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Subject: RE: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed

From To Cc Subject: RE: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Date: Sat, 12 Sep 2020 00:18:12 +0000 Attachments: 2020.09.04_Govemment_letter_in_support_of stay.pdf The letter was publicly filed on the docket in the civil case, per Judge Freeman's order. The version from ECF is attached. From:I.INSANYS) [Contractor] Sent: n a , e tem r 11, 2020 3:11 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: FW: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Here's the Telegraph story that quotes from the letter. From: Sent: Friday, September 11, 2020 3:06 PM To: Subj : w L rosecutors inGhislaine axwe ase s or a t to ivi rocee This is the Telegraph story... Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceedings Against British Heiress 2020-09-11 18:16:21.827 GMT By Josie Ensor (Telegraph) -- Federal prosecutors pursuing child sex trafficking charges against Ghislaine Maxwell say the

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From To Cc Subject: RE: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Date: Sat, 12 Sep 2020 00:18:12 +0000 Attachments: 2020.09.04_Govemment_letter_in_support_of stay.pdf The letter was publicly filed on the docket in the civil case, per Judge Freeman's order. The version from ECF is attached. From:I.INSANYS) [Contractor] Sent: n a , e tem r 11, 2020 3:11 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: FW: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Here's the Telegraph story that quotes from the letter. From: Sent: Friday, September 11, 2020 3:06 PM To: Subj : w L rosecutors inGhislaine axwe ase s or a t to ivi rocee This is the Telegraph story... Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceedings Against British Heiress 2020-09-11 18:16:21.827 GMT By Josie Ensor (Telegraph) -- Federal prosecutors pursuing child sex trafficking charges against Ghislaine Maxwell say the

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From To Cc Subject: RE: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Date: Sat, 12 Sep 2020 00:18:12 +0000 Attachments: 2020.09.04_Govemment_letter_in_support_of stay.pdf The letter was publicly filed on the docket in the civil case, per Judge Freeman's order. The version from ECF is attached. From: I.INSANYS) [Contractor] Sent: n a , e tem r 11, 2020 3:11 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: FW: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Here's the Telegraph story that quotes from the letter. From: Sent: Friday, September 11, 2020 3:06 PM To: Subj : w L rosecutors inGhislaine axwe ase s or a t to ivi rocee This is the Telegraph story... Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceedings Against British Heiress 2020-09-11 18:16:21.827 GMT By Josie Ensor (Telegraph) -- Federal prosecutors pursuing child sex trafficking charges against Ghislaine Maxwell say their case would be jeopardised if a separate civil lawsuit against the heiress was allowed to continue, in an extraordinary appeal to the judge. Prosecutors from the Southern District of New York (SDNY) have argued that there is a "factual overlap between the civil and criminal cases" and there was "significant risk" that proceeding with the civil suit jeopardises the criminal prosecution against Ms Maxwell. The civil suit, filed earlier this year under the pseudonym Jane Doe, contains allegations that are substantially similar to those in the criminal indictment against Ms Maxwell, who allegedly groomed three minor girls to be abused by Epstein in the mid-1990s. EFTA00089600 Ms Maxwell, 58, who is being detained in a federal prison in Brooklyn until her trial next year, has pleaded not guilty to the charges and has denied the allegations in the civil suit. The woman, now 40, alleges that she was first approached at age 13 by Epstein and Ms Maxwell in 1994 at a summer camp in Michigan and that a months-long grooming process by the pair continued after she returned home to Florida. She claims she was then subjected to years of sexual abuse. "Witnesses may be forced to testify about any efforts to assist the criminal investigation and prosecution, and may thereby expose facts about the investigation ... and could potentially expose witnesses and/or their families to harassment," states the SDNY's letter filed on Thursday. "Moreover, permitting any discovery to proceed in this lawsuit would enable Maxwell to seek a preview of trial testimony in the criminal case, and would afford her with a broader array of discovery than she is entitled to in the criminal case." By advocating for a stay in the civil case, the government finds itself, in this instance, aligned with Ms Maxwell and the co-executors of Epstein's estate, who have been arguing that the case should be placed on hold while criminal investigation remains open. The disgraced late financier left behind an estate worth an estimated $577(£450m) million after he was found dead in his prison cell five weeks after his arrest on July 6, 2019 on multiple sex-trafficking charges. A number of his victims are suing the estate, arguing they should be compensated for the abuse they suffered. Robert Glassman, a lawyer representing Jane Doe, wrote in a letter to the court that his client "is best served by pressing forward with her claims — not waiting even longer for justice. "A stay of the civil proceedings would provide what defendant Maxwell has sought for years - concealing her heinous acts from public view," he said. A court in Manhattan is also due to hear oral arguments on September 22 in the civil defamation case filed against Ms Maxwell by [REDACTED], a victim of Epstein's, in the decision over whether to unseal "sensitive" evidence. -0- Sep/11/2020 18:16 GMT To view this story in Bloomberg click here: https://blinks.bloomberg.corn/news/stories/QGIAR93HBS3K EFTA00089601

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United States v. Ghislaine Maxwell 20 Cr. 330 INN/ Testifying Witness 3500 Material 10/25/2021 Date Description Attorney Produced to Defense 2021.02.01 Notes from phone cal 2021.04.23 3502402 202102 01 Testimony disclosure 2021.04.23 3502-003 2021.03.03 Notes from phone cal 2021.04.23 3502404 2021.04.09 Interview notes 2021.04.23 3502405 2021.04.21 2021.04.23 3502-006 S e some 2021.04.23 3502-007 Contract for services 2021.04.23 3502-008 2021.10.21 Notes 2021.10.25 3502-009 2021.10.24 Notes 2021.10.25 3502-010 2006 Article 2021.10.25 3502-011 2009 Article 2021.10.25 3502-012 2010 Article 2021.10.25 3502-013 2014 Article 2021.10.25 3502-014 2015 Article 2021.10.25 3502-015 2015 Article 2021.10.25 3502-016 2015 Article 2021.10.25 3502-017 2016 Article 2021.10.25 3502-018 2017 Article 2021.10.25 3502-019 2018 Article 2021.10.25 3502-020 2018 Article 2021.10.25 3502-021 2019 Article 2021.10.25 3502-022

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(USANYS) [Contractor]"

From: To: Cc: ' (USANYS) [Contractor]" USANYS)" (USANYS)" (USANYS)" Subject: FW: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed Date: Fri, 11 Sep 2020 19:11:03 +0000 Here's the Telegraph story that quotes from the letter. From: Patricia Hurtado (BLOOMBERG/ FEDERAL C) Sent: Friday, September 11, 2020 3:06 PM To: (USANYS) < >; (USANYS) [Contractor] Subject: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed This is the Telegraph story... Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceedings Against British Heiress 2020-09-11 18:16:21.827 GMT By Josie Ensor (Telegraph) -- Federal prosecutors pursuing child sex trafficking charges against Ghislaine Maxwell say their case would be jeopardised if a separate civil lawsuit against the heiress was allowed to continue, in an extraordinary appeal to the judge. Prosecutors from the Southern District of New York (SDNY) have argued that there is a "f

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