in their appeals. 435 U.S. at 595, 602 n.14. Judge Sirica noted that
the transcripts of the audio tapes had been released to the public. Id at 595. The D.C. Circuit
Court of Appeals held Judge Sirica abused his discretion.
The Supreme Court reversed the court of appeals and rejected the media's arguments that
release of the tapes was required under the common law right of access and the First
Amendment. The Court noted apparently with approval that (a) "Judge Sirica 's view" that
"the public's `right to know' did not ... overcome the need to safeguard the defendants'
rights on appeal," and (b) "Judge Sirica's principal reason for refusing to release the tapes
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[was] fairness to the defendants, who were appealing their convictions." Id at 595, 602 n.14.
The Court indicated that the public interest in access to the tapes properly was balanced
against "the duty of the courts," id. at 602, including the duty to ensure fairness to the
defendants, see id. at 602 n.14.
In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v.
Longueuil, 567 Fed. App'x 13, 16 (2d Cir. 2014), Judge Weinstein denied the media's motion
to unseal papers filed in connection with an unsuccessful defense motion to suppress evidence
obtained by electronic surveillance. He found that "defendants' interest in a fair trial and the
interests of third parties [referenced in] the motion papers justified continued sealing of the
papers." 828 F.2d at 112; see id. at 112 (defendants opposed unsealing on the grounds it would
prejudice their Sixth Amendment right to a fair trial, their privacy rights, and third parties'
privacy rights). The Second Circuit vacated the order in part because "the wholesale sealing"
of the motion papers was "more extensive than necessary to protect defendants' fair trial
rights, their privacy rights, and the third persons' privacy interests. Id at 116. The court
noted, "now that the jury has been impaneled, defendants' fair trial rights can certainly be
adequately protected by sequestration." let
In Nixon and New York Times, the courts properly were concerned about the effect of
unsealing materials notwithstanding that they were core judicial documents—audio tapes
admitted into evidence at the merits trial and motion papers seeking suppression of evidence
which the judge denied. And the courts continued to hold these concerns even after the
defendants had been convicted and had launched appeals (Nixon) and after the petit jury had
been empaneled (New York Times).
The courts have recognized that the right to a fair criminal trial is a compelling interest in
"weighing the interests advanced by the parties in light of the public interests and the duty of
the courts," Nixon, 435 U.S. at 602. See United States v. Cicale, No. 05-CR-60-2 (NGG), 2018
WL 388941, at *3 (E.D.N.Y. Jan. 11, 2018) ("Compelling interests warranting closure of a
courtroom—and, by extension, sealing of court documents— `may include the defendant's
right to a fair trial ....' ") (quoting with alterations United States v. Doe, 63 F.3d 121, 128 (2d
Cir. 1995)); United States v. Martoma, No. Si 12 CR 973 PGG, 2014 WL 164181, at *4
(S.D.N.Y. Jan. 9, 2014) ("A court's conclusion that a qualified First Amendment right of
access to certain judicial documents exists does not end the inquiry, however. `Courts must
balance the right [of access] against other important values, like the Sixth Amendment right of
the accused to a fair trial... and the defendant's ... privacy interests.") (internal quotations
omitted; quoting United States v. Rajaratnam, 708 F. Supp. 2d 371, 374-75 (S.D.N.Y. 2010));
Travelers Indem. Co. v. Excalibur Reins. Corp., 3:11-CV-1209 CSH, 2013 WL 4012772, at *3 (D.
Conn. Aug. 5, 2013) ("The public's right to access court documents is not, however, absolute
in that it may be surmounted by a party's showing that sealing will further other substantial
interests, for example, a criminal defendant's right to a fair trial or a third party's privacy
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interests."); United States a McVeigh,119 F.3d 806, 813 (10th Cir. 1997) (upholding district
court's sealing of discovery materials deemed inadmissible at trial, holding that "disclosure of
such [materials] would play a negative role in the functioning of the criminal process, by
exposing the public generally, as well as potential jurors, to incriminating evidence that the law
has determined may not be used to support a conviction"), cited with approval in United States
v. Avenatti, (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020).
Based on these cases, the Court may make specific findings supporting the sealing of
Ms. Maxwell's deposition transcript: The Court may take judicial notice, as Judge Nathan
herself may have, of the widespread negative media publicity and speculation directed at
Mr. Epstein and Ms. Maxwell. See Condit v. Dunne, 317 F. Supp. 2d 344, 358 (S.D.N.Y. 2004).
We attach a compilation of such articles in EXHIBIT E. The Court also may take judicial
notice of Ms. Maxwell's arrest and indictment, and the government's charge against her based
on her answers in a deposition transcript that was subject to this Court's Protective Order.
The unsealing of Ms. Maxwell's deposition transcript would result in substantial negative
media publicity and speculation in an internet world in the same way that Judge Sirica found
release of the audio tapes in Nixon would generate publicity and affect those defendants' right
to a fair trial. And the Court may take judicial notice of Judge Nathan's own concerns about
the need for counsel for the parties and witnesses in the criminal case to comply with Local
Criminal Rule 23.1 to "safeguard" and "protect [Ms. Maxwell's] right to a fair trial by an
impartial jury," EXHIBIT C. The public's right of access to Ms. Maxwell's deposition
transcript is substantially outweighed by the compelling interest in ensuring her right to a fair
trial. Particularly is this true in light of the other countervailing interests discussed in our
objection papers and below.
4. The deposition transcripts obtained by the government and the indictment's perjury
counts place in a new light plaintiff's earlier litigation conduct—suggesting the planned
use of Ms. Maxwell's deposition as a perjury trap. Throughout much of the first year of
this litigation plaintiff through her counsel had represented to the Court and defense counsel
that plaintiff was privy to and participating in an ongoing criminal investigation in which
Ms. Maxwell was a "person of interest." Doc.101 at 2. Toward that end plaintiff withheld
documents responsive to defense discovery requests for any documents relating to such a
criminal investigation; plaintiff asserted such documents were subject to a law enforcement,
"investigative" or public interest "privilege." Id at 2-3. In response to Ms. Maxwell's motion
to compel the production of documents, plaintiff submitted the "law enforcement materials"
ex pane and in camera to the Court. Doc.128. Ms. Maxwell objected to the submission of the
materials ex parte and in camera. Doc.130. The Court denied the motion to compel. Doc. 264-1.
The materials never have been produced to the defense.
Based on plaintiff's claim of an ongoing investigation, Ms. Maxwell requested, prior to her
deposition, that plaintiff disclose any alleged "on-going criminal investigation by law
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enforcement" or alternatively to stay this action pending completion of any such investigation.
Doc.101. In part, Ms. Maxwell needed information concerning any such investigation to
assess "the impact on any 5th Amendment privilege." Id. at 2, 4-5. Judge Sweet denied that
motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials
that the plaintiff has with respect to any criminal investigations will be turned over [by
plaintiff] except for any statements made by plaintiff to law enforcement authority." Tr. of
Apr. 21, 2016 at 21. Plaintiff produced no such materials and Ms. Maxwell was deposed the
next day. In reliance on the protective order which included no exception for any law
enforcement need or subpoena and based on plaintiff's failure to disclose any "on-going
criminal investigation," she did not assert the 5th Amendment during that deposition.
This background is given a new context in light of (a) the provision of the sealed transcripts to
the government without court authorization and (b) the indictment and perjury charges lodged
against Ms. Maxwell based upon the transcripts. Under Martindell, decided forty years ago
and still binding precedent in this district, it is settled law that the government may not breach
a protective order to gain access to deposition transcripts in a civil lawsuit. As the Second
Circuit held in that case, the government "may not ... simply by picking up the telephone or
writing a letter to the court ... insinuate itself into a private civil lawsuit between others." 594
F.2d at 294. The court rejected the government's argument that the district court's
"solicitude for the witnesses' Fifth Amendment" over the government's desire for the
deposition transcripts was an abuse of discretion. It held that "a more significant
counterbalancing factor" is the civil rules' goal of encouraging witnesses to participate in civil
litigation:
Unless a valid Rule 26(c) protective order is to be fully and fairly enforceable,
witnesses relying upon such orders will be inhibited from giving essential
testimony in civil litigation, thus undermining a procedural system that has
been successfully developed over the years for disposition of civil differences.
In short, witnesses might be expected frequently to refuse to testify pursuant to
protective orders if their testimony were to be made available to the
Government for criminal investigatory purposes in disregard of those orders.
594 F.2d at 296. After balancing the interests at stake, the court held that absent improvidence
in issuing the protective order or some extraordinary circumstance or compelling need,
witnesses must be permitted to rely on the protective order's enforceability. Id. The protective
order should not be vacated or modified "to accommodate the Government's desire to inspect
protected testimony for possible use in a criminal investigation, either as evidence or as the
subject ofa possible perjury charge." Id. (emphasis supplied).
The procedural history of this litigation culminating in plaintiff's gratuitously attaching the
entire transcripts of both Ms. Maxwell's depositions to court submissions, and leaking or
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causing someone to leak the transcripts to the government, which then charged Ms. Maxwell
with perjury counts, suggest plaintiff in conjunction with the government sought to
circumvent Martindell: they set a perjury trap for Ms. Maxwell when plaintiff took her
deposition. Ms. Maxwell requests that this Court examine the law enforcement materials
submitted ex parte and in camera in connection with its vindication of the Protective Order. In
the meantime we respectfully submit it is appropriate to maintain the seal over the
depositions.
5. Ms. Maxwell's reliance on the Protective Order is entitled to substantial weight. In its
July 23 ruling the Court did not address a substantial ground Ms. Maxwell asserted in support
of her objection to unsealing her deposition transcript. The first countervailing interest
Ms. Maxwell presented was that she reasonably relied on the Protective Order in disclosing
intimate information about her personal life. Doc.1057 at 4-5. As we pointed out, id. at 5, even
without any evidentiary or other showing from an interested party, the Second Circuit in
Brown v. Maxwell protected from disclosure "deposition responses concerning intimate
matters where the questions were likely only permitted —and the responses only compelled—
because of a strong expectation of continued confidentiality."929 F.3d 41, 48 n.22 (2d Cir
2019). The Protective Order was entered before Ms. Maxwell's deposition was taken; in fact
plaintiff's counsel explicitly consented to the Order because "'I just want [Ms. Maxwell's]
deposition .... It is that important to me." Doc.1073 at 8 (quoting Doc.66 at 9). The Court
may make specific findings supporting the sealing of the transcript based on the information
Ms. Maxwell supplied from the court submissions. See id We incorporate by reference here
the facts asserted and arguments made in the objection and reply in support of this
countervailing interest.
For the foregoing reasons we respectfully request that the Court reconsider its decision to
unseal (1) the transcripts of Ms. Maxwell's and Doe l's depositions, and (2) court submissions
excerpting from, quoting from or summarizing the contents of the transcripts.
Very truly yours,
Ty Gee
C: Counsel of Record via ECF
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EXHIBIT A
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Haddon, Morgan and Foreman, P.0
Jeffrey Paoflue°
II A D D O N
MORGAN
150 East 10th Avenue
FOREMAN Denver, Colorado 80203
pH [Phone Redacted] FA [Phone Redacted]
www.hmflow.com
[Email Redacted]
July 21, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, Case No. 20 Cr. 330 (MN), Local Criminal Rule 23.1
Dear Judge Nathan,
On behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an
order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government,
its agents, witnesses and their lawyers have made, and continue to make, statements prejudicial
to a fair trial. The Sixth Amendment to the United States Constitution guarantees an accused the
right to an impartial jury. This fundamental guarantee is part of a criminal defendant's basic right
to a fair trial, which requires that a defendant must be judged by a jury of her peers based on
evidence presented at trial, not in the media. The Court, to safeguard the due process rights of the
accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial
publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect
to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly, Ms. Maxwell
requests that the Court exercise its express power under Local Criminal Rule 23.1(h) and enter
an Order requiring compliance with that rule to prevent further unwarranted and prejudicial
pretrial publicity by the Government, its agents, and lawyers for alleged witnesses.
Legal Standard
More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the
Supreme Court directed trial judges to take "such steps by rule and regulation that will protect
their processes from prejudicial outside interferences. Neither prosecutors, counselfor defense,
the accused, witnesses, court staff nor enforcement officers coming under the jurisdiction of the
court should be permitted to frustrate itsfunction." Sheppard v. Maxwell, 384 U.S. 333, 363
(1966) (emphasis added).
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In an effort to protect the trial process from "prejudicial outside interferences," this Court
promulgated Local Criminal Rule 23.1(a) which provides, in relevant part, that:
It is the duty of the lawyer or law firm, ... and government agents
and police officers, not to release or authorize the release of non-
public information or opinion which a reasonable person would
expect to be disseminated by means of public communication, in
connection with pending or imminent criminal litigation with
which they are associated, if there is a substantial likelihood that
such dissemination will interfere with a fair trial or otherwise
prejudice the due administration of justice.
To avoid any confusion this Court identified seven "subject matters" that "presumptively
involve a substantial likelihood that their public dissemination will interfere with a fair trial or
otherwise prejudice the due administration of justice." Id. at (d). Accordingly, lawyers for parties
and witnesses and their agents are prohibited from publicly disseminating information
concerning:
(1) The prior criminal record (including arrests, indictments or other charges of crime), or
the character or reputation of the accused...;
(2) The existence or contents of any confession, admission or statement given by the
accused, or the refusal or failure of the accused to make any statement;
(3) The performance of any examinations or tests or the accused's refusal or failure to
submit to an examination or test;
(4) The identity, testimony or credibility ofprospective witnesses, except that the lawyer
or law firm may announce the identity of the victim if the announcement is not otherwise
prohibited by law;
(5) The possibility of a plea of guilty to the offense charged or a lesser offense;
(6) Information the lawyer or law firm knows is likely to be inadmissible at trial and
would if disclosed create a substantial likelihood of prejudicing an impartial trial; and
(7) Any opinion as to the accused's guilt or innocence or as to the merits of the case or
the evidence in the case.
Id. at (d)(1-7) (emphasis added).
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Recent Prejudicial Public Statements by the Government, its Azents and Counsel to
Prospective Witnesses
Recent public statements by the Government, its agents and counsel for prospective
witnesses have included presumptively prejudicial information.
On July 2, 2020 Ms. Maxwell was arrested without notice to her lawyers who had been in
active communication with the Government for one year. Because plain vanilla surrenders lack
the fanfare and attendant media coverage afforded to secret, armed, raids at dawn, the
Government chose to invade Ms. Maxwell's New Hampshire residence, arrest her, and stage a
media presentation that included numerous statements that prejudice Ms. Maxwell's right to a
fair trial.
Immediately following Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held
a press conference in which she commented on Ms. Maxwell's credibility and her incorrect
opinions concerning "guilt or innocence or as to the merits of the case or the evidence in the
case" in violation of Local Rule 23.1(d)(1), (4) and (7):
Per the New York Law Journal:
'Maxwell lied because the truth, as alleged, was almost unspeakable,' Strauss said
at a press conference announcing the charges. `Maxwell enticed minor girls, got
them to trust her and then delivered them into the trap that that she and Epstein
had set for them. She pretended to be a woman they could trust, all the while she
was setting them up to be sexually abused by Epstein and, in some cases, by
Maxwell herself."
