The document is a letter from the US Department of Justice to Judge Alison J. Nathan, arguing that M...
The document is a letter from the US Department of Justice to Judge Alison J. Nathan, arguing that Minor Victim-3's testimony is admissible as direct evidence or under Rule 404(b) in the trial of Ghislaine Maxwell. The government claims that Minor Victim-3's testimony will help establish Maxwell's relationship with Jeffrey Epstein and her involvement in the alleged conspiracies.
Summary
The document is a letter from the US Department of Justice to Judge Alison J. Nathan, arguing that Minor Victim-3's testimony is admissible as direct evidence or under Rule 404(b) in the trial of Ghislaine Maxwell. The government claims that Minor Victim-3's testimony will help establish Maxwell's relationship with Jeffrey Epstein and her involvement in the alleged conspiracies.
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EFTA00011452
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24 ORIGINAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. SUPERSEDING INDICTMENT S2 20 Cr. 330 (AJN) COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex 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 2004, 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 victi
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
GRAND JURY [EFTA00008998]
GRAND JURY EXHIBIT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA SUPERSEDING INDICTMENT GHISLAINE MAXWELL, Defendant. S1 20 Cr. 330 (AJN) COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW The char...
EFTA00021842
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18 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 Sex 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 victim
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