EFTA00090721Set 9
2021-09-0352p13,922w
Defendant in
this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure
the absence of delay ... Court, unambiguously and emphatically,
directed: "The Government is FURTHER ORDERED to disclose all co-conspirator hearsay
statements it intends to offer at trial no later than October 11, as consistent ... original.)
The Court used the word "disclose" both as to the identity of the co-conspirators "to
whom the government will refer to at trial" and "all co-conspirator hearsay
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090721.pdf
EFTA00592369Set 9
2017-03-3194p24,655w
want to redact.
24 Maxwell -- they want to redact this: "was a primary
25 co-conspirator in Epstein's sexual abuse and sex trafficking
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00592397
H3ulgiva ... redact, "in a fashion very similar to
the manner in which Epstein and his co-conspirators coerced
4 dozens of other children." So they want to redact everything
5 that ... think --
11 THE COURT: Well, her allegation is that Maxwell was a
12 co-conspirator.
13 MR. CASSELL: Correct.
14 THE COURT: We're not talking about --
15 MR. CASSELL
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592369.pdf
EFTA00804328Set 9
2016-02-1057p17,298w
page prosecution memorandum and a 53-page indictment against Epstein and his
co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the
Government ... agents of the abuse that they endured at the hands of Epstein and his
co-conspirators. In September 2007, without conferring with any of the victims, the Government
and Epstein ... alternative charges, they discussed charging
Epstein with: (1) various misdemeanors, (2) assaulting his co-conspirators and girlfriend, (3)
using private investigators to chase and harass victims' families, (4) obstructions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804328.pdf
EFTA00102999Set 9
2019-03-26239p78,398w
application to
other districts—based on no textual indicia—into the provision relating to co-conspirators.
Moreover, the defendant's reading of the NPA would require the Court to adopt ... reach the counterintuitive
conclusion that Epstein expressly bargained for broader immunity for his co-conspirators than he
did for himself. That is, under the defendant's reading of the agreement ... Epstein bargained to
protect co-conspirators nationally for crimes they committed with Epstein, but Epstein only sought
protection for himself in the Southern District of Florida. The text
https://www.justice.gov/epstein/files/DataSet%209/EFTA00102999.pdf
EFTA00809690Set 9
2018-08-2251p13,224w
participation in a massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein, an uncharged
co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp ... result of his role in this Ponzi scheme, Epstein
has remained an uncharged co-conspirator.2 All the while, Epstein knowingly and intentionally
utilized funds he fraudulently diverted and obtained ... conduct that resulted in Hoffenberg's
conviction and which was imputed to Hoffenberg's co-conspirators. See Exhibit A.
'See Exhibit B which is an affidavit from Hoffenberg detailing Defendants
https://www.justice.gov/epstein/files/DataSet%209/EFTA00809690.pdf
EFTA00145606Set 9
2017-01-1037p15,406w
advocate for my rights as a sex trafficked
victim of Epstein, Maxwell and their co-conspirators, David Boies and his firm
informed me that they would re me only ... young ballerina I tried to protect from Epstein and Maxwell and the co-conspirators.
We were both raped repeatedly by Epstein whilst on the island together. I wanted to
reach ... give my evidence about Jeffrey
Epstein and his co-conspirators. Although my case had been settled (to my detriment
and to silence me...again), I still wanted to hold these
https://www.justice.gov/epstein/files/DataSet%209/EFTA00145606.pdf
EFTA00802452Set 9
1997-03-0425p6,896w
September 14, 2018 and submitted
herewith.
EFTA00802455
did not know Defendant Epstein was the "co-conspirator" Plaintiffs admit knowing about for 20
years.
It therefore bears mention that this action ... Defendants and others, including by falsely accusing Defendant
Epstein of being the so-called co-conspirator:
• 2001: Judge Berman dismissed a similar case in which Hoffenberg attempted ... filed a Verified Petition to perpetrate Epstein's testimony,
alleging Epstein was Hoffenberg's "co-conspirator" in the same fraudulent
activities described in the Complaint in this action. Hoffenberg also
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802452.pdf
EFTA01653490Set 10
2019-07-060p25,849w
Additional Subject Offenses"). The
Target Subjects of this investigation are known and unknown co-conspirators of JEFFREY
EPSTEIN, including but not limited to and GHISLAINE MAXWELL.