As reported in the Washington Post,
Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and
others in deposition because the truth 'was almost unspeakable.'
Acting U.S. Attorney Audrey Strauss called the sex abuse described in the
Maxwell case 'the prequel' to the charges they lodged against Epstein....
Maxwell played a critical role in helping Epstein to identify, befriend, and groom
minor victims for abuse' ... 'In some cases Maxwell participated in the abuse
itself.'2
https://www.law.corninewyorklawjournal/2020/07/02/ghislaine-maxwell-arrested-in-
connection-with-jeffrey-epstein-sex-trafficking-ringfislreturn=20200614124921
2 hups://www.washingtonpost.comMational-security/ghislaine-maxwell-arrested-jeffrey-
epstein/2020/07/02/20c74502-bc69-11ea-8cf5-9c1b8d7f84c6 story.html
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The Honorable Alison J. Nathan
July 21, 2020
Page 4
Although Ms. Strauss sprinkled her comments with the phrase "as alleged," she presented
certain of her statements as fact? Regardless, after Ms. Strauss's remarks, FBI Special Agent
William Sweeney went even further, calling Ms. Maxwell "one of the villains in this
investigation" and compared her to a snake that "slithered away to a gorgeous property in New
Hampshire." Thus, Mr. Sweeney offers the Government's, again flatly wrong, opinions about
character and guilt while, at the same time, invoking a semi-biblical reference involving a snake
slithering away to a garden in New Hampshire. These types of comments, which serve no
compelling law enforcement or investigatory purpose, are prohibited by the local rules of this
District.
New York attorney David Boies and his partner Sigrid McCawley, who represent several
witnesses in this matter, have also made public and presumptively prejudicial statements in
recent days, notwithstanding the fact that such conduct is prohibited by Local Rule 23.1, which
applies to lawyers practicing in this District, generally, and lawyers for witnesses, specifically.
See Rule 23.1(a) and (b).
As reported by the Washington Post, Mr. Boies expressed his views on the prohibited
subject of "the possibility of a plea of guilty to the offense charged or a lesser offense" in
violation of sections (d)(5) and (7) of the Rule:
Boies said he thinks Maxwell will be `under tremendous pressure to cooperate' as
she looks for ways to shave time off what may be a significant prison sentence.
Maxwell could potentially help prosecutors shed light on Epstein's dealings with
other wealthy and influential people who may have had encounters with
underaged victims, he said, adding `There were a lot of people with a lot of public
stature who were involved with Epstein!'
Ms. McCawley echoed Mr. Boies, saying that, "The pain [Maxwell] has caused will never go
away but today is a step toward healing." Id.
Bradley Edwards, another attorney representing witnesses in this matter made similar
presumptively prejudicial statements following Ms. Maxwell's arrest:5
`The reality of how this organization worked was that 99.9% of it was
orchestrated for Jeffrey Epstein's personal sexual satisfaction. So to the degree
that um there was a main facilitator that started the whole thing, it was Ghislaine.
3 A purported transcript of the press conference is contained on the intemet at
https://www.rev.comiblog,/transcripts/announcement-transcript-of-charges-against-ghislaine-
maxwell-in-new-york-jeffrey-epstein-associate-arrested.
https://www.washingtonpost.cominational-security/ghislaine-maxwell-arrested-jeffrey-
epstein/2020/07/02/20c74502-bc69-11ea-8cf5-9c1b8d7f84c6 story.html
https://www.youtube.com/watch?v=mDKHdzix2kO
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The Honorable Alison J. Nathan
July 21, 2020
Page 5
So to cooperate in the way that that kind of rumors out there would mean that
she's cooperating downwards. She'd be cooperating with people who are much
less culpable than her. Will she name names to try to shave years off of what
would be a lengthy prison sentence maybe, I think you should probably expect
that if she's going to share information that's going to actually help her, it's
probably gonna be about unrelated crimes that she may be aware about because
with respect to this particular operation, in terms of living people, she's as high as
it gets. ... I think like most of my clients would really hope that she does
cooperate, at least shares the information that she has. I mean I know that it
would only be to help herself but the public deserves to know who was involved
besides her and Jeffrey Epstein, and only she knows that.
The violations of Rule 23.1 did not stop after Ms. Maxwell's arrest and detention.
Following the detention hearing on July 14, 2020, Mr. Boies, counsel for one of the accusers
who spoke at the hearing, commented on the content of the hearing. As reported by Bloomberg,
Mr. Boies offered his gratuitous critique of defense counsel, commented on the credibility of Ms.
Maxwell and his client, and commented on what Mr. Boies considers "evidence" in this case, all
in violation of subsections (1), (4), (6), and (7) of the Rule:
That's a dan erous tactic that might backfire at trial, said David Boies, who
represents and several other women who say they were sexually abused
by Epstein and Maxwell. ... It's "a tone-deaf argument" that cost Maxwell her
credibility, said Boies, who listened to the hearing remotely.
`To mount a `blame the victim' defense, particularly in today's world and trying
to blame these girls for what happened is so contrary to the evidence, is so
contrary to people's normal sense of morality,' Boies said. `I think that's just
going to enrage a jury if she goes to trial -- which I would not do if I were
representing her.'
Boies said he was confident would stand up to cross-examination if
there's a trial. , who addressed the court by telephone, urged the judge not
to grant Maxwell bail, calling her a `sexual predator who groomed and abused
me.' Maxwell `lied under oath and tormented her survivors,' said. Boies
said that was a 16-year-old who 'wanted to go to college' when she met
Maxwell. `Maxwell and Epstein tell and her mother `we're having a group
of high school students to this ranch to help them get into college,' Boies said.
'But when gets there, there are no high school students, all these claims are
fraudulent and she's in this isolated place in New Mexico.'6
6 https://www.bnnbloomberg.ca/ghislaine-maxwell-may-play-the-victim-card-in-trial-
defense-1.1465631
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The Honorable Alison J. Nathan
July 21, 2020
Page 6
Mr. Boles and Ms. McCawley gave on-air interviews with ABC News following Ms.
Maxwell's detention that contained repeated, presumptively prejudicial quotes, including: 7
Boles: Remember these girls were abused twice, once sexually years ago and then
a second time when Epstein and Maxwell and all their enablers began these
vicious attacks on their credibility. ... No question about it. Maxwell knows
where a lot of the bodies are buried. If I was somebody who had participated in
their sex trafficking, um, I would not be sleeping easily tonight.
Boles: I think that [the accusers] want to see her go to trial. On the other hand,
the arrest and conviction that would come from a plea deal is an enormous step
and I think they also recognize that Jeffrey Epstein and Maxwell did not act alone.
There are lots of other people that need to be brought to justice.
McCawley: I think that the prosecutors in the Southern District of New York have
done an incredible job and they're being very meticulous, they want to make sure
that the Indictments stick. ...They took a lot of time to be very careful and
thoughtful and that gives me a lot of hope that she will remain in prison for the
remainder of her life. ... This morning was a very joyful and tearful filled
morning, it was a wonderful moment in my journey with these survivors, to be
able to call them and tell them that the one person's who's been out in the public
without being held accountable was finally in prison....She was really, Ghislaine
was really the central figure, so she worked hand-in-hand with Jeffrey Epstein to
be able to facilitate these crimes over the course of more than two decades; and
she was the main person who assisted him and allowed him to be able to
perpetrate so many crimes against young females.
These comments violate subsections (6) and (7) of the Rule.
It appears that given any opportunity lawyers associated with the prosecution of this case
will offer any opinion that damages Ms. Maxwell's opportunity for a fair trial. Entry of an order
prohibiting extrajudicial statements, therefore, is a necessary remedy to avoid further
dissemination of prejudicial information. The Court, under Local Criminal Rule 23.1(h) should
enter an Order, punishable by contempt, that all lawyers associated with this case, and their
agents, comply with the Rule and refrain from publicly commenting on the seven prohibited
topics identified in subsection (d).
7 https://abcnews.go.corn/US/ghislaine-maxwell-epsteins-alleged-recruiter-private-battle-
public/story?id=71705375
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The Honorable Alison J. Nathan
July 21, 2020
Page 7
Respectfully Submitted,
Jeffrey S. Pagliuca
cc:
U.S. Attorney's Office for the Southern District of New York
Mark Cohen
Christian Everdell
Cohen & Gresser LLP
Laura A. Menninger
Haddon, Morgan & Foreman, P.C.
EFTA00075071
Cagesle120o140ZaUX.PertDo&Aflt."1016ZO. PEIR603824/20e1a4e205f 2
EXHIBIT B
EFTA00075072
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DOCUMENT
ELECTRONICALLY FILED
DOC it
UNITED STATES DISTRICT COURT DATE Fii-ED:7/23/2020
SOUTHERN DISTRICT OF NEW YORK
United States of America,
—v—
20-CR-330 (MN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Defense has moved for an order "prohibiting the Government, its agents and counsel
for witnesses from making extrajudicial statements concerning this case." Dkt. No. 27 at 1.
The Court firmly expects that counsel for all involved parties will exercise great care to
ensure compliance with this Court's local rules, including Local Criminal Rule 23.1, and the
rules of professional responsibility. In light of this clear expectation, the Court does not believe
that further action is needed at this time to protect the Defendant's right to a fair trial by an
impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But the Court
warns counsel and agents for the parties and counsel for potential witnesses that going forward it
will not hesitate to take appropriate action in the face of violations of any relevant rules. The
Court will ensure strict compliance with those rules and will ensure that the Defendant's right to
a fair trial will be safeguarded.
SO ORDERED.
Dated: July 23, 2020
New York, New York A ( 4
ALISON J. NATHAN
United States District Judge
EFTA00075073
Ca69,bil9C.2493.309.91961otbilleDY1319B920F/19g1571/29Pd4999€1O d9919
EXHIBIT C
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
UNITED STATES OF AMERICA SUPERSEDING INDICTMENT
S1 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
x
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sax Acts)
The Grand Jury charges:
OVERVIEW
1. The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00075075
CadiataKibt141 r : t3 Al b moIMOSIVAPPAQP44140ANIMPOlacW41319
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3. During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
EFTA00075076
caglataaftienWrifif igtae t P.•
4. Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a. MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b. Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
c. MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
3
EFTA00075077
caglatiVALWAMAZNEWstiteirigilgAILANSOMPIMiatO 19
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d. In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e. Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5. GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
4
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catakibkli NattoktftigailMAIEWNISMASO 19
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6. Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a. A a multi-story private residence on the
Upper East Side of Manhattan, New York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
EFTA00075079
c4aatagwdoroAwiematoktfiwrmsq4a4w0A1tQA9woaoitis
b. An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
c. A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
6
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cadiattelaW414§§1WeriamokftitaliWila01§§72132Varaige 19
d. MAXWELL's personal residence in London,
England.
7. Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a. MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
EFTA00075081
cw t 0 19
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b. MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
8
EFTA00075082
cadstlivi444614MnritthrlikkWifenaiNsfitaFerm*WA 19
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
c. MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8. In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
EFTA00075083
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abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAIN£ MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
10
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a. Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
c. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d. Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
11
EFTA00075085
case Stt120fititOratialiVIPMElig agOar0441319
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
12
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cagsVg14,4 c St Ptet4D4s4kiwATIPAteSEilg jkle::747;7;?i, 144f319
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423(a).
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423(a).
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
13
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New York Residence, in violation of New York Penal Law, Section
130.55.
c. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d. Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
14
EFTA00075088
ca§itsVtbitocel V':•: titetPtailat711139fliig efflekg6Wile19
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423(a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q. Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A. I don't know what you're talking about.
• • •
15
EFTA00075089
ca3FtsVrit5164 Get. PtiftitPtiktivektA8Siig W*40441319
Q. List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A. I'm not aware of anybody that I interacted with,
other than obviously (the plaintiff) who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
0: Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A: No, not that I recall. . . .
Q. Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A. No.
16
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ca§isViBitocei teW5t0blittniarktasitfrteglig 31t01;?i, aggigfeti#41319
• • •
Q. Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A. I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q. I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A. That is my testimony, that is correct.
• . .
Q. Is it your testimony that you've never given
anybody a massage?
A. I have not given anyone a massage.
Q. You never gave Mr. Epstein a massage, is that
your testimony?
A. That is my testimony.
Q• You never gave (Minor Victim-2) a massage is your
testimony?
A. I never gave (Minor Victim-2) a massage.
(Title 18, United States Code, Section 1623.)
FOi#PERSON AUDREY RAUSS
Acting sited States Attorney
17
EFTA00075091
ca§itsVt§14)44. cett talet~faliWitetsgEkgMO if ciAeRgekint19
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
GHISLAINE MAXWELL,
Defendant.
SUPERSEDING INDICTMENT
S1 20 Cr. 330 (AJN)
(18 U.S.C. SS 371, 1623, 2422, 2423(a),
and 2)
AUDREY STRAUSS
Acting United States Attorney
Foreperson
18
EFTA00075092
Ca6.0_0[..09-400004F006101,001.5Y1B1B40FIletle61219Pdligengh d0910
EXHIBIT D
EFTA00075093
02/26/2016 14:Qe*A41Sam.24)1721.313dcAPIe CitaliarilieffiltrI8Q4RO,Faii9657329 Puce 202 laib 0001/0026
BOLES, SCHILLER & FLEXNER LLP
Sie,'w Vert( ■ WasbinntotitDC Florida • New i California New Jersc •
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, Florida 33301
Telephone: ([Phone Redacted]
Facsimile: ([Phone Redacted]
FACSIMILE COVER SHEET
TO: Laura Menninger, Esq. Fax No. [Phone Redacted]
Haddon, Morgan and Foreman, P.C. Telephone No. [Phone Redacted]
FROM: Sigrid S. McCawley, Esq.
Total Number of Pages: 26
DATE: February 26, 2016 (including this cover sheet)
RE: v. Maxwell,
Case no. 15-cv-07433-RWS
MESSAGE: Attached please find a copy of my email transmission to you from
today at 12:10 pm, along with the accompanying Agreed Protective
Order in both redline and clean version. Thank you.
THE ATTORNEY-CLIENT AND/OR ATTORNEY WORK-PRODUCT PRIVILEGES
This facsimile transmission is intended solely for the above-named recipient and may contain confidential information which is exempt from disclosure
and protected by the attorney-client and/or attorney work-product privikges. Any unauthorised use or disclosure is strictly prohibited and may result in
civil and/or criminal liability. limy of the information contained in this transmission is misdirected to you, pkase call ([Phone Redacted] collect and mail
such information back to us. Thank you.
EFTA00075094
02/26/2016 14:Cattioatileam.2-017-
43130EARle litoteniheni alma o cathilariaS Page 302 10Zoolsioo26
United States District Court
Southern District Of New York
Plaintiff,
v. 15-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
AGREED PROTECTIVE ORDER
Upon a showing of good cause in support of the entry of a protective order to protect
the discovery and dissemination of confidential information, including sensitive personal
information relating to a victim of sexual abuse, copyright or trade secrets, commercially
sensitive information, or proprietary information.
