EFTA00091595Set 9
2021-04-2724p5,120w
Appellee,
AFFIRMATION IN OPPOSITION
TO DEFENDANT'S
RENEWED MOTION FOR
GHISLAINE MAXWELL, PRETRIAL RELEASE
Defendant-Appellant.
x
STATE OF NEW YORK
COUNTY OF NEW YORK : ss.:
SOUTHERN DISTRICT ... America in this matter. I submit this affirmation in
opposition to defendant-appellant Ghislaine Maxwell's renewed motion for pretrial
release following this Court's order, dated April ... which denied Maxwell's
prior motion for bail or temporary pretrial release and affirmed the District Court's
orders denying such relief.
EFTA00091595
PRELIMINARY STATEMENT
2. Indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091595.pdf
EFTA00085225Set 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/EFTA00085225.pdf
EFTA00676990Set 9
2015-09-2112p2,669w
United States District Court
Southern District of New York
Plaintiff, CASE NO:
v.
GHISLAINE MAXWELL,
Defendant.
COMPLAINT
Boles Schiller & Flexner LLP
575 Lexington Avenue
New York. NY 10022
EFTA00676990
Case ... Plaintiff, , formerly known as
In), for her Complaint against Defendant, GHISLAINE MAXWELL ("Maxwell"), avers
upon personal knowledge as to her own acts and status and otherwise upon information and
belief ... NATURE OF THE ACTION
1. This suit arises out of Defendant Maxwell's defamatory statements against
Plaintiff As described below, was a victim of sexual trafficking and abuse while
https://www.justice.gov/epstein/files/DataSet%209/EFTA00676990.pdf
EFTA00087230Set 9
2016-02-2921p6,032w
YORK DATE FILED: 6/25/2021
United States of America,
—v—
20-cr-330 (AJN)
Ghislaine Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
Maxwell moves to suppress evidence obtained through ... that follow, the Court
concludes that the evidence should not be suppressed and that Maxwell is not entitled to an
evidentiary hearing.
I. Background
In late 2015, sued Maxwell ... defamation. See v. Maxwell, No.
15-cv-7433 (S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying
about Maxwell and Jeffrey Epstein sexually abusing her. The law firm
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087230.pdf
EFTA01340354Set 10
2019-04-0998p22,511w
EXAMINATION BEFORE TRIAL of the Defendant,
116 EAST 65TH STREET, LLC, by GHISLAINE MAXWELL, in
the above-entitied action, held at the above time
and place, taken before a Notary ... INDEX NO. 159224/2016
NYSCEF DOC. NO. 113 RECEIXWITsCEF: 03/05/2020
April 9, 2019
GHISLAINE MAXWELL
2 GHISLAINE M A X W E L L, called as a
3 witness, having been ... FALLEK:
8 Q. Please state your name for the record.
9 A. Ghislaine Maxwell.
10 Q. Please state your address for the record.
11 A. 44 Kinnerton Street, London, England
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01340354.pdf
EFTA00094773Set 9
2020-07-2919p3,274w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094773.pdf
EFTA01626027Set 10
2020-07-0818p3,380w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01626027.pdf
EFTA00078311Set 9
2019-11-1219p5,107w
their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN, and
GHISLAINE MAXWELL,
Defendants.
COMPLAINT
BOIES $CHILLER FLEXNER LLP
1
EFTA00078311
Case ... capacities as the executors of
the Estate of Jeffrey Edward Epstein ("Epstein") and Ghislaine Maxwell ("Maxwell")
(collectively, "Defendants"), avers upon personal knowledge as to her own acts and status ... Plaintiff was 16, she was sexually trafficked by Defendants as part of Epstein and
Maxwell's organized ring of procuring young women and girls for sex.
3. Epstein's trafficking
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078311.pdf
EFTA01249021Set 9
2020-01-158p2,758w
EPSTEIN, described what she calls
the "training period". During this time, EPSTEIN and GHISLAINE MAXWELL
taught her sexual experiences. They would have conversations about what to
look for, including younger ... tattoos. EPSTEIN
would say the "girl from next door" and "younger the better".
