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efta-efta00078497DOJ Data Set 9Other

Subject: Maxwell - UMR

From Subject: Maxwell - UMR Date: Thu, 02 Jul 2020 13:31:26 +0000 FROM: UNITED STATES ATTORNEY SOUTHERN DISTRICT OF NEW YORK PHONE: 212-637-2200 DISTRICT POC: Audrey Strauss. Acting U.S. Attorney Phone: SYNOPSIS: At approximately 8:30am on Tuesday, July 2, FBI-NY in conjunction with the USAO-SDNY arrested Ghislaine Maxwell, the former girlfriend and close confident of Jeffrey Epstein, on multiple counts stemming from her role in facilitating Epstein's sexual abuse of minor girls between approximately 1994 and 1997 in Palm Beach, Florida, New York, New York, Santa Fe, New Mexico, and London, England. Maxwell was arrested in Bradford, New Hampshire, and is expected to be presented later today at the United States District Court for the District of New Hampshire. DESCRIPTION: Since approximately December 2018, the USAO-SDNY has been investigating Jeffrey Epstein and his associates for their roles in abusing dozens of minor victims over a multi-year period. Between approx

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Unknown
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DOJ Data Set 9
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EFTA 00078497
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2
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2
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Summary

From Subject: Maxwell - UMR Date: Thu, 02 Jul 2020 13:31:26 +0000 FROM: UNITED STATES ATTORNEY SOUTHERN DISTRICT OF NEW YORK PHONE: 212-637-2200 DISTRICT POC: Audrey Strauss. Acting U.S. Attorney Phone: SYNOPSIS: At approximately 8:30am on Tuesday, July 2, FBI-NY in conjunction with the USAO-SDNY arrested Ghislaine Maxwell, the former girlfriend and close confident of Jeffrey Epstein, on multiple counts stemming from her role in facilitating Epstein's sexual abuse of minor girls between approximately 1994 and 1997 in Palm Beach, Florida, New York, New York, Santa Fe, New Mexico, and London, England. Maxwell was arrested in Bradford, New Hampshire, and is expected to be presented later today at the United States District Court for the District of New Hampshire. DESCRIPTION: Since approximately December 2018, the USAO-SDNY has been investigating Jeffrey Epstein and his associates for their roles in abusing dozens of minor victims over a multi-year period. Between approx

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From Subject: Maxwell - UMR Date: Thu, 02 Jul 2020 13:31:26 +0000 FROM: UNITED STATES ATTORNEY SOUTHERN DISTRICT OF NEW YORK PHONE: 212-637-2200 DISTRICT POC: Audrey Strauss. Acting U.S. Attorney Phone: SYNOPSIS: At approximately 8:30am on Tuesday, July 2, FBI-NY in conjunction with the USAO-SDNY arrested Ghislaine Maxwell, the former girlfriend and close confident of Jeffrey Epstein, on multiple counts stemming from her role in facilitating Epstein's sexual abuse of minor girls between approximately 1994 and 1997 in Palm Beach, Florida, New York, New York, Santa Fe, New Mexico, and London, England. Maxwell was arrested in Bradford, New Hampshire, and is expected to be presented later today at the United States District Court for the District of New Hampshire. DESCRIPTION: Since approximately December 2018, the USAO-SDNY has been investigating Jeffrey Epstein and his associates for their roles in abusing dozens of minor victims over a multi-year period. Between approximately 1994 and 1997, Maxwell was in an intimate relationship with Epstein, was paid by Epstein to manage his various properties, and was one of Epstein's closest associates. Evidence gathered during our investigation establishes that, beginning in at least 1994, Maxwell enticed and groomed multiple minor girls to engage in sex acts with Epstein. Maxwell did so by befriending minor victims, and then, after developing a rapport with them, normalizing sexual abuse by discussing sexual topics and undressing in front of the victim, and ultimately being present when the victim was undressed, and/or subjected to sex acts involving Epstein. Maxwell did so knowing that the victims were minors and that Epstein intended to engage in sex acts with those minors. Additionally, in or around 2016, in the context of a deposition as part of civil litigation, Maxwell repeatedly provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the abuse of minor victims by Jeffrey Epstein, including several of the victims alleged to have been abused as part of the crimes being charged. As previously reported in an Urgent Matter Report filed on June 29, 2020, the USAO-SDNY recently sought an indictment charging Maxwell with one count of conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; one count of enticement of a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 2422; one count of conspiracy to transport minors with intent to engage in criminal sexual activity, in violation of 18 U.S.C. § 371; one count of transporting a minor with intent to engage in criminal sexual activity, in violation of 18 U.S.C. § 2423(a); and two counts of perjury, in violation of 18 U.S.C. § 1623. At the time the indictment was obtained, Maxwell's precise whereabouts were unknown. Maxwell, who has intentionally evading detection since Epstein's arrest in July 2019, was located by the FBI at a residence in EFTA00078497 Bradford, New Hampshire, which she appears to have purchased through an LLC in December 2019. She was arrested at approximately 8:30am this morning and will be presented later this afternoon at the United States District Court for the District of New Hampshire. EFTA00078498

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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

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