I. Purposes And Limitations
(a) The Parties acknowledge that this Order does not confer blanket protections on
all disclosures during discovery. Designations under this Order shall be made sparingly, with
care, and shall not be made absent a good faith belief that the designated material satisfies the
criteria set forth herein. If it comes to a Designating Party's attention that designated material
does not qualify for protection at all, or does not qualify for the level of protection initially
asserted, the Designating Party must promptly notify all other parties that it is withdrawing or
changing the designation.
IT IS ORDERED:
EFTA00075095
02/26/2016 14: BC62-0174.534cAM e 0lotbrib 1311))78(4 0 Faiii657329 PAO AGM HQ 0020/0026
1. This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and other information
disclosed pursuant to the disclosure or discovery duties created by the Federal
Rules of Civil Procedure.
2. As used in this Protective Order, "document" is defined as provided in
FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document within
the meaning of this term.
3. Information designated "CONFIDENTIAL" shall be information that is
confidential and is covered by common law and statutory privacy protections of
(a) plaintiff hrid (b) defendant Ghislaine Maxwell or
any non-party that was subject to sexual abuse.
4. CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case and any related matter, including
but not limited to, investigations by law enforcement.
5. CONFIDENTIAL documents, materials, and/or information (collectively
"CONFIDENTIAL INFORMATION") shall not, without the consent of the
party producing it or further Order of the Court, be disclosed except that such
information may be disclosed to:
a. attorneys actively working on this case;
b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial, or at other proceedings in this case;
EFTA00075096
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c. the parties;
d. expert witnesses and consultants retained in connection with this
proceeding, to the extent such disclosure is necessary for preparation, trial
or other proceedings in this case;
e. the Court and its employees ("Court Personnel") in this case;
f. stenographic reporters who are engaged in proceedings necessarily incident
to the conduct of this action;
g. deponents, witnesses, or potential witnesses;
h. any person (1) who authored or received the particular Protected Material; (2)
who has or had at any point in time access to the Protected Material outside of
the context of this action; or (3) for which there is a good faith basis to
conclude that the individual has earlier received or seen such Protected
Material; and
i. any other persons by written agreement of the parties or by Order of a Court
of competent jurisdiction.
6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel, persons employed by counsel, Court
Personnel and stenographic reporters), counsel shall provide such person with
a copy of this Protective Order and obtain from such person a written
acknowledgment stating that he or she has read this Protective Order and
agrees to be bound by its provisions. All such acknowledgments shall be
retained by counsel and shall be subject to in camera review by the Court if
good cause for review is demonstrated by opposing counsel.
3
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7. Documents are designated as CONFIDENTIAL by placing or affixing on them
(in a manner that will not interfere with their legibility) the following or other
appropriate notice: "CONFIDENTIAL." Discovery material designated
CONFIDENTIAL shall be identified by Bates number. To the extent practical,
the respective legend shall be placed near the Bates number.
8. Designation of a document as CONFIDENTIAL INFORMATION shall
constitute a representation that such document has been reviewed by an
attorney for the designating party, that there is a valid and good faith basis for
such designation, made at the time of disclosure or production to the receiving
party, and that disclosure of such information to persons other than those
permitted access to such material would cause a privacy harm to the
designating party.
9. Whenever a deposition involves the disclosure of CONFIDENTIAL
INFORMATION, the deposition or portions thereof shall be designated as
CONFIDENTIAL and shall be subject to the provisions of this Protective
Order. Such designation shall be made on the record during the deposition
whenever possible, but a party may designate portions of depositions as
CONFIDENTIAL after transcription, provided written notice of the
designation is promptly given to all counsel of record within thirty (30) days
after notice by the court reporter of the completion of the transcript, and until
the expiration of such thirty (30) days after notice by the court reporter of the
4
EFTA00075098
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completion of the transcript, no party or counsel for any such party may share
the contents of the deposition outside the limitations of this Protective Order.
10. Whenever a party seeks to file any document or material containing
CONFIDENTIAL 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.
11. Challenging Designations Of Protected Material
(a) A Party shall not be obligated to challenge the propriety of any designation of
Discovery Material under this Order at the time the designation is made, and a
failure to do so shall not preclude a subsequent challenge thereto. Moreover,
failure to challenge the designation of any Discovery Material as
CONFIDENTIALshall not in any way constitute an admission that such material
contains any competitively sensitive information, trade secret information, or
other protectable material.
(b) In the event that counsel for the Party receiving Protected Material objects
to the CONFIDENTIAL designation of any or all such items, said counsel shall
provide the Producing Party and, if different, the Designating Party written notice
of, and the basis for, such objections. The Parties will use their best efforts to
resolve such objections among themselves. Should the Receiving Party, the
Producing Party and, if different, the Designating Party be unable to resolve the
EFTA00075099
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objections, the Receiving Party may seek a hearing before this Court with respect
to the propriety of the designation. The Designating Party will cooperate in
obtaining a prompt hearing with respect thereto. Pending a resolution, the
discovery material in question shall continue to be treated as Protected Material as
provided hereunder. The burden of proving that Discovery Material is properly
designated shall at all times remain with the Designating Party.
12. At the conclusion of this case, unless other arrangements are agreed upon, each
document and all copies thereof which have been designated as CONFIDENTIAL
shall be returned to the party that designated it CONFIDENTIAL, or the parties
may elect to destroy CONFIDENTIAL documents. Where the parties agree to
destroy CONFIDENTIAL documents, the destroying party shall provide all parties
with an affidavit confirming the destruction.
13. With respect to any Discovery Material produced by such non-party, the non-party
may invoke the terms of this Order in writing to all Parties by designating
Discovery Material "CONFIDENTIAL". Any such Protected Material produced
by the non-party designated "CONFIDENTIAL" shall be subject to the restrictions
contained in this Order and shall only be disclosed or used in a manner consistent
with this Order.
14. In the event that any Producing Party inadvertently produces Discovery Material
eligible for designation as CONFIDENTIAL without such designation, the Parties
agree that the Producing Party may retroactively apply the correct designation. If a
EFTA00075100
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Producing Party makes a subsequent designation, the Receiving Party will treat the
Protected Material according to the retroactive designation, including undertaking
best efforts to retrieve all previously distributed copies from any recipients now
ineligible to access the Protected Material.
16. Limitations. Nothing in this Order shall restrict in any way the use or disclosure
of Protected Material by a Receiving Party (a) that is or has become publicly
known through no fault of the Receiving Party; (b) that is lawfully acquired by or
known to the Receiving Party independent of the Producing Party; (c) that was
previously produced, disclosed, and/or provided by the Producing Party to the
Receiving Party or a non-party without an obligation of confidentiality and not by
inadvertence or mistake; (d) with the consent of the Producing Party and, if
different, the Designating Party; (e) pursuant to Order of the Court; or (f) for
purposes of law enforcement.15. This Protective Order shall have no force and
effect on the use of any CONFIDENTIAL INFORMATION at trial in this
matter.This Protective Order may be modified by the Court at any time for good
cause shown following notice to all parties and an opportunity for them to be
heard.
EFTA00075101
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BY THE COURT
UNITED STATES DISTRICT JUDGE
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EXHIBIT E
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New Jeffrey Epstein accuser says he molested her at 13, told her to
wear children's underwear
January18.2020 I 12:04am I Updated
Jeffrey Epstein
AP
A woman claiming she was Jeffrey Epstein's "first-known victim" says she was sexually abused by the now-dead pedophile
— who called himself her "Godfather" — when she was 13 years old.
Jane Doe met Epstein and his friend, Ghislaine Maxwell, in the summer of 1994 at Michigan's interlochen Arts Camp, where
she was In voice training, according to newly flied court papers suing Epstein's estate and Maxwell.
The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all
the while grooming her for abuse, the Manhattan federal court suit says.
Epstein "started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of letting Doe pick out
clothes she wanted to wear, Epstein Insisted that she pick out and wear little children's cotton underwear," the suit says.
EFTA00075104
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She was first allegedly abused in a pool house that same year when Epstein pulled her onto her his lap and began
masturbating — claiming this was what "professionals" did.
The attacks escalated, the court papers claim. The financier would regularly sexually assault her and force her to perform
sex acts in Palm Beach, New York City and his New Mexico ranch, always traveling to the locations on his private plane
dubbed the "Lolita Express."
At 16, Epstein put Doe up in one of his apartments in New York City — near his own townhouse, where he would allegedly
rape her the next year.
MAIM
Feds finally start
investigating Jeffrey
Epstein's gal pal Ghislaine
Maxwell
"In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had
a boyfriend. Doe replied that she did not," the lawsuit reads. "Epstein responded that when she did have a boyfriend she
would want the sex to be 'good' and that she should 'get it over with already; meaning lose her virginity."
"Despite Doe's resistance, Epstein then pushed Doe down onto her stomach and raped her. From that point forward for
several years in New York. Epstein raped Doe on multiple occasions," the papers claim, noting Maxwell was often present
when the abuse took place.
The court papers also claim Epstein introduced her to President Trump when she was 14 years old, allegedly elbowing
Trump and saying, "This is a good one, right?"
"Trump smiled and nodded in agreement." the suit states.
A spokesperson for the president did not immediately return a request for comment.
Doe is suing Epstein's estate, alleging sexual assault, sexual battery, false imprisonment and other charges. Her complaint
joins over a dozen filed by other women claiming they were trafficked and abused by the multi-millionaire.
Epstein was found dead in his jail cell in August while awaiting trial for sex trafficking. His death was officially ruled a suicide
by hanging.
Lawyers for Maxwell and Epstein's estate did not immediately return emails.
FILED U k, • COURTS. DONALD TRUMP. GHISLAINE MAXWELL JEFFREY EPSTEIN, LAWSUITS, PEDOPHILES, SEXUAL ABUSE, I/18/20
EFTA00075105
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Epstein, Maxwell wanted me to have surrogate baby: Virginia
Roberts
March 22.2020 I 3:24pm
Virginia Roberts Giuffre
wham Farrington
Former teen "sex slave" says she finally fled Jeffrey Epstein and Ghislaine Maxwell after three years,
when they asked her, at g , pear mew sur ogate baby.
MUM
Epstein's former gal pal
sues his estate
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The latest creepy allegation bs=vho has also accused Epstein of pimping her out to Prince Andrew when she was
just 17, was revealed by her attorney, Bradley Edwards, in his new memoir, "Relentless Pursuit."
"It was the final straw," Edwards writes in an excerpt published in the Daily Mail.
"She knew she had to escape."
FILED UNDER GHISLAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20
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Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-16-vear-old-airl-naked-massaae-victims-
lawyer-says.html
March 28. 2020
Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a
naked massage while Jeffrey Epstein watched,' lawyer who
dedicated his life to nailing Prince Andrew's paedophile friend
claims in new book
• Ghislaine Maxwell, 58, allegedly sexually assaulted i6-year-old
• It reportedly happened at paedophile Epstein's 7,500-acre New Mexico
ranch
• A lawyer for more than 20 of Epstein's victims has made the allegation
By Mark Hookham For The Mail On Sunday
Published: 18:O3 EDT, 28 March 2O2O I Updated: 15:59 EDT, 2 July 2O2O
•
•
• e-mail
•
713 shares
Socialite Ghislaine Maxwell allegedly groped a teenage girl during a naked massage while
paedophile Jeffrey Epstein watched, a new book claims.
Maxwell, 58, allegedly sexually assaulted 16-year-old at Epstein's 7,5OO-acre
ranch in New Mexico, according to the book by Bradley Edwards, a lawyer for more than
2O of Epstein's victims.
The book, from which we are summarising stories in The Mail on Sunday, details
Maxwell's alleged role in recruiting and grooming underage girls for Epstein. According to
some accounts, she was even involved in some of the abuse herself.
116
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It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for
months, has never been charged with any wrongdoing. She has always maintained that
allegations against her are abhorrent and untrue.
The book also claims that:
Maxwell, Epstein's ex-girlfriend, was at the wedding of former US President Bill
Clinton's daughter Chelsea in July 2010, a year after Epstein was released from jail as
a convicted sex offender;
She loved to take nude photographs of girls and allegedly took many of the pictures
displayed on the walls of Epstein's mansions.
According to one witness, she felt `indebted' to Epstein for helping her following the
mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell;
Epstein `wasn't beyond killing someone' to keep his sex addiction alive, the witness
claimed.
now 40, helped keep Epstein behind bars last July after giving evidence
about her ordeal as a teenager during a bail hearing. The financier was found dead in his
cell the following month. Ms is now suing Epstein's estate and Maxwell in the New
York district court for damages.
According to Ms testimony, detailed in the book, she was flown to the financier's
vast Zorro Ranch after he offered to pay for her to attend a summer educational
programme in Thailand.
316
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Prince Andrew pictured with his arm around who has accused the
Queen's 'favourite son' of having sex with her
416
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516
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616
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When will feds arrest Jeffrey Epstein `fixer' Ghislaine Maxwell?
May 28. 2020 I 4:l7pm I Updated
Jeffrey Epstein and Ghislaine Maxwell
Patticit McMullan via Getty Images
Nine months after Attorney General William Barr warned that Jeffrey Epstein's co-conspirators -should not rest easy: the
pedophile's alleged madam. Ghislaine Maxwell. remains at large — and is using a potential criminal investigation to thwart
civil action against her.
Maxwell is currently a co-defendant in several civil cases brought by alleged Epstein sex-trafficking victims.
Among them is ho claims in her suit against Maxwell and the proprietors of Epstein's estate that she was
lured to his New emu:, rant as a teenager and sexually abused by the pair.
According to the suit. Maxwell allegedly forced n undress in view of Epstein after promising to give her a massage.
"Maxwell touched intimate parts of .Mody against her will for the sexual benefit of
Maxwell and Epstein." the suit states. "Maxwell exposed reasts and groped her," it adds.
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Through her attorne=as sought to depose Maxwell and have her respond to written questions related to the
alleged sexual abuse.
gGhislaine Maxwell
Paul BmInoogelPatack MclAullan ma Getty Images
But the former fixer has successfully dodged a grilling in the case, citing an ongoing criminal investigation into co-
conspirators of Epstein — all while not admitting she herself is being probed by the feds.
An investigation into Epstein's accomplices was alluded to by Barr days after the pedophile's suicide in a Lower Manhattan
lockup, and has been mentioned repeatedly by the US Attorneys Office in New York. according to court filings.
A spokesperson for the Southern District of New York declined to comment on the investigation.
Maxwell's attorney cited the investigation in an effort to block her testimony in the Farmer case.
.1.11ALL2
Ghislaine Maxwell wins
questioning delay in sexual
battery suit
"The Southern District of New York has publicly and repeatedly announced its 'ongoing' criminal investigation into alleged
Epstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to
Manhattan federal Judge Debra Freeman seeking to stay discovery in the case.
"Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investigation could impair
her Fifth Amendment privilege against self-incrimination," added her attorney, Laura Menninger.
Farmer's attorney, David Boies, noted in his response that Maxwell has not publicly admitted she herself is the center of a
federal investigation, but is nevertheless using it to shield herself.
"Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators.
the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation,"
Boies wrote.
Epstein investigators
contacted by 'dozens' since
his death
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"When Plaintiff's counsel asked Maxwell's counsel for information about the criminal investigation during their meet and
confer, Maxwell's counsel refused to provide any details," he added.
