EFTA00091353Set 9
2014-12-3024p10,201w
COURT
SOUTHERN DISTRICT OF NEW YORK
X
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
X
DEFENDANT GHISLAINE MAXWELL'S RESPONSES AND OBJECTIONS TO
PLAINTIFF'S SECOND REQUEST ... PRODUCTION OF DOCUMENTS
Defendant Ghislaine Maxwell, by and through her undersigned counsel, hereby responds
to Plaintiff's Second Request for Production of Documents (the "Requests").
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS ... This response is made to the best of Ms. Maxwell's present knowledge,
information and belief. Ms. Maxwell, through her attorneys of record, have not completed the
investigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091353.pdf
EFTA00092886Set 9
2021-07-1234p11,087w
YORK DATE FILED: 4/16/21
United States of America,
—v—
20-cr-330 (MN)
Ghislaine Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned ... count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein's sexual abuse of minor victims from around
1994 to 1997. The Government filed a first (S1) superseding ... commit those offenses. It also included two
counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to
begin on July 12, 2021.
Maxwell
https://www.justice.gov/epstein/files/DataSet%209/EFTA00092886.pdf
EFTA00090721Set 9
2021-09-0352p13,922w
YORK
x
UNITED STATES OF AMERICA,
S2 20 Cr. 330 (AJN)
v.
GHISLAINE MAXWELL,
Defendant.
x
GHISLAINE MAXWELL'S REPLY IN SUPPORT OF
HER MOTIONS IN LIMINE
Jeffrey S. Pagliuca ... York NY
Phone:
Bobbi C. Stemheim
Law Offices of Bobbi C. Stemheim
Attorneysfor Chislaine Maxwell
EFTA00090721
TABLE OF CONTENTS
I. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO-
CONSPIRATOR STATEMENTS ... constitutes an impermissible constructive
amendment and variance to the Indictment. 13
C. Ms. Maxwell reiterates her re, uest to defer briefing and ruling on the admissibility
for two weeks
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090721.pdf
EFTA00594211Set 9
2015-09-2118p3,615w
Quash under the
pseudonym "Jane Doe No. 3" filed a lawsuit captioned v. Ghislaine Maxwell,
Case No. 15-cv-07433 (S.D.N.Y.) (the "Maxwell Action"). A copy of the complaint ... Maxwell Action is attached as Exhibit A. By publicly filing the complaint in the Maxwell
Action in her own name, "=") made a voluntary decision to identify
herself and therefore ... Motion to Quash,
chose to identify herself publicly even before she filed the Maxwell Action. Moreover, at a
EFTA00594211
Even more significantly, public allegations in the Maxwell Action eliminate
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594211.pdf
EFTA01565004Set 10
2013-01-01147p14,188w
GHISLAINE MAXWELL
EFTA01565004
EFTA01565005
For the Period 1/1/13 to 1/31/13
Account Summary
Account
Number
Investment Account(s)
GHISLAINE MAXWELL
GHISLAINE MAXWELL
GHISLAINE MAXWELL - OAP IHD
GHISLAINE MAXWELL - TAP DYS
GHISLAINE ... MAXWELL - TAP ARFI
i
Total Value
1
Beginning Net
Market Value
8,370,404.10
430.00
0.00
0.00
0.00
$8,370,834.10
Ending Net
Market Value ... 1/1/13 to 1/31/13
Consolidated Summary
INVESTMENT ACCOUNT(S) YEAR-TO-DATE
Portfolio Activity
GHISLAINE MAXWELL
GHISLAINE MAXWELL
GHISLAINE MAXWELL - OAP IHD
GHISLAINE MAXWELL - TAP DYS
GHISLAINE MAXWELL - TAP ARFI
Total
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01565004.pdf
EFTA01565740Set 10
2013-05-01139p14,270w
GHISLAINE MAXWELL
EFTA01565740
EFTA01565741
For the Period 5/1/13 to 5/31/13
Account Summary
Account
Number
Investment Account(s)
GHISLAINE MAXWELL
GHISLAINE MAXWELL
GHISLAINE MAXWELL - OAP IHD
GHISLAINE MAXWELL - TAP DYS
GHISLAINE ... MAXWELL - TAP ARFI
i
Total Value
1
Beginning Net
Market Value
10,618,191.17
430.00
1,559,621.45
1,024,348.47
1,007,691.20
$14,210,282.29
Ending Net
Market ... 5/1/13 to 5/31/13
Consolidated Summary
INVESTMENT ACCOUNT(S) YEAR-TO-DATE
Portfolio Activity
GHISLAINE MAXWELL
GHISLAINE MAXWELL
GHISLAINE MAXWELL - OAP IHD
GHISLAINE MAXWELL - TAP DYS
GHISLAINE MAXWELL - TAP ARFI
Total
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01565740.pdf
EFTA00089465Set 9
2021-04-2720p3,589w
Court of Apprat5
for the *mufti Circuit
UNITED STATES OF AMERICA,
Appellee,
v.
GHISLAINE MAXWELL,
Appellant.
On Appeal from the United States District Court
for the Southern District ... York, 20-CR-330 (AJN)
Appellant Ghislaine Maxwell's Appendix to the
Renewed Motion for Pretrial Release
Leah S. Saffian David Oscar Markus
LAW OFFICES OF LEAH SAFFIAN *Counsel ... April 27, 2021
Doc. 282 Lower Court Order
May 14, 2021
Doc. 256 Ghislaine Maxwell letter regarding conditions at
Metropolitan Detention Center
April 29, 2021 .0
Doc. 270 Government
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089465.pdf
EFTA00157958Set 9
2020-07-179p3,089w
EPSTEIN's residence, drove her
there. and went into the residence after GBISLAINE MAXWELL
(MAXWELL) answered the door. described the door that she entered
being through the first driveway ... inugion orm.302 or (U) Interview of .0, 07/17/2020 .fts, 2 of 9
MAXWELL told to takc upstairs and show her what to do.
took up the stairs and through EPSTEIN ... house approximately a week later and was picked up from her house.
recalled MAXWELL introduce herself saying something like "My
name is MAXWELL...nice to meet you." told MAXWELL
https://www.justice.gov/epstein/files/DataSet%209/EFTA00157958.pdf
EFTA00158636Set 9
2019-08-276p1,992w
nature of the interview, provided the following
information:
friend introduced her to GHISLAINE MAXWELL.
visited MAXWELL at her place in . MAXWELL treated like
they were sisters, "like naughty schoolgirls". MAXWELL ... nice to
and seemed interested in her. MAXWELL talked about her boyfriend JEFFREY
EPSTEIN. MAXWELL told , "I know how much he's going to like you".
EPSTEIN visited and MAXWELL ... shirt talking on the
phone. When EPSTEIN got off the phone, MAXWELL gave EPSTEIN a "résumé" of
attributes, saying things like "she's so pretty and she's so
strong
https://www.justice.gov/epstein/files/DataSet%209/EFTA00158636.pdf
EFTA01246373Set 9
2021-02-094p1,093w
interview, provided the
following information:
and then moved onto Oxford University between
meets GHISLAINE MAXWELL at Oxford. worked as
met MAXWELL at Oxford. They were friends and part ... degrees. In
the mid to late 80's, started working in London. never dated
MAXWELL. She dated two of friends around that time.
In 1991, MAXWELL's father BOB MAXWELL ... circle prior to her moving to the United States.
never met JEFFREY EPSTEIN. MAXWELL's life had moved on after
New York, New York, United States (, Other (Video
Insmfigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01246373.pdf