MAXWELL and EPSTEIN would constantly remind her of what EPSTEIN liked.
would have a lot of conversations ... room and his feet would be in the middle.
recalled having a conversation with MAXWELL and
outside one day while smoking a cigarette. They were outside the "yellow
room
https://www.justice.gov/epstein/files/DataSet%209/EFTA01249021.pdf
EFTA00100925Set 9
2020-10-237p3,628w
Response to the Government's October 7, 2020 letter,
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Judge Nathan,
At the initial conference in this case, the Government ... promised Ms. Maxwell and the
Court that it would review and produce "prior investigative files from another investigation in
the Southern District of Florida," which it characterized as part ... core of the case" against
Ms. Maxwell,'- after a "careful and exhaustive and through review of all of the materials," with
the "bulk" of the discovery produced
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100925.pdf
EFTA00285909Set 9
2016-12-16336p96,026w
MARCH IS. 1849)
T he greatest theoretical physicist of the nineteenth century,
James Clerk Maxwell, whom Einstein would later compare to Newton for
his impact on physics, was coincidentally born ... year that Mi-
chael Faraday made his great experimental discovery of induction.
Like Newton, Maxwell also began his scientific career fascinated by
color and light. Newton had explored the spectrum ... visible colors into
which white light splits when traversing a prism, but Maxwell, while still a
student, investigated the reverse question: What is the minimal combina-
tion of primary colors
https://www.justice.gov/epstein/files/DataSet%209/EFTA00285909.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
EFTA00794556Set 9
2017-03-31159p41,795w
YORK
2 x
3
4 Plaintiff,
5 v. 15 Civ. 7433 (RWS)
6 GHISLAINE MAXWELL,
7 Defendant. Oral Argument
8
New York, N.Y.
9 March ... restricting your claim to
24 the truth and falsity of the statements about Maxwell?
25 MS. McCAWLEY: Yes, that is the case, your Honor. The
SOUTHERN DISTRICT REPORTERS ... EFTA00794557
3
H3V0GIU1
1 statements about Maxwell and her activities, without using any
2 description of what that is, but yes, as we've described in our
3 pleadings
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794556.pdf
EFTA00090290Set 9
2021-01-0811p2,396w
Central Authority of France
SUBJECT: Request for Assistance in the Prosecution of Ghislaine Maxwell
DATE: January 8, 2021
INTRODUCTION
The Central Authority of the United States requests the assistance ... authorities")
are prosecuting charges of violations of United States criminal law concerning Ghislaine
Maxwell and her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey
Epstein ... witness to certain events, conduct, or conversations relevant to its
prosecution of Maxwell and, in particular, that was sexually abused by Epstein
1
EFTA00090290
in New York after meeting Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090290.pdf
EFTA00263734Set 9
2014-12-3014p6,279w
Ghislaine 9714".eatctavr-YPin.§TJ9s1)
she
several -olheri, . Perversion of Justice, The Miami
Maxwell for their own use and for use by Herald, November 29, 2018. --
Harvard.. Law
including ... Prince Andrea-1 misled
professor Alan Dershowitz-[
8][1421 also claimed that
Epstein, Maxwell ana Others had physically and sexually
may have been involved in a cover-up.P441 ... 5/19/22, 4:19 PM
4sey --re.ofFicKAN)c, oeGRA\--riocJ - M eXV• )
Ghislaine Maxwell - M awr*
sex trafficking conspiracy.[991
Maxwell requested a rehearing in a federal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00263734.pdf
EFTA00065781Set 9
2020-08-1010p2,147w
Exhibit 0
EFTA00065781
GHISLAINE MAXWELL
FINANCIAL CONDITION REPORT: 2015 - 2020
INDEPENDENT REPORT & COMMENTARY
PREPARED BY MACALVINS LIMITED
CHARTERED ACCOUNTANTS
FOR
COHEN & GRESSER LLP
Wage
EFTA00065782
GHISLAINE MAXWELL
FINANCIAL CONDITION REPORT ... August 2020, we have prepared a summary
of the financial condition of Ghislaine Maxwell based on the following information
(i) Copies of her US tax returns filed in the years ... Documentation provided by Ghislaine Maxwell's office and her spouse
including bank statements and financial correspondence relating to bank
accounts, pension fund, and investments2
(iii) Documentation provided by the United
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065781.pdf
EFTA00237739Set 9
2016-02-018p1,699w
Chelsey lal; Ladd, Molly
Subject: RE: [2016/01/21 05:17 PM - Sent via LeapFILEI RE: MAXWELL: RE: Ms. Maxwell's accountants
Hi Jourdan,
I received the faxed document ... Waldron, Chelsey; Ladd, Molly;
Subject: RE: [2016/01/21 05:17 PM - Sent via LeapF1LE] RE: MAXWELL: RE: Ms. Maxwell's accountants
Good Morning Jourdan,
I hope you had a good weekend ... Waldron, Chelsey; Ladd, Molly
Subject: RE: [2016/01/21 05:17 PM - Sent via LeapF1LE] RE: MAXWELL: RE: Ms. Maxwell's accountants
Thank you! We've received the form from Alan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00237739.pdf