Freeman agreed Maxwell could potentially incriminate herself by giving a deposition and ordered that she not be required
to sit for one as part of the suit.
r.
the $570 single speed
tokyobike
Maxwell, who is apparently in hiding, has not given testimony or a public statement since Epstein's arrest and suicide.
Attorneys for Farmer and Maxwell did not immediately respond.
FILED UN:flk GHISLAINE MAXWELL JEFFREY EPSTEIN, LAWSUITS, SEX TRAFFICKING, WILLIAM BARR, 5/28/20
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Ghislaine Maxwell felt no guilt in procuring girls for
Jeffrey Epstein, claims friend
mi dailymail.co.uk/femailiarticle-8384165/Ghislaine-Maxwell-felt-no-guilt-procuring-airls-JeffrerEostein-claims-
friend.htrnl
June 3, 2020
• US_based 57, has spoken out in new documentary
• Claims Ghislaine Maxwell felt 'no guilt' in procuring girls for Jeffrey Epstein
• reveals she 'feared for her life' at the hands of Epstein and
Maxwell
• Who Killed Jeffrey Epstein? premieres at npm Saturday 6th June on Quest
Red and dplay
•
•
• e-mail
•
592 shares
Ghislaine Maxwell felt no guilt in procuring girls for ,Jeffrey Rpsteja to satisfy his
'incredible sex drive,' Prince Andrew's distant cousin has claimed - adding that 'if anything,
she was proud.'
In Quest Red's new true crime documentary special Who Killed Jeffrey Epstein? it is
alleged that socialite Ghislaine Maxwell - Epstein's former partner - procured girls for
Epstein to 'satisfy his insatiable sex drive.'
Socialite writer Christina Oxenberg, 57, from the US, who is a friend of Maxwell, notes that
Maxwell felt no guilt in procuring girls for his pleasure.
'She says he has an incredible sex drive, he has to have three orgasms a day, so I help him
out by bringing in the females,' explains Christina. 'She felt no compunction about telling
me this, if anything she was proud.'
Christina is the daughter of a Serbian princess and sister of the Hollywood actress,
Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex
cult run by its leader, Keith Raniere, after an 18 month battle.
India was among the women he recruited under the guise of offering them self-help
courses. Her actress mother pulled her out of it in 2018 after fighting relentlessly in the
press to expose Raniere and his practices.
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Christina Oxenberg claims that Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey
Epstein to satisfy his 'incredible sex drive' in Quest Red's new true crime documentary
special Who Killed Jeffrey Epstein?
Jeffrey Epstein and Ghislaine Maxwell attend de Grisogono Sponsors The 2005 Wall
Street Concert Series Benefitting Wall Street Rising on March 15, 2005 in New York
2112
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Prince Andrew and
Britain on March 13, 2001
l
iged 17 at Ghislaine Maxwell's townhouse in London,
The documentary dives headfirst into the Epstein story, examining the mysterious
circumstances surrounding the financier's death, aiming to answer one vital question: Did
Epstein take his own life, or was it something much more sinister?
On loth August 2019, disgraced American financier Jeffrey Epstein was found dead in his
New York prison cell as he awaited his trial on sex trafficking charges.
3112
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It was a dramatic end to one of the world's most mysterious billionaires, with the coroner
officially ruling the cause of death as suicide.
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But it wasn't long before the circumstances surrounding Epstein's death were
called into question.
Having being linked with some of the world's most influential and powerful
celebrity figures — including Prince Andrew, Donald Trump and Bill Clinton —
some believe that Epstein may have been murdered.
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Whe tliashingtott post
Democracy Dies in Darkness
Ghislaine Maxwell, longtime associate of Jeffrey
Epstein, charged in sex abuse case
By Shayna Jacobs and Devlin Barrett
July 2, 2020 at 3:14 p.m. MDT
NEW YORK — Ghislaine Maxwell, a longtime confidante of sex offender Jeffrey
Epstein, was arrested Thursday in New Hampshire on charges she recruited and
groomed underage girls for abuse by her then-boyfriend, officials said.
Support our journalism. Subscribe today. 3
A grand jury indictment unsealed Thursday charged Maxwell, daughter of the late
media tycoon Robert Maxwell, with perjury and conspiring to entice minors to
travel to engage in sex acts.
Maxwell has been under investigation for months as a possible accomplice to
Epstein's history of sexual abuse of underage girls. Epstein, who committed suicide
while in federal custody last summer, dated Maxwell for years, and the indictment
charges she played a key role in grooming girls for him to abuse.
AD
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Beginning in at least 1994, the indictment alleges, Maxwell "enticed and groomed
multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of
means and methods."
Acting U.S. Attorney Audrey Strauss called the sex abuse described in the Maxwell
case "the prequel" to the charges they lodged last year against Epstein covering
alleged acts of abuse in the early 2000S.
"Maxwell played a critical role in helping Epstein to identify, befriend, and groom
minor victims for abuse," said Strauss, who oversees the federal prosecutor's office
in the Southern District of New York. "In some cases, Maxwell participated in the
abuse herself."
A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages
seeking comment.
David Boies, who along with Sigrid McCawley represents a dozen of Epstein's
accusers, said their clients were elated by the development. "It's just an enormous
step," he said.
AD
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Boies said he thinks Maxwell will be under "tremendous pressure to cooperate" as
she looks for ways to shave time off what may be a significant prison sentence.
Maxwell could potentially help prosecutors shed light on Epstein's dealings with
other wealthy and influential people who may have had encounters with underage
victims, he said, adding, "There were a lot of people with a lot of public stature ...
who were involved with Epstein."
"The pain [Maxwell] has caused will never go away but today is a step toward
healing," McCawley added in a statement, praising prosecutors on the case for their
"unrelenting courage."
U.S. Magistrate Judge Andrea Johnstone ordered Maxwell to remain in custody at a
brief hearing via videoconference in federal court in New Hampshire, where
another of her attorneys, Lawrence Vogelman, did not seek an immediate bail
hearing because her lawyers plan to make those arguments after she is transferred
to New York.
AD
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In a court filing, prosecutors said Maxwell should stay behind bars pending trial
because she might flee given her "extensive international ties," noting she has
citizenship in two countries and three passports in her name. Maxwell, 58, faces the
possibility of 85 years in prison if convicted and has "absolutely no reason to stay in
the United States," prosecutors argued in the filing.
Prosecutors also said the Epstein investigation is not over and asked any victims or
witnesses to Epstein's abuse of minors to contact the FBI.
William Sweeney, head of the FBI's New York office, called Maxwell "one of the
villains" of the Epstein saga and said that agents kept close tabs on her after she
"slithered away to a gorgeous property in New Hampshire."
AD
The indictment charged that Maxwell "would try to normalize sexual abuse for a
minor victim by, among other things, discussing sexual topics, undressing in front
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of the victim, being present when a minor victim was undressed, and/or being
present for sex acts involving the minor victim and Epstein."
One of the victims was 14 years old when Epstein and Maxwell began grooming her
for sex acts with Epstein, according to the indictment.
The victims were groomed or abused at a number of Epstein's luxurious homes,
including his sprawling Upper East Side townhouse in Manhattan, an estate in
Palm Beach, Fla., a ranch in Santa Fe, N.M., and Maxwell's home in London,
according to the charges.
"Minor Victim-2," according to the indictment, was under 18 when she was flown to
New Mexico at Epstein's invitation. "In New Mexico, Maxwell began her efforts to
groom Minor Victim-2 for abuse by Epstein by, among other things, providing an
unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless,"
the indictment charged.
Maxwell is also accused of grooming and befriending a third victim, whom she met
in London between 1994 and 1995. She allegedly encouraged that victim to give
Epstein massages "knowing that Epstein would engage in sex acts with Minor
Victim-3 during those massages."
The indictment also accuses Maxwell of lying in a deposition in 2016 when asked
about these activities by a lawyer for one of Epstein's alleged victims, when she
denied any knowledge of him engaging in sex acts with minors. When asked if
Epstein had a scheme to recruit underage girls for sexual massages, Maxwell
replied, "I don't know what you're talking about," the indictment says.
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AD
Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and
others in the deposition because the truth "was almost unspeakable — Maxwell
enticed minor girls, got them to trust her, then delivered them into the trap that she
and Epstein had set for them. She pretended to be a woman they could trust, all the
while she was setting them up to be sexually abused by Epstein."
Maxwell's arrest was first reported Thursday by NBC News.
Epstein, 66, was a registered sex offender who was arrested last year on federal sex
trafficking charges for alleged abuses of underage girls in New York and Florida.
His suicide in a Manhattan federal detention center led to charges against two of his
guards who were accused of failing to check on him in his cell in the hours before he
was found hanging from a bedsheet.
Epstein's ability to avoid a lengthy prison sentence has raised questions about
whether the wealthy, politically connected sex offender — with ties to both
President Trump and former president Bill Clinton — was able to manipulate state
and federal officials to go easy on him.
Years before his 2019 arrest, Epstein had resolved similar allegations with a plea
deal involving state charges in Florida that allowed him to spend a little more than a
year in jail and leave daily for work — an arrangement widely criticized as too
lenient. As part of that deal, prosecutors agreed not to pursue cases against
Epstein's associates who might have recruited girls for him.
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AD
Gloria Allred, a lawyer representing more than a dozen of Epstein's alleged victims,
said her clients hope Maxwell "will be accountable if the evidence presented in
court proves beyond a reasonable doubt that she had a role in assisting and
recruiting young girls to be sex trafficked and sexually victimized by Jeffrey
Epstein."
The investigation into Epstein's conduct continued after his jailhouse death and has
ensnared Britain's Prince Andrew, another old friend of the late financier.
Federal prosecutors complained earlier this year that Andrew has provided "zero
cooperation" to authorities.
One of Epstein's accusers, claims she was paid by Epstein
for sexual encounters with the prince when she was 17. The prince has denied any
wrongdoing.
On Thursday, Strauss made clear prosecutors still want to talk to him.
"We would welcome Prince Andrew coming in to talk to us," she said. "We would
like to have the benefit of his statement."
Epstein's alleged victims continue to pursue lawsuits against his estate, which is
valued at hundreds of millions of dollars.
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Ghislaine Maxwell leaves luxe life behind for tiny jail cell in Brooklyn
July 7.2020 I 8A7pm I Updated
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From beef bourguignon to beef jerky: Ghislaine Maxwell has traded in her palatial New Hampshire cabin for stripped-down
confinement at Brooklyn's Metropolitan Detention Center.
The Oxford-educated British socialite had been lying low in a million-dollar New Hampshire hideaway featuring a cathedral
ceiling, a massive floor-to-ceiling stone fireplace and a gourmet kitchen, according to the home's listing.
Jeffrey Epstein's alleged right-hand woman cooked stews for herself in a kitchen with two ovens, a six-burner stove and a
luxury refrigerator.
Maxwell, 58, on Monday was transferred to the city's largest federal jail, where she is expected to be kept in a 10-foot-by-12-
foot cell.
The notorious facility is in the midst of a lawsuit that has sounded the alarm over its potential to foster a dangerous
coronavirus outbreak. It's the same facility where officers last month pepper-sprayed inmate Jamel Floyd to death.
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In January 2019, inmates went freezing for weeks when an electrical fire knocked out power in the building, an environment
described as a "humanitarian crisis."
The Interior of the Metropolitan Detention Center
D0.I
Maxwell will be given a T-shirt and other basic clothing at the MDC along with a thin mattress, pillow and blanket. She may
be allowed to have an approved religious medallion or book, such as the Bible — but cannot have any other personal
possessions.
After schmoozing among the global elite, Maxwell has apparently had a difficult time socializing with her fellow inmates. One
inmate at a New Hampshire jail where she was briefly held reportedly called her a "snooty b—h."
Injuring a high-profile inmate like Maxwell "would be a badge of honor: former MDC warden Cameron Lindsay said.
"You go from living a life like Maxwell to all of a sudden being in a situation where you're being strip-searched and having
people look into your body cavities: Lindsay added.
HIED UN' BROOKLYN. GNISLAINE MAXWELL, JAIL JEFFREY EPSTEIµ 7/7/20
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VIDEO LIVE SHOWS 2020 ELECTIONS CORONAVIRUS
• ■
For Ghislaine Maxwell, Epstein's alleged Top Stories
recruiter, a private battle has become a For Ghislaine Maxwell. Ilp,stein's
alleged recrulter.a private battle
public reckoning has become a public reckoning
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She has been charged with conspiring with the infamous sex offender.
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Congressman who refused to
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Contentious S-hour House
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GNsialne Maxwell behind ban as new details emerge
Jeffrey Epstein's ex-gw1.0. J.66, Epstem's sex aunts by he@ng him
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Ghislaine Maxwell, a British socialite and longtime companion of disgraced
financier Jeffrey Epstein, is facing a reckoning for her alleged role in
facilitating Epstein's sexual abuse of young women.
Federal prosecutors say Maxwell played a "key role" in a multi-state sex
trafficking scheme, in which she not only allegedly "befriended' and later
'enticed and groomed multiple minor girls to engage in sex acts with
Epstein, through a variety of means and methods," but was also, at times,
"present for and involved• in the abuse herself.
Maxwell is scheduled to appear before a federal judge in New York on
Tuesday, where she is expected to publicly address those allegations for the
first time. But court filings make clear that Tuesday's hearing is only the
latest chapter in long-running legal battles waged mostly out of public
view.
Maxwell has been named as a defendant in five lawsuits from alleged
Epstein victims, and in at least three others, alleged victims identify her as
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0 Jeffrey Epstein anti Ghislaine Platowil attend de Gnsogono Sponsors The 1005 Wail Street Concert Series
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Patrick Mcmulan/Patnck McMullen via Getty Image. FILE
But in lawsuits several of Epstein's alleged victims tell an entirely different
story, one that often places Maxwell in a role that was central to their abuse.
One anonymous victim, identified only as Jane Doe, alleged that Epstein
and Maxwell "attempted to groom and mentor" her when she was just 13
years old.
"They took her to movies, went shopping with her and lounged around
Epstein's estate with her," Doe alleged in her complaint. "Epstein and
Maxwell then started to make sexual references when they were with her:
Ultimately, according to Doe's complaint, Maxwell "regularly facilitated
Epstein's abuse of Doe and was frequently present when it occurred."
+ MORE; Ghislaine Maxwell given paper clothes at correctional center to avoid
suicide attempt: Sources
nd another anonymous alleged victim
identified only as Doe 1000, have alleged that Maxwell not only rec
girls for Epstein but, in their cases, even participated in their abuse
alleged Epstein and Maxwell sexually abused her between 2000 and 2002
and claims that she was directed to have sex with some of their prominent
friends alleged that Maxwell "groped her" and "touched intimate
parts oflherl body against her will for the sexual benefit of Maxwell and
Epstein"; Doe alleged "Epstein and Maxwell proceeded to sexually assault
Jane Doe simultaneously and by forcible compulsion" and that Maxwell
"forcibly penetrated Jane Doe with a sex toy."
Maxwell has, in court filings, strenuously denied any such misconduct.
"She absolutely denies that she participated in this or any other sexual
abuse or trafficking or assault," her lawyer wrote in response
t'
allegations, "and no court, judge or jury has ever determined that she has."