II. Probable Cause ... activity beyond that outlined in the indictment, as well as at least two potential co-conspirators:
and GHISLAINE MAXWELL.
17. Count One of the Indictment alleged that JEFFREY EPSTEIN conspired ... participation in this investigation, I have reason to believe that
EPSTEIN and his co-conspirators committed and/or maintained evidence of the Original and
Additional Subject Offences in and around
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01653490.pdf
EFTA00028880Set 8
2016-01-1123p6,182w
Applies to Ms. Maxwell, and She Has Standing to Enforce It. 2
II. The Co-Conspirator Immunity Provision is Not Limited to the SDFL. 7
III. The Co-Conspirator Immunity ... limitation, that "the United States .. . will not institute any
criminal charges against any potential co-conspirators of Epstein." Because the Superseding
Indictment ("Indictment") contends that Ms. Maxwell was a co ... intended to immunize only the four individuals
specifically named in the co-conspirator immunity provision, the government flagrantly ignores
the express statement that immunity is "not limited to" those individuals
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028880.pdf
EFTA00088802Set 9
2021-10-1184p23,883w
Applicable Law 44
C. Discussion 45
IV. There is No Basis to Preclude Co-Conspirator Statements at Trial 54
A. Background 55
B. Discussion 58
EFTA00088803
V. There ... Fourth, there is no
basis to preclude the introduction of co-conspirator statements under Fed. R. Evid. 801(d)(2)(E).
(See Def. Mot. 1). Fifth, Minor Victim ... should be put before
the jury.
IV. There is No Basis to Preclude Co-Conspirator Statements at Trial
On October 11, the Government provided the defense with comprehensive Jencks
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088802.pdf
EFTA00612483Set 9
2015-10-2035p8,537w
included allegations of RRA as an "Enterprise" in
which Rothstein and his yet unidentified co-conspirators engaged in a
racketeering conspiracy, money laundering conspiracy, mail and wire
fraud conspiracy ... fraud, and specifically alleged that (a)
potential investors were told by Rothstein and other co-conspirators that
confidential settlement agreements were available for purchase; (b)
settlements were allegedly available ... repaid to the investors at face value over time; (c)
Rothstein and other co-conspirators utilized the offices of RRA and the
offices of other co-conspirators to convince potential
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612483.pdf
EFTA01433867Set 10
2018-08-2029p7,744w
participation in a massive Ponzi scheme perpetrated by Defendant Jeffrey
Epstein, an uncharged
co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The
Financial Trust Company,
XYZ Corp ... result of his role in this Ponzi
scheme, Epstein
has remained an uncharged co-conspirator.2 All the while, Epstein knowingly
and intentionally
utilized funds he fraudulently diverted and obtained ... conduct that resulted
in Hoffenberg's
conviction and which was imputed to Hoffenberg's co-conspirators. See
Exhibit A.
EFTA01433868
3 See Exhibit B which is an affidavit from Hoffenberg
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01433867.pdf
Page 1 of 1
EFTA01682078
Individual Role Known counsel? Possible Location Notes
IMO suspected co-conspirator
suspected co-conspirator
no, but ask Hammad questions
no, but ask Hammad questions
suspected ... co-conspirator no, but ask Hammad questions
Maxwell Ghislaine suspected co-conspirator no, but ask Hammad questions
suspected co-conspirator no, but ask Hammad questions
•Brunel, Jean Luc suspected co ... conspirator
suspected co-conspirator / victim no, but ask Hammad questions
victim / recruiter
victim / recruiter
victim previously contacted in this investigation
victim previously contacted in this investigation
victim previously contacted
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01682078.pdf
EFTA00795983Set 9
2018-08-2116p3,378w
companies, totalling
$1.1 million.
til December 1987 and June 1988, Hoffenberg And his
Between
co-conspirators again used Associated and United Fire bonds as
collateral in securities brokerage accounts ... Finally, in a further attempt to conceal their
activities, Hoffenberg and his co-conspirators filed a lawsuit in
the United States District Court for the Northern District of
Illinois against ... Hoffenberg decided to expand'Towers.
In order to raise capital, he and his co-conspirators devised a
plan to sell Promissory Notes (the "Notes"). Towers sold the Notes
in private
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795983.pdf