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casehissaotznagapitpmettuartennamsanizemnatiagEI§et3802 161
la
lefty Epstein and Glusdoine Maxwell attend on event in New York Ory, June 13,1995.
Patrick McMullan via Getty Images, FRE
Following Epstein's arrest last July and his death in prison a month later,
Maxwell's whereabouts became the subject of intense scrutiny. She sold her
former residences In New York and London and shuttered her non-profit
ocean conservation organization. Various press reports placed her in
Massachusetts, California, France and Israel, and attorneys for several of
Epstein's alleged victims struggled to locate her in order to serve their
lawsuits. She was ultimately arrested by the FBI in Bradford. New
Hampshire, where prosecutors say she was living at a 156-acre property,
nicknamed "Tucked Away?
Prosecutors are now arguing that Maxwell poses an "extreme" flight risk,
citing her "three passports, large sums of money, extensive International
connections."
Maxwell is a citizen of the United States, United Kingdom and France,
prosecutors said, and she has traveled abroad frequently within the last
three years. Prosecutors also believe she possesses "significant sums of
money," citing a government investigation that identified "more than 15
different bank accounts held by or associated with the defendant from 2016
to the present, and during that same period, the total balances of those
accounts have ranged from a total of hundreds of thousands of dollars to
more than $20 million."
+ MORE: Truth and Lies: Jeffrey Epstein' Podcast
As with Epstein, however, prosecutors have found the full extent of
Maxwell's wealth difficult to determine.
EFTA00075140
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one of Epstein's primary "recruiters." claims that Maxwell, through her " ABC News Live
attorneys, has repeatedly denied.
"Maxwell had no involvement in or knowledge of Epstein's alleged
misconduct," one lawyer for Maxwell wrote earlier this year in her own
lawsuit against the Epstein estate.
+ MORE: As feds continue to seek interview with Prince Andrew, Attorney
General William Barr says Jeffrey Epstein probe marches on 24/7 eoiwooe of treohng news on. hw evens
In court filings related to that lawsuit, in which she claimed that Epstein
had "promised that he would indemnify, defend, and advance any expenses
incurred by reason of my prior employment relationship with him and his
affiliated businesses,' Maxwell contended that she had "incurred
substantial expenses defending myself against false accusations and
investigations." She claimed to owe more than $318,000 to a criminal
defense firm, more than $101,000 to a civil litigation firm, and more than
$194,000 in security and relocation costs. The estate, according to court
records, declined to reimburse the costs.
According to Joshua Schiller of Boies, Schiller, Flexner, LLP, a firm that
represents three Epstein's alleged victims who have filed civil suits against
her, Maxwell has been at the forefront of the fight with Epstein's alleged
victims long before her recent arrest.
"(Maxwell] has been using this Court as a sword and a shield for many
years." Schiller wrote in a filing earlier this year, "and she, Jeffrey Epstein,
and their other co-conspirators have attempted to thwart their victims from
obtaining justice for decades."
ita Chinon,. Maxwell of Spring Studios in New Yoek Cies fXe IS 2016.
Patrick McMullan via Getty Images, File
Maxwell, 58, is the Oxford-educated daughter of Robert Maxwell, the larger
than life publishing baron whose rags-to-riches story captivated England.
She lived an extravagant life among the British elite until her father's
business empire collapsed in the wake of his death. She fled to New York
looking for a fresh start and was soon seen in the company of the
mysterious multimillionaire Epstein.
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The defendant's financial resources appear to be substantial," prosecutors
wrote, "and her numerous accounts and substantial money movements
render her total financial picture opaque and indeterminate, even upon a
review of bank records available to the Government."
Brad Edwards, an attorney who represents several of Epstein's alleged
victims, believes that there is still much more to learn about Maxwell.
"I think that's the tip of the iceberg," Edwards told ABC News. "And I would
expect the same thing that happened after Jeffrey Epstein was arrested.
There's going to be a flood of calls and more information coming in'
But her role in Epstein's story, he said, is already clear.
"Ghislaine Maxwell created Jeffrey Epstein,' Edwards told ABC News. "She
helped to create the monster that we later understood him to be."
e Comments (89) II 11 ■
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In a letter to a Florida state prosecutor related to Epstein's 2008 guilty plea,
Epstein's attorneys describe his relationship with Maxwell as one of two
long-term intimate relationships" Epstein had in adulthood. They met
through mutual friends in 1991. his attorneys said, and parted "amicably" in
2000 because "the demands of his work ... precluded a good married life
with children." The same letter contains what purports to be a quote from
Maxwell. in which she describes Epstein as a "thoughtful, kind, generous,
loving man."
Maxwell has asserted in court filings that she entered Epstein's employ in
1999, where she remained, despite the end of their romantic relationship.
until at least 2006.
Maxwell's only sworn testimony on the nature of her work for Epstein can
be found in excerpts -- unsealed by a federal court last year -- of two 2016
depositions related to a defamation lawsuit filed by Virginia Giuffre. one of
Epstein's alleged victims, who has accused Maxwell of recruiting her into
Epstein's alleged child trafficking scheme, an accusation Maxwell denied.
• O Truth and Lies: Jerre
•., decade ago. mysterious I
According to Maxwell's testimony, she was responsible for the staffing and
management of Epstein's various properties.
'There were six homes," Maxwell said. "I hired assistants, I hired architects,
I hired decorators, I hired cooks, I hired cleaners, I hired gardeners, I hired
pool people, I hired pilots, I hired all sorts of people."
"A very small part ofmy job," she added, "was from time to time to find
adult professional massage therapists for Jeffrey."
She denied, under oath, that she had ever hired underage girls to work for
Epstein, assertions that are now the subject of perjury charges.
'As far as I'm concerned, everyone who came to his house was an adult,
professional person," Maxwell said. "I am not aware of teenagers who
worked in his home."
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'I'm no Cruella de Vil': Ghislaine Maxwell insists she is
not an 'evil villain'
O dailymail.co.uk/news/article-8513675/Im-no-Cruella-Vil-Ghislaine•Maxwell-insists-not-evil-villain.html
July 11, 2020
• Maxwell says she is not the 'cartoon caricature of a villain' she is portrayed
as
• The 58-year-old is scheduled to appear before a judge in New York on
Tuesday
• She will be charged with procuring girls as young as 14 for Jeffrey Epstein
•
•
• e-mail
•
685 shares
Defiant Ghislaine Maxwell has rounded on her accusers, insisting that her portrayal as a
'cartoon caricature of a villain' is utterly false.
Friends say that the 58-year-old socialite, who is scheduled to appear before a judge in
New York on Tuesday to be formally charged with procuring girls as young as 14 for Jeffrey
Epstein — the serial paedophile and her former boyfriend — 'is no Cruella de Vil'.
Referring to the glamorous but evil character from the Disney film One Hundred And One
Dalmatians, one friend told The Mail on Sunday: `This cartoon caricature of a villain she is
being painted as is utterly untrue and false.
'This is a real human being with real feelings.'
1/13
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Ghislaine Maxwell, 58, has rounded on her accusers, insisting that her portrayal as a
`cartoon caricature of a villain' is utterly false
Breaking a year-long silence since Epstein's death, sources dose to Maxwell have gone on
the offensive to put her side of the story.
After a year during which she was neither seen nor heard, her allies now reveal how she
intends to salvage her liberty and reputation against claims that she supplied depraved
Epstein with young girls.
Maxwell's allies have told The Mail on Sunday that she:
• Is not the person who introduced billionaire Epstein to Prince Andrew;
• Fears dying of Covid-19 while in prison;
• Insists she and Epstein had not met in person for 15 years;
• Weeps over friends who have lost jobs because of their association with her;
• Has not had a haircut in a year and is being moved `from cell-to-cell' for her own
safety.
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Maxwell is scheduled to appear before a
judge in New York on Tuesday to be
formally charged with procuring girls as
young as 14 for Jeffrey Epstein — the serial
paedophile and her former boyfriend
The daughter of the late newspaper tycoon
Robert Maxwell will make global headlines
on Tuesday when she appears in court via
remote link from her New York jail cell.
She will be formally charged with sex
offences between 1994 and 1997 and will
plead not guilty to them all. Her lawyers will
argue for her release from the high-security
Metropolitan Detention Center in Brooklyn
on £4 million bail, arguing that her life is in
danger from coronavirus and 'multiple and
credible' death threats.
Maxwell, who is a long-time friend of Prince Andrew and who saw him most recently in
2019, was arrested at her £800,000 New Hampshire hideaway on July 2.
Prosecutor Audrey Strauss condemned her as 'playing a critical role in finding and
grooming victims', while scores of Epstein's victims claim that she acted as his 'madam',
often driving from his £20 million mansion in Palm Beach, Florida, to nearby trailer parks
to 'procure' vulnerable young girls for the paedophile.
But last night a source close to Maxwell hit back, saying: 'Ghislaine is no Cruella de Vil. She
is being portrayed as this evil character and a cartoon-like villain but she is nothing like
that. She is a real person and is determined to prove her innocence despite the fact that she
has been characterised as some sort of monster.'
Maxwell insists that her romance with Epstein ended in 2001 and that she did not see him
in person after 2005 when she was photographed with him at a party.
At the time, she was dating billionaire Gateway computer founder Ted Waitt.
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@Clive Coote Walt Disney K REX Shutte rstock
A source close to Maxwell hit back, saying: 'Ghislaine is no Cruella de Vil'. Pictured: The
character played by Glenn Close in the 1996 film 101 Dalmatians
'The reality is that Ghislaine's relationship with Epstein ended in 2001,' says the friend.
'Starting in late 2002, early 2003, she was dating Ted and she loved him deeply. Epstein
kept trying to woo her back but she wasn't interested.'
However, the friend adds, Maxwell continued to work for the twisted tycoon. 'She hired
Epstein's pool guys, the IT guys.
'She managed his household. They weren't that close. It was a professional relationship.'
When Epstein negotiated an infamous plea deal, pleading guilty to two child sex
nrnstitntinn rharges in 9 nng and serving lust 1Q months in nrisnn — most nn day release —
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Four more women accused of supplying young girls for
Epstein to abuse
dailymail.co.uldnews/article-8513823/Four-women-accused-supplyina-young-girls-Eostein-abuse.html
July 12, 2020
Epstein's other 'recruiters': Four more women accused of
supplying young girls for him to abuse face probe as it's revealed
Ghislaine Maxwell moved house 36 times in a year before she was
caught
• Sara Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova are
under investigation for their role in Epstein's sex-trafficking ring,
according to reports
• The four women are accused of helping to procure and groom the girls
• In one case a previous victim went on to help groom other young women
• Ms Kellen, dubbed Maxwell's 'lieutenant', 'flew on the lolita express
almost as many times as the disgraced couple'
• Reports suggest that Ms Maxwell moved 36 times before her arrest last
week
By Ryan Fahey For Mailonline
Published: 20:46 EDT, ii July 2O2O I Updated: 09:08 EDT, 12 July 2O2O
•
•
• e-mail
•
21k shares
Four more women accused of supplying young girls for billionaire paedophile Jeffrey
Epstein to abuse are facing investigation as it's revealed Ghislaine Maxwell moved house
36 times in a year before she was caught by the FBI.
Sara Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova are being investigated for
their alleged role in Epstein's sex-trafficking ring, according to a report in the Sunday
Telegraph.
Ms Kellen, dubbed Ghislaine Maxwell's 'lieutenant' by Epstein's victims, is said to have
flown on the paedophile's 'lolita express' almost as many times as the disgraced couple.
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Ms Kellen, who is said to have taken a leading role in the sex ring, and the other three
women, have previously been accused of recruiting and grooming underage girls for
Epstein to sleep with.
One was also said to have been involved in a sexual relationship with the financier.
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Kellen worked as an assistant for Jefferey Epstein and was named in his 2008 plea
agreement as 'potential co-conspirators'
Nada Marcinkova who now goes by Nadia, was allegedly one of Epstein's victims according
to interviews with victims back in 2005, before she began procuring girls for the
paedophile herself
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Ghislaine Maxwell breaks down in
tears as she is DENIED bail and must
stay locked up until her July 2021 trial
as judge rules Epstein's 'madam' has
shown 'sophistication in hiding her
finances AND herself and poses
significant flight risk'
• Ghislaine Maxwell cried as she was denied bail on Tuesday, with a judge ruling she
must stay locked up until her trial in July of 2021
• The British socialite, 58, pleaded not guilty to the sex trafficking charges brought
against her
• She hung her head as she learned her fate, wearing a prison-issued brown top and
with her normally short hair now long and swept back into a bun
• Judge Alison Nathan ruled Maxwell was a significant flight risk, citing her
'substantial international' ties and 'extraordinary financial resources'
• Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey
Epstein to abuse between 1994 and 1997
• She had offered a $5 million bond co-signed by two of her sisters and backed up
by more than $3.75 million in property in the UK
• Prosecutors fought for no bail, presenting evidence that she is 'skilled at living in
hiding', citing her three passports and claimed she is worth more than $10M
• They said Maxwell refused to open the front door to the FBI and tried to flee to
another room when they raided her $1 million home on July 2
• A victim also argued she was a flight risk and wrote: 'Without Ghislaine, Jeffrey
couldn't have done what he did. She is a predator and a monster'
By CHEYENNE ROUNDTREE FOR DAILYMAIL.COM and DANIEL BATES FOR DAILYMAIL.COM
PUBLISHED: 13:21 EDT, 14 July 2020 I UPDATED: 17:20 EDT, 14 July 2020
Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay
locked up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not
guilty to the sex trafficking charges brought against her.
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The 58-year-old wiped tears away and hung her head as she learned her fate, wearing a
prison-issued brown top and with her normally short hair now long and swept back into a
bun, appearing via video link.
U.S. District Judge Alison Nathan denied Maxwell's proposal of a $5 million bond co-
signed by two of her sisters and backed up by more than $3.75 million in property in the
UK.
Maxwell's legal team had argued she would be confined to a 'luxury hotel' in the New
York area, surrender all her travel documents and be subject to GPS monitoring.
But Judge Nathan ruled the British socialite was a significant flight risk, citing her
'substantial international' ties and 'extraordinary financial resources', setting an anticipated
trial date for July 12, 2021.
Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994
and 1997, a period when she was his girlfriend.
She faces up to 35 years in prison if found guilty of the charges, as
prosecutors successfully argued that along with her three passports, connections to
some of the world's most powerful people and her own fortune of more than $10 million -
Maxwell had every incentive to try and flee.
Maxwell will now return to the fortress-like Metropolitan Detention Center in Brooklyn
where she has been given paper clothes to ensure she doesn't kill herself.
EFTA00075170
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Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay locked
up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not guilty to the
sex trafficking charges brought against her
But Judge Nathan ruled the British socialite was a significant flight risk, citing her 'substantial
international' ties and 'extraordinary financial resources', setting an anticipated trial date for
July 12, 2021
EFTA00075171
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Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994 and
1997, a period when she was his girlfriend. She faces up to 35 years in prison if found guilty of
the charges, as prosecutors successfully argued that along with her three passports,
connections to some of the world's most powerful people and her own fortune of more than
S10 million - Maxwell had every incentive to try and flee
Maxwell is currently in custody in the Metropolitan Detention Center in Brooklyn (pictured)
where she is wearing paper clothes to ensure she doesn't kill herself
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Maxwell is being closely watched as the Department of Justice wants to ensure she does
not kill herself like Epstein, who hanged himself last August while awaiting trial on sex
trafficking charges.
During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell
appeared via video from the Metropolitan Detention Center in Brooklyn.
The small room she was in had white walls, a white bed, a window with frosted glass and
a door at the back.
She was wearing a dark brown prison issued top and her dark hair was far longer than in
the past - she reportedly has not had a haircut in a year - and was swept behind her head
in a bun.
At the start of the hearing, Maxwell rested her elbows on a table in front of the camera
and put her head on her hands.
She appeared nervous and pensive and kept looking from side to side, as she leaned into
the camera.
Maxwell briefly spoke and only to confirm she could hear the judge and to enter her
plea by saying: 'Not guilty, your honor'.
Her demeanor changed when prosecutor began outlining the allegations
against her, sitting back in her chair and bowing her head when accused her of
'sexual abuse of minors'.
With every allegation, Maxwell either scratched her face or moved her hair, but was
emotionless as victim impact statements were read aloud.
It wasn't until Judge Nathan started reading her decision that Maxwell finally broke down.
She began moving uneasily in her chair as the judge said the evidence against her was
'strong'.
When Judge Nathan said a 'combination of factors' showed she had the 'motive and
opportunity' to flee before her trial, Maxwell wiped a tear away.
The second tear fell as the judge said Maxwell was 'sophisticated at hiding her financial
resources'.
EFTA00075173
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During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell appeared via
video from the Metropolitan Detention Center in Brooklyn. She was wearing a dark brown
prison issue top and her dark hair was far longer than in the past - she reportedly has not had a
haircut in a year - and was swept behind her head in a bun
It wasn't until Judge Nathan began reading her decision that Maxwell finally broke down. She
began moving uneasily in her chair as the judge said the evidence against her was 'strong'.
When Judge Nathan said a 'combination of factors' showed she had the 'motive and
opportunity' to flee before her trial, Maxwell wiped a tear away
EFTA00075174
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For the rest of the decision, Maxwell rested her head in her hands as she had done at the
start of the hearing.
Maxwell sat though prosecutors detailing how she was 'skilled at living in hiding' and as
two victims argued she was a flight risk, with one writing: 'Without Ghislaine, Jeffrey
couldn't have done what he did. She is a predator and a monster.'
Prosecutors argued against Maxwell being granted bail, citing that due to holding both
French and British passports, she has the ability to 'live beyond the reach of extradition
indefinitely'.
Prosecutor argued: 'She is good at living under an assumed identity. There really
can be no question that she can live in hiding.'
She revealed when Maxwell bought her $1 million home in Bradford, New Hampshire last
December, she toured the property with a real estate agent using an alias.
said: 'The real estate agent told the FBI agent the buyers for the house introduced
themselves as Scott and Janet Marshall. Both had British accents.
'Scott Marshall told her he was retired from the British military and was currently working
on a book. Janet Marshall described herself as a journalist.'
Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea,
living at a home owned by her tech CEO lover Scott Borgerson. It is unclear if the man
who toured the New Hampshire home with Maxwell was Borgerson.
also read out a victim impact statement from a woman identified as Jane Doe, who
also made the case that Maxwell was a flight risk.
The victim said she knew Maxwell for 10 years and the socialite intended to 'deliver' her
to Epstein, all the while knowing the 'heinous dehumanization that awaited me'.
The woman claimed Maxwell 'was in charge' and 'egged' Epstein on.
She described Maxwell as 'sociopathic' and said she would 'have done anything to get
what she wanted - to satisfy Jeffrey Epstein'.
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Victim ictured) also spoke at the hearing, detailing how she met Maxwell when
she was years o . has previously gone on record with her claims against Maxwell
Prosecutor said when Maxwell bought her S1 million Bradford, New Hampshire
home (pictured), she toured the home back in November of 2019 using the alias of Janet
Marshall and claimed to the real estate agent that she worked as a journalist
The victim added that 'if [Maxwell] is out, I need to be protected', citing a phone call she
received in the middle of the night threatening her two-year-old child.
EFTA00075176
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Iso spoke at the hearing, detailing how she met Maxwell when she was 16
has previously gone on record with her claims against Maxwell.
She said Maxwell 'has never shown any remorse [andj tormented her survivors... She has
associates across the globe, some of great means.'
Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she
has community ties and is 'part of a very large and close family'.
He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media
spin', leading prosecutor. to later shoot back: 'These are the facts. It is not dirt, it is
not spin, it is evidence to the court.'
Cohen claimed Maxwell had received numerous threats and denied she had refused to
open her front door to the FBI when they raided her home on July 2.
He claimed her front door was unlocked, the windows were open and she had
'surrendered' to the agents.
Addressing reports that Maxwell had wrapped her mobile phone in tin foil, which
prosecutors called a 'seemingly misguided effort to evade detection' by law enforcement,
Cohen claimed her phone had been hacked and she had to preserve the phone as
evidence.
MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A.
Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she
is at increased risk of catching the coronavirus whilst in prison. They claim that the restrictions
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on access to her lawyers caused by the pandemic would mean it was impossible for her to get
a fair trial
Also on the case is (l-r) and James Comey's
daughter
• Um, recovutt a. per:vol.% arditt4
you maybe Warm, gem WU* togmil
Worker
1-800-CALL FBI
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Pictured: Acting United States Attorney for the Southern District of New York Audrey Strauss
speaks during a news conference to announce charges against Ghislaine Maxwell
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Cohen went above the issue of Maxwell being a flight risk to complain that the charges
against her are from 25 years ago, calling the indictment 'an effort to dance around' the
controversial non-prosecution sweetheart deal Epstein and his associates received in
Florida in 2007.
With her bail now denied, Maxwell will return to the Metropolitan Detention Center in
Brooklyn.
Journalists had started lining up outside the federal court in downtown Manhattan at 6am
to get a seat inside the courtroom.
They were allowed in at 11.45am and had to stand 6ft apart while they waited to ensure
social distancing.
The hearing took place in the jury assembly room which normally has space for hundreds
of people but had a dramatically reduced capacity of just 60 due to the coronavirus.
A dial-in phone line allowed 1,000 more people to listen in - the capacity was increased
from 500 due to world-wide interest.
Inside the room there were two projector screens, which showed the proceedings live.
All parties, including the judge, appeared remotely and no one was physically in court.
Maxwell's lawyer was visible at all times in a box on the screen. Maxwell had her own
box, the judge had one and the prosecutors had another.
Maxwell's mugshot has not been released by the federal authorities and the hearing
offered the first chance to see her in at least a year.
Maxwell's whereabouts had largely been unknown since Epstein's arrest last July.
Although DailyMail.com tracked her down to the New England coast last summer, she
vanished again, later popping up in a photo at an In-N-Out in Los Angeles.
The FBI managed to finally trace her down in the quiet and rural town of Bradford, New
Hampshire earlier this month, where she had been living since December.
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rprise Women: Inspiratioi
Maxwell's mugshot has not been released by the federal authorities and the hearing offered the
first chance to see her in at least a year. Maxwell's whereabouts had largely been unknown
since Epstein's arrest last July. Although DailyMail.com tracked her down to the New England
EFTA00075180
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coast last summer, she vanished again, later popping up in a photo at an In-N-Out in Los
Angeles
M Patric k Me Marten en Cm ay Images
Maxwell was romantically involved with Jeffrey Epstein from around 1992, but then became his
'right-hand woman', managing his property empire and, it is alleged, his trafficking of minors
Officials said her conduct during the 8.30am raid at the property called 'Tuckedaway' was
'troubling'.
They wrote that when the FBI arrived they were confronted by a locked gate which they
forced their way through.
The filing said: 'As the agents approached the front door to the main house, they
announced themselves as FBI agents and directed the defendant to open the door.
'Through a window, the agents saw the defendant ignore the direction to open the door
and, instead, try to flee to another room in the house, quickly shutting a door behind her.
Agents were ultimately forced to breach the door in order to enter the house to arrest the
defendant, who was found in an interior room in the house.
'Moreover, as the agents conducted a security sweep of the house, they also noticed a
cell phone wrapped in tin foil on top of a desk, a seemingly misguided effort to evade
detection, not by the press or public, which of course would have no ability to trace her
phone or intercept her communications, but by law enforcement'.
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After Maxwell, the daughter of late newspaper tycoon Robert Maxwell, was arrested the
FBI spoke to a security guard who worked on the property who said that her brother had
hired him from a company staffed with former British military soldiers.
The filing states: 'The guard informed the FBI that the defendant had not left the property
during his time working there, and that instead, the guard was sent to make purchases for
the property using the credit card. As these facts make plain, there should be no question
that the defendant is skilled at living in hiding'.
In their filings to the court Maxwell's lawyers had argued that she is at increased risk of
catching the coronavirus whilst in prison. So far there have only been five cases and no
deaths at the prison.
They claim that the restrictions on access to her lawyers caused by the pandemic would
mean it was impossible for her to get a fair trial.
The prosecutors said that in fact the prison had made substantial efforts to accommodate
her and keep her safe.
EFTA00075182
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 2 of 19
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
UNITED STATES OF AMERICA
20 Cr. 330 (AJN)
GHISLA1NE MAXWELL,
Defendant.
x
THE GOVERNMENT'S REPLY MEMORANDUM
IN FURTHER SUPPORT OF DETENTION
The Government respectfully submits this reply memorandum in further support of its
motion for detention, dated July 2, 2020 (the "Detention Memorandum") (Dkt. 4), and in response
to the defendant's memorandum in opposition (the "Opposition Memorandum") (Dkt. 18).
The charges against Ghislaine Maxwell arise from her essential role in sexual exploitation
that caused deep and lasting harm to vulnerable victims. At the heart of this case are brave women
who are victims of serious crimes that demand justice. The defendant's motion wholly fails to
appreciate the driving force behind this case: the defendant's victims were sexually abused as
minors as a direct result of Ghislaine Maxwell's actions, and they have carried the trauma from
these events for their entire adult lives. They deserve to see her brought to justice at a trial.
There will be no trial for the victims if the defendant is afforded the opportunity to flee the
jurisdiction, and there is every reason to think that is exactly what she will do if she is released.
For the reasons detailed in the Detention Memorandum, and as further discussed below, the
defendant poses a clear risk of flight, and no conditions of bail could reasonably assure her
continued appearance in this case. Among other concerns: (1) she is a citizen of a country that
does not extradite its own citizens; (2) she appears to have access to considerable wealth
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 3 of 19
domestically and abroad; (3) her finances are completely opaque, as her memorandum pointedly
declines to provide the Court with information about her financial resources; and (4) she appears
to be skilled at living in hiding. These are glaring red flags, even before the Court considers the
gravity of the charges in this case and the serious penalties the defendant faces if convicted at trial.
Instead of attempting to address the risks of releasing a defendant with apparent access to
extraordinary financial resources, who has the ability to live beyond the reach of extradition in
France, and who has already demonstrated a willingness and ability to live in hiding, the defendant
instead proposes a bail package that amounts to little more than an unsecured bond. Among other
things, the proposed bail package contemplates the defendant pledging as the sole security a
property that is beyond the territory and judicial reach of the United States, and which therefore is
of no value as collateral. She proposes six unidentified co-signers, an unknown number of whom
even reside in the United States, and stone of whose assets are identified. The Court and the
Government have no information whatsoever regarding whether these co-signers would be able to
able to pay the proposed $5 million bond should the defendant flee — or if, of equal concern, the
co-signers are themselves so wealthy that it would be no financial burden whatsoever to do so.
The defendant does not identify what residence she proposes to live at in the Southern District of
New York, nor does she identify any meaningful ties to the area. And most importantly, the
defendant's memorandum provides the Court with no information whatsoever about her own
finances or her access to the wealth of others, declining to provide the Court the very information
that would inform any decision about whether a bond is even meaningful to the defendant — and
which the Government submits would reveal the defendant's financial means to flee and live
comfortably abroad for the rest of her life.
2
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 4 of 19
Finally, the Government recognizes that the COVID-19 pandemic is — and should be — a
relevant factor for the Court and the parties in this case. However, the Bureau of Prisons ("BOP")
is taking very significant steps to address that concern, and the defendant has offered no reason
why she should be treated any differently from the many defendants who are currently detained at
the Metropolitan Detention Center ("MDC") pending trial, including defendants who have medical
conditions that place them at heightened risk. Inmates at the MDC are able to assist in their own
defense, especially long before trial, through established policies and procedures applicable to
every pretrial detainee. This defendant should not be granted the special treatment she requests.
The defendant faces a presumption of detention, she has significant assets and foreign ties,
she has demonstrated her ability to evade detection, and the victims of the defendant's crimes seek
her detention. Because there is no set of conditions short of incarceration that can reasonably
assure the defendant's appearance, the Government urges the Court to detain her.
ARGUMENT
Each of the relevant factors to be considered as to flight risk — the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant —
weigh strongly in favor of detention, and the defendant's proposed package would do absolutely
nothing to mitigate those risks.
I. The Defendant's Victims Seek Detention
As the Court is aware, pursuant to the Crime Victims' Rights Act ("CVRA"), a crime
victim has the right to be reasonably heard at certain public proceedings in the district court,
including proceedings involving release. 18 U.S.C. § 377 l(a)(4). Consistent with that
requirement, the Government has been in contact with victims and their counsel in connection with
its application for detention. Counsel for one victim has already conveyed to the Government that
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their client opposes bail for the defendant, and has asked the Government to convey that view to
the Court. The Government also expects that one or more victims will exercise their right to be
heard at the July 14, 2020 hearing in this matter, and will urge the Court not to grant bail. More
generally, as noted above, the Government is deeply concerned that if the defendant is bailed, the
victims will be denied justice in this case. That outcome is unacceptable to both the victims and
the Government.
II. The Government's Case Is Strong
The defendant's motion argues, in a conclusory fashion, that the Government's case must
be weak because the conduct charged occurred in the 1990s. That argument, which ignores the
many specific allegations in the Indictment, could not be more wrong. As the superseding
indictment (the "Indictment") makes plain, multiple victims have provided detailed, credible
evidence of the defendant's criminal conduct. And while that conduct did take place a number of
years ago, it is unsurprising that the victims have been unable to forget the defendant's predatory
conduct after all this time, as traumatic childhood experiences often leave indelible marks. The
recollections of the victims bear striking resemblances that corroborate each other and provide
compelling proof of the defendant's active participation in a disturbing scheme to groom and
sexually abuse minor girls. In addition to compelling victim accounts, as the Government has
explained, the victims' accounts are corroborated by documentary evidence and other witnesses.
In particular, the victims' accounts are supported by contemporaneous documents and
records, such as flight records, diary entries, and business records. The powerful testimony of
these victims, who had strikingly similar experiences with Maxwell, together with documentary
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 6 of 19
evidence and witness testimony, will conclusively establish that the defendant groomed the victims
for sexual abuse by Jeffrey Epstein.'
The defendant's motion alludes to defenses in this case, all of which are legal or procedural
in nature, and none of which pass muster, let alone counsel in favor of bail. To begin with, the
notion that the defendant is protected from prosecution by the Non-Prosecution Agreement
("NPA") between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District ofFlorida
("SDFL") is absurd. That agreement affords her no protection in this District, for at least three
reasons. First, the defendant was not a party to that agreement nor named in it as a third-party
beneficiary, and the defendant offers no basis to think she would have standing to claim any rights
under the NPA. Tellingly, the defendant cites no authority for the proposition that an agreement
she was not a party to and that does not even identify her by name could possibly be invoked to
bar her prosecution. Second, and equally important, the NPA does not bind the Southern District
ofNew York, which was not a party to the agreement. See (lulledStates v. Annabl, 771 F.2d 670,
672 (2d Cir. 1985) (per curiam) ("A plea agreement binds only the office of the United States
Attorney for the district in which the plea is entered unless it affirmatively appears that the
agreement contemplates a broader restriction.")); (lulled States v. Prim), 391 F. App'x 920, 921
(2d Cir. 2010). This rule applies even when the text of the agreement refers to the signing party
as the "Government." Annab1, 771 F.2d at 672.
Third, and perhaps most important, even assuming the NPA could be read to protect this
defendant and bind this Office, which are both legally unsound propositions, the Indictment
Additionally, and beyond the strong evidence set forth in the Indictment, in just the past week,
and in response to the charges against the defendant being made public, the Federal Bureau of
Investigation ("FBI") and the U.S. Attorney's Office have been in touch with additional
individuals who have expressed a willingness to provide information regarding the defendant. The
Government is in the process of receiving and reviewing this additional evidence, which has the
potential to make the Government's case even stronger.
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New York prosecutors said in a filing Monday this was evidence that Maxwell was 'skilled at
living in hiding' and should be denied bail
ProposedBoil Conditions. In light of the above, we propose the following bail
conditions, which are consistent with those that courts in this Circuit have imposed in analogous
situations: 01 a S5 million personal recognizance bond, co-signed by six financially responsible
i eople, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United
kingdom worth over 53.75 million; (ii) travel restricted to the Southern and Eastern Districts of
New York; (iii) surrender of all travel documents with no new applications; (iv) strict
supervision by Pretrial Services: ( v ) home confinement at a residence in the Southern District of
New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate
family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's
office, except upon application to Pretrial Services and the government; and (viii) such other
terms as the Court may deem appropriate under Section 3142.
Her bail request (pictured) was filed in the US District Court in Manhattan and claims she was
not 'hiding' from authorities, is not a flight risk and is at risk of contracting COVID-19 if she
continues to be held in the Brooklyn jail
The case against her is 'strong' and multiple victims have provided 'detailed, credible
evidence of the defendant's criminal conduct' - with more women coming forward in the
past week.
The victims have made clear they want Maxwell remanded in custody and say they were
'directly abused as a result of Ghislaine Maxwell's actions'.
The document states: 'While that conduct did take place a number of years ago, it is
unsurprising that the victims have been unable to forget the defendant's predatory
conduct after all this time, as traumatic childhood experiences often leave indelible marks.
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'The recollections of the victims bear striking resemblances that corroborate each other
and provide compelling proof of the defendant's active participation in a disturbing
scheme to groom and sexually abuse minor girls'.
The prosecutors said that it was 'curious' that Maxwell claimed to have access to millions
of dollars had not offered 'a single dime' as collateral for her bond.
They claimed that Maxwell's finances were 'completely opaque' and she had not even
indicated which properties she would use for her bond.
Some of the co-signers are 'themselves so wealthy that it would be no financial burden
whatsoever' if they lost their $5 million by Maxwell skipping bail, the document states.
Epstein's victims have long demanded Maxwell's arrest and lawyers for them say that a
slew of new accusers have come forward since she was apprehended.
Prosecutors will likely be looking to do a plea deal with Maxwell to lighten some of the six
charges against her, two of which are perjury for allegedly lying during depositions.
They will be questioning her about powerful men in Epstein's orbit including Bill Clinton
with whom she flew on Epstein's private jet, called the 'Lolita Express', on a tour of Africa
in 2002.
Maxwell was also good friends with Prince Andrew and one of Epstein's victims,
ims she was loaned out to the Duke three times for sex when she was 17.
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Ghislaine Maxwell's attack-the-victim strategy may
backfire
bnnbloomberg.cakThislaine-maxwell•may-Olay-the-yictim-card-in-trial-defense-1.1465631
July 15, 2020
Ghislaine Maxwell Photographer: Laura Cavanaugh/Getty Images , Photographer: Laura
Cavanaugh/Getty Images
The bail hearing for Ghislaine Maxwell ended with a judge ruling that she must spend the
next year behind bars awaiting trial on sex-trafficking charges tied to her former boyfriend
Jeffrey Epstein. But it also offered hints at her defense strategy.
During the two-hour video-conference hearing Tuesday, Maxwell's lawyers questioned the
credibility of her accusers as well as the strength of the government's case.
While the arguments were designed to win bail, they'll likely be the same ones used at the
58-year-old's trial, which is scheduled to start next July. The federal charges stem from
events that are more than two decades old, Maxwell's lawyer, Mark Cohen, said, noting
that the government doesn't have "tapes or video" or other such evidence to support the
allegations.
"Absolutely, the defense is telegraphing where they're going," said David Weinstein, a
former federal prosecutor who listened in on Maxwell's hearing. "While the defense isn't
putting all of their cards on the table, they showed they're going to argue that she was as
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much a victim of Epstein -- much in the same way as these girls were -- and that she didn't
know what was going on behind closed doors."
Cohen briefly took aim a e of Maxwell's accusers. He said she has sued
Maxwell and is seeking a d set up for Epstein's victims, Cohen said.
Established in May, Epstein's victims can be compensated by the financier's estate, valued
at more than US$600 million.
That's a dangerous tactic that might backfire at trial, said David Boies, who represents
and several other women who say they were sexually abused by Epstein and
Maxwell.
It's "a tone-deaf argument" that cost Maxwell her credibility, said Boies, who listened to the
hearing remotely.
"To mount a 'blame the victim' defense, particularly in today's world and trying to blame
these girls for what happened is so contrary to the evidence, is so contrary to people's
normal sense of morality," Boies said. "I think that's just going to enrage a jury if she goes
to trial -- which I would not do if I were representing her."
Boies said he was confident would stand up to cross-examination if there's a trial.
who addressed the court by telephone, urged the judge not to grant Maxwell bail,
calling her a "sexual predator who groomed and abused me." Maxwell "lied under oath and
tormented her survivors," aid.
Boies said that as a 16-year-old who "wanted to go to college" when she met
Maxwell.
"Maxwell and Epstein tell and her mother 'we're having a group of high school
students to this ranch to help them get into college,"' Boies said. "But when gets
there, there are no high school students, all these claims are fraudulent and she's in this
isolated place in New Mexico."
Remote Hearing
Because of the pandemic, Maxwell's hearing was held remotely with press and the public
permitted to hear arguments over the phone. About 6o members of the press were allowed
to watch the proceeding on monitors in a jury room in the Manhattan courthouse, with the
judge, lawyers and Maxwell all in different locations.
Prosecutors also offered detail on their evidence, saying they have travel records,
photographs and other documents that will support the charges.
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Along with remarks, Assistant U.S. Attorney read from a letter
written by another of Maxwell's alleged victims, who asked to be identified only as Jane
Doe. It's possible that the woman may testify at the trial as well.
"Without Ghislaine Maxwell, Jeffrey Epstein could not have done what he did; she egged
him on," the woman said in the letter. She called Maxwell "a monster."
The judge scheduled the trial for July 12. The defense must file its pretrial motions by Dec.
21.
--With assistancefrom Bob Van Voris.
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Ghislaine Maxwell's neighbours tried to make her leave
town
O dailvmail.co.uk/news/article-8525759/Neighbors-Ghislaine•Maxwell-lover-tried•ostracize-couple-make-leave-
town.html
July 16, 2020
• Ghislaine Maxwell had been living with her tech CEO lover Scott Borgerson
at his home in Manchester-by-the-Sea outside of Boston until last December
• In February 2019 neighbors learned the quiet, well-dressed woman in their
midst had been accused of procuring young girls for pedophile Jeffrey Epstein
• 'They were absolutely appalled to learn who they were allowing to have the
run of their property,' one resident exclusively told DailyMail.com
• Neighbors tried to harass and 'ostracize' Maxwell into leaving, and make her
and Borgerson 'feel they weren't welcome on Sharksmouth or in Manchester'
• It led to a court case where Borgerson successfully fought the neighbors'
decision to stop them from using paths and a beach near the home that were
part of a 4o-acre estate with other homes
• A judge only made his ruling on March 11 this year, three months after
Maxwell had left Sharksmouth for good, moving to her hideaway in Bradford,
NH
• Borgerson is believed to have met Maxwell six years ago through speaking
engagements connected to ocean preservation
• They were both pictured speaking at the Arctic Circle Assembly in Reykjavik,
Iceland, in 2014
Ghislaine Maxwell's neighbors were so disgusted when they discovered an accused sex
trafficker was living among them that they tried to harass her into leaving, DailyMail.com
has learned exclusively.
It led to a court case where Maxwell's 14-years-younger lover Scott Borgerson successfully
fought the neighbors' decision to prevent them from using paths and a beach near their
Massachusetts oceanfront property, part of the 40-acre estate shared by other owners.
But the decision was not handed down until after Maxwell, 58, had already left for her new
life of seclusion in neighboring New Hampshire.
The small-town dispute involving the woman who was among the most-wanted in America,
all played out in quaint Manchester-by-the-Sea, a well-to-do town 3o miles north of Boston
where Maxwell was holed up with wealthy tech CEO Borgerson.
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But in February 2019 neighbors learned the quiet, well-dressed woman in their midst had
been accused of procuring young girls for pedophile Jeffrey Epstein — and they decided to
act.
'They were absolutely appalled to learn who they were allowing to have the run of their
property,' one resident told DailyMail.com.
'The second they learned she was involved with Epstein they decided to try to limit how
much they could use their land.'
Ghislaine Maxwell and Scott Borgerson's
neighbors were so disgusted when they
discovered an accused sex trafficker was
living among them that they tried to harass
her into leaving. Borgerson is believed to
have met Maxwell six years ago through
speaking engagements connected to ocean
preservation, a subject on which they share
a passion. They were both pictured speaking
at the Arctic Circle Assembly in Reykjavik,
Iceland, in 2014 (left and right)
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It led to a court case where Maxwell's lover Scott Borgerson successfully fought the
neighbors' decision to prevent them from using paths and a beach near their
Massachusetts oceanfront property. Borgerson, 44, bought the Phippin House (pictured), a
7-bedroom property, for $2.4M in June 2016, using a limited liability company called
Tidewood
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Jeffrey Epstein's victim claims it was the
British socialite who always set the trap
Ira dailvmail.co.uk/news/article-8535303/Jeffrev-Eosteins-victim-Maria-Farmer-claims-British-socialite-set-trap.html
July 17. 2020
'Ghislaine Maxwell was the mastermind': Jeffrey Epstein's victim
who was the first to blow the whistle on him claims it
was the British socialite who always set the trap
By Tom Leonard for the Daily Mail
Published: 17:25 EDT, 17 July 2020 I Updated: 17:25 EDT, 17 July 2020
•
•
• .e-mail
•
337 shares
For talented young artist , it was the night she'd been working towards for
months — her graduation show at the prestigious New York Academy of Art.
then 25, was ecstatic, having sold all three of her exhibited paintings for five-figure
sums.
Then a senior staff member appeared at her shoulder, took her arm and pointed out two
people she'd never seen before.
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outside New York court on
July 15, 2019
'This couple here are going to buy your art ..
. they're very important benefactors of the
academy,' she was told.
It was Jeffrey Epstein and Ghislaine
Maxwell, and they got the painting they
wanted — a semi-naked man observing a
sleeping girl, inspired by Edgar Degas's The
Rape — for $6,000, half the price had
been offered earlier.
Fast-forward 25 years and this week
younger sister gave an emotional statement
to a Manhattan court about why Maxwell
should not be granted bail.
Speaking via an audio feed from her home
in Texas, psychotherapist
one of three women whose claims are the
basis for the criminal case against the
British socialite, said Maxwell was a 'sexual
predator' who had 'never shown any
remorse for her heinous crimes or the
devastating, lasting effects her actions
caused'.
• who says she feels guilty for
unwittingly bringing her then teenage sister
into the orbit of Maxwell and Epstein, was the first person to report the pair's alleged
sexual abuse of underage girls in 1996. But her attempts to get the police and FBI to
investigate the attack on then 16, were ignored, leaving Epstein free to pursue his
depravity.
The sisters' story is shocking and their determination to get justice remarkable. Now, at
last, their voices are being heard. testimony was a key factor in the judge's decision
to deny Maxwell bail and keep her in a New York jail cell before her trial next year — which
is as it should be, told the Mail yesterday.
For her, Epstein — who was found dead in his remand jail cell last year — isn't the worst
villain in this scandal.
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'That woman was much more sinister than Epstein, and to me, much more dangerous,' she
says. 'She was definitely the mastermind. She was in charge.'
worked for Epstein, a financial guru, for a year, during which time she says she saw
first hand Maxwell's astonishing charm and her terrifying viciousness.
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Ghislaine Maxwell was `a sexual predator,' alleged victim says in new
testimony
By Isntuc V nc• July18.2020 I 6:32pm
Ghlslalne Maxwell
Penick McMullan via Getty lcnages
Ghislaine Maxwell had to find three girls a day to be sexually abused by her longtime associate, convicted pedophile Jeffrey
Epstein, according to blockbuster new testimony by an alleged victim who has waived her anonymity In the case.
"She was a sexual predator who abused me and countless other children and young women: told a federal
Judge who denied Maxwell, 58, ball Tuesday and ordered her to spend a year awaiting trial at the Brooklyn Detention
Center, where she has been held since shortly after her July 2 arrest in New Hampshire.
Farmer, now 41, is believed to be one of three victims — all of them minors at the time of the alleged abuse between 1994
and 1997 — in the case against Maxwell. She is is charged with helping Epstein sexually abuse girls as young as 14. If
convicted, Maxwell faces up to 35 years in prison.
Maxwell has denied any wrongdoing.
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Although prosecutors have not revealed all evidence, details of her abuse, which began when she was 16 and
flown to Epstein's ranch in New Mexico. were contained in a civil lawsuit filed last December.
Papers filed in Maxwell's case on Saturday allege that "Maxwell spent years overseeing and managing Epstein's sex-
trafficking network . . . Epstein's preference was to have three different girls a day for his sexual pleasure and Maxwell was in
charge of recruiting the girls." according to a report in the Sunday Times of London.
The documents say that rents divorced when she was young and her "mother struggled financially to support
her siblings".
"Maxwell appeared charming and friendly t pon arriving, Maxwell and Epstein took Annie shopping and lavished
her with gifts, including beauty products an rand new cowboy boots." Annie's older sister Maria, an artist, also
claims that she was abused by Epstein.
Maxwell and Epstein also took e a movie while she was in New Mexico. While they were standing in line,
Maxwell "pulled down Epstein' exposing part of his buttocks. Both Epstein and Maxwell repeatedly fondled
each other in front ofd to normalize sexual behavior to a child."
"Upon returning [to the ranch] from the movie, Maxwell repeatedly toleiat she wanted to give her a massage ...
Maxwell directed Annie to take off all of her clothes and lay on the massage table.
LAI a
Ghislaine
lieutenan
may be a next,
parents fear
"Maxwell touched intimate parts of body against her will for the sexual benefit of Maxwell and Epstein. Maxwell
exposed reasts and groped hernas extremely distressed and afraid. She was a child in a massive ranch,
away from her family, and isolated from any source of help."
The following morning, the court papers say. Epstein went to 'edroom got into bed demanding a "cuddle" and
sexually assaulted her.
lawyers claim that she decided to go public with her allegations only after Epstein's apparent suicide in a
Manhattan federal lockup in August: "Until his death, the plaintiff feared that Epstein and his co-conspirators, including
Maxwell, would harm her or her family, or ruin her life, if she came forward."
Maxwell, who has claimed that she only has $1 million left in her bank accounts, used to keep a "sex swing" and would hang
upside down "like a bat" on another device in an attempt to look younger, the newspaper reported.
FILFIJUN"),- GHISLAINE MAXWELL JEFFREY EPSTEIN, NEW MEXICO, SEXUAL ABUSE. 7/18/20
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Ghislaine Maxwell paid $25k to Jacob Wohl to 'smear
victims'
dailymail.co.ukThews/article-8531293/Ghislaine-Maxwell-Daid-25K-Jacob-Wohl-smear-victims-AG-fired.html
July 21, 2020
EXCLUSIVE: Ghislaine Maxwell paid $25K to fake news purveyor
Jacob Wohl to 'smear Epstein victims and to get prosecutor
Geoffrey Berman fired in attempt to stall sex trafficking
investigation against her'
• Ghislaine Maxwell hired Jacob Wohl to smear alleged victims of Jeffrey
Epstein and her, a former friend told DailyMail.com in an exclusive
interview
• As part of a $25k deal, Wohl and his lobbyist colleague Jack Burkman
also allegedly pushed to get former New York US Attorney Geoffrey
Berman fired
• Wohl and Burkman are far-right lobbyists who have become a laughing
stock in DC after several failed attempts to smear top political figures
• Maryland paralegal Kristin Spealman claims she was initially contacted
by the duo to use her in a smear campaign against Nancy Pelosi and Ted
Cruz
• Spealman told DailyMail.com they bragged to her they had been hired in
early June for $25,000 to dig up dirt on Maxwell's alleged sex trafficking
victims
• Federal documents filed this month show a company linked to Maxwell
had hired Wohl and Burkman to lobby on `issues relating to US DOJ,
Senate Judiciary, House Judiciary,' DailyMail.com can exclusively
reveal
• Berman's removal was intended to stall or stop the criminal investigation
into Maxwell, Spealman said
• Berman was ultimately pushed out by Barr in June, but two weeks later
Maxwell was charged as part of Epstein's sex trafficking ring
By Josh Boswell For Dailymail.com
Published: 09:15 EDT, 21 July 2O2O I Updated: 02:55 EDT, 22 July 2O2O
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6.7k shares
Ghislaine Maxwell hired fake news purveyor Jacob Wohl to smear her and Jeffrey Epstein's
alleged victims, a former friend has told DailyMail.com in an exclusive interview.
As part of a $25,000 deal made in June, Wohl and his lobbyist colleague Jack Burkman
also allegedly pushed to get New York US Attorney Geoffrey Berman, who had led Epstein's
case, fired in order to stall or stop the criminal investigation into Maxwell.
Wohl and Burkman are far-right lobbyists who have become a laughing stock in DC after
several failed attempts to smear top political figures including Elizabeth Warren, ICamala
Harris, Nancy Pelosi, Ted Cruz, Robert Mueller and Dr. Anthony Fauci by paying women
to make false claims of sordid affairs and drug-dealing.
One of the women they tried to use for their smear plots, Maryland model and paralegal
Kristin Spealman, told DailyMail.com the men had been hired by Maxwell, who currently
faces trial over charges she and Epstein trafficked underage girls for sex.
Spealman, 36, said the lobbyists bragged to her they had been hired in early June for
$25,000 to dig up dirt on Maxwell's alleged sex trafficking victims and to get Berman fired
using Burkman's supposed influence with Attorney General William Barr.
Berman ultimately stepped down after a push from Barr. But less than two weeks later,
Maxwell was charged on July 2 as being part of Epstein's sex trafficking ring and taken
into custody.
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Ghislaine Maxwell hired fake news purveyor and accused felon Jacob Wohl to smear
alleged victims of her and Jeffrey Epstein, Wohl's former friend has told DailyMail.com in
an exclusive interview
3/21
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As part of a $25,000 deal made in June,
Wohl (left) and his lobbyist colleague Jack
Burkrnan (right) also allegedly pushed to get
New York US Attorney Geoffrey Berman,
who had led Epstein's case, fired to stall or
stop the criminal investigation into Maxwell
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,\
as i ll, MAUREEN CALLAHAN
Authorities are letting Jeffrey Epstein's fixer Ghislaine Maxwell get
away with it
June 72. 7020 I 5100Prn
Jeffrey Epstein and Ghislaine Maxwell
Photo try Joe Schildhoin/Patrick McMullan via Getty Images
We got Osama bin Laden, but we can't catch a repulsive fugitive socialite?
Since the death of sex trafficker-rapist-pedophile Jeffrey Epstein last August, the woman who allegedly recruited his many,
many underage girls and sexually abused them herself has been in hiding.
And Ghislaine Maxwell has hardly been moving cave-to-cave.
Most recent reports put the 58-year-old in a luxury apartment in Paris, right off the Champs Elysees.
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At the risk of stating the obvious, Paris, too, is on COVID-19 lockdown. The Sun reports that Maxwell is currently living on
Avenue Matignon in the city's 8th arrondissement, in an apartment reportedly owned by a Normandy-based millionaire.
This would put her just five minutes away from the late Epstein's own Parisian apartment, which was raided shortly after his
suicide.
So: where is the urgency? Why hasn't this depraved criminal suspect, one who by many credible accounts sexually abused
minors for years, been arrested yet?
France may not have an extradition treaty with the U.S.. but that doesn't explain why French authorities haven't taken her
into custody. It's well-known that Jeffrey Epstein was a sexual predator who knew no geographic boundaries. Maxwell
appears to have been his madam, his pimp, his enabler, his co-conspirator, and reportedly a sexual offender herself.
The world would be better off without her moving around in it. Yet it seems there are powerful people who disagree. What
other explanation is there?
Maxwell is one of the world's most wanted women, sought by the FBI for questioning. Yet before the lockdown, she was
seen swanning around Paris. patronizing high-profile. four-star restaurants and cafés, dropping into art galleries. a scarf tied
around her head as if she were Jackie 0 on Fifth Avenue.
These are the defiant actions of a remorseless woman who knows she is well protected. Her hiding seems almost
performative. Maxwell isn't hunkered down on a private island or on a yacht in international waters. Her whereabouts are
well known.
Yet we're still playing "Where in the World is Ghislaine Maxwell?"
;luxury apartments on on Avenue Matignon in Paris where Maxwell has reportedly been living.
Luxury apartments on Avenue Matignon in Parrs where Maxwell has reportedly been living.
Getty Imaoes
There's a reason conspiracy theories still swirl around Epstein's suicide. At the time, he was likely the most high value
suspect in U.S. federal custody. As it was, his arrest was long overdue. His case made international headlines. He was on
suicide watch.
-Mg=
Ghislaine Maxwell
reportedly hiding from the
fads in plush Paris
apartment
And he was friends with very powerful men, heads of state and royals among them, hosted at his homes and on his private
island, flying on his private jet, known to all as The Lolita Express.
So the idea that none of these men knew about Jeffrey Epstein, again, defies the most basic logic.
Sure, Prince Andrew has "stepped down" as a senior royal. So what? What does that even mean? He has never faced any
consequences of any kind, even though Virginia Guiffre Roberts has made consistent and credible claims that Epstein sex
trafficked her to Andrew when she was just 17.
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And that Maxwell recruited and groomed her back in 1999, along with many other underage girls through the years.
Maxwell doesn't even have the temerity of a Roman Polanski, who also fled to France and whose stance for decades has
been "Yes, I raped a 13-year-old girl. Bygones."
We are living in a fraught and electric moment, one in which all manner of injustice is no longer tolerated, protests in the
streets day after day, forcing us to ask hard and painful questions in pursuit of a fairer and freer world.
She dreamed
of walking
like other
kids.
DONATE NOW
MrliM
Don't let Ghislaine Maxwell benefit from this as a distraction. Make her part of it. Make her — and whoever else, no matter
how powerful — pay.
El ls I) UN) FBI, FRANCE, GHISLAINE MAXWELL, JEFFREY EPSTEIN, PARIS, SEX TRAFFICKING, 6/22/20
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Ghislaine Maxwell latest news: Socialite and Jeffrey
Epstein said to have had `mysterious' relationship over
the years
thesun.co.ukinews/12041691/ghislaine-maxwell-liye-jeffrey-eostein-latest-news/
July 29, 2020
JAIL BIRD
- Who is Ghislaine Maxwell and where is she now?
- Is Scott Borgerson Ghislaine Maxwell's husband?
- Who was Ghislaine's famous father Robert Maxwell?
- More news on Ghislaine Maxwell
Live Blog
• Alex Winter
• Debbie White
• 29 Jul 2O2O, 15:O9
• Updated: 29 Jul 2O2O, 15:O9
Ghislaine Maxwell and Jeffrey Epstein are said to have had a "mysterious" relationship
over the years.
The two are thought to have linked up not long after she moved to New York in 1991.
One pal claims that Epstein and Maxwell were not linked romantically as has been often
reported, but instead their relationship was a financial one.
"I couldn't work out at first how, the second Ghislaine landed in New York, she was all of a
sudden — overnight really — very chummy with Jeffrey," the source said.
"Then he started spending on a different level, suddenly buying these extraordinary
townhouses."
Meanwhile, Ghislaine Maxwell could strike a plea deal, exonerate Prince Andrew from any
wrongdoing and walk in a few years, according to a pal.
An anonymous friend told the Sunday Times that they expect her to get a good deal with
the prosecutors by turning on key members of the Epstein inner circle.
But the pal said Maxwell would use the deal to "exonerate" Prince Andrew of his alleged
links - with the Duke of York denying any wrongdoing.
Follow our live blog below for all the latest news and updates on the Ghislaine
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Jeffrey Epstein rape survivor, now 22, claims
paedophile was abusing girls right up to his death
thesun.co.uktnews/12220305/ieffrev-eostein-raoe-survivor-claims-billionaire-abusina-oirls-rioht-deathi
Patrick July 24, 2020
Knox
A JEFFREY Epstein rape survivor believes the warped financier was still abusing girls right
up until he was jailed and hanged himself.
The former model claimed this will leave behind a "second wave" of younger victims too
afraid to even tell their parents.
®Click here for the latest news on Ghislaine Maxwell
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2
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Jeffrey Epstein's mugshot after his arrest in 2019.... one of his victims claims he was abusing right up to
this pointCredit: AFP or licensors
Sillas Mir
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2
The girl alleges she was raped by Epstein in his Manhattan mansion — dubbed the House of Horrors by
many of his victimsCredit: Getty Images - Getty
The woman who was speaking to DailyMail.com says she was raped and molested during
two visits to Epstein's mansion in New York, in the summer of 2015.
She said: "I believe he was abusing young girls right up until the day he was arrested.
"There are likely to be multiple young victims out there who are still in their teens, perhaps
still living with their parents and too ashamed and confused to speak out.
"I know how it feels because I was one of them. I thought about suicide, I tried to cut my
wrists. These girls need support before it's too late.
"They need to know it's OK to tell their stories."
She contacted the FBI and police after Epsetin's arrest last July 6 on federal sex trafficking
charges filed in the Southern District of New York because she knew Epstein was locked
up.
The 22-year-old, who is thought to be the youngest woman to come forward, wants to
remain anonymous because she fears reprisals from Epstein's powerful pals and
accomplices.
This is despite the 66-year-old being found hanged in a New York jail cell nearly a year
ago.
Marie was an aspiring 16-year-old model in the Autumn of 2014 when she met an older
woman called Madison in a bar.
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There are likely to be multiple young victims out there who are still in their teens, perhaps
still living with their parents and too ashamed and confused to speak out
Epstein victim
Last week Ms Maxwell pleaded not guilty to charges that in the 1990s she recruited three
girls, one aged 14, for Epstein to sexually abuse.
It is also alleged that she sometimes participated in the abuse during massage sessions at
Epstein's Manhattan mansion and properties in Palm Beach, New Mexico and London. She
also denies this.
When Epstein brought her into a dimly lit room with red velvet curtains she claimed he
began fondling her, saying it was normal for young models to do "favours" for older men in
the fashion industry.
She was later raped by Epstein, who in doing so took her virginity.
Epstein was subject to two criminal indictments.
One focused largely on his activities in Palm Beach, Florida before 2008 when Epstein
signed a controversial non-prosecution deal to avoid federal charges.
The other cites abuse in New York, Florida and other locations between 2002 and "at least
in or about 2005".
But civil lawsuits give a broader timeframe for his crimes..
A January 2020 suit filed by prosecutors in the US Virgin Islands alleges that Epstein
trafficked, raped and abused children on his private island as recently as 2019.
This was the year he was arrested and was later found dead last August 10.
Jeffrey Epstein accusers claim he rigged his New York mansion with CCTV and kept videos
to use as blackmail
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Ghislaine Maxwell latest news: Socialite and Jeffrey
Epstein said to have had `mysterious' relationship over
the years
g thesun.co.ukinews/12041691/ghislaine-maxwell-liye-jeffrey-eostein-latest-news/
July 29. 2020
JAIL BIRD
- Who is Ghislaine Maxwell and where is she now?
- Is Scott Borgerson Ghislaine Maxwell's husband?
- Who was Ghislaine's famous father Robert Maxwell?
- More news on Ghislaine Maxwell
Live Blog
• Alex Winter
• Debbie White
• 29 Jul 2O2O, 15:09
• Updated: 29 Jul 2O2O, 15:09
Ghislaine Maxwell and Jeffrey Epstein are said to have had a "mysterious" relationship
over the years.
The two are thought to have linked up not long after she moved to New York in 1991.
One nal claims that Epstein and Maxwell were not linked romantically as has been often
reported, but instead their relationship was a financial one.
"I couldn't work out at first how, the second Ghislaine landed in New York, she was all of a
sudden — overnight really — very chummy with Jeffrey," the source said.
"Then he started spending on a different level, suddenly buying these extraordinary
townhouses."
Meanwhile, Ghislaine Maxwell could strike a plea deal, exonerate Prince Andrew from any
wrongdoing and walk in a few years, according to a pal.
An anonymous friend told the Sunday Times that they expect her to get a good deal with
the prosecutors by turning on key members of the Epstein inner circle.
But the pal said Maxwell would use the deal to "exonerate" Prince Andrew of his alleged
links - with the Duke of York denying any wrongdoing.
Follow our live blog below for all the latest news and updates on the Ghislaine
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