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Document 302 Filed 06/16/21 Page1of3
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
J
Case 1:20-cr-00330-PAE Document 301 Filed 06/15/21 Pagelof1
Uspc SDNY
DOCUMENT
UNITED STATES DISTRICT COURT ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK BO yt
DATE FILED: 6/16/21
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Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page5of32 1
L4TPDAYS
UNITED STATES
Case 1:20-cr-00330-PAE Document 300 _ Filed 06/15/21 Page 3 of 32
LAW OFFICES OF BOBBI C. STERNHEIA\
During a recent sentencing in which defense counsel described deplorable conditions at the
MCC, Ju
;ct-330(AJN)
M p N DATE™ File d506/07P2ige 1Raige 1 6
21-58-cr (L), 21-770-cr
United States v. Maxwell
USDC SDNY
: DOCUMENT
United States Court of Appeals | crectronICALLy FILED
FOR THE DOC #:
SECO
Case 1:20-cr-00330-PAE Document 297 Filed 06/02/21 Page1of2
Uspc SDNY
DOCUMENT |
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT Bee ik
SOUTHERN DISTRICT OF NEW YORK DATE FILED:_ 6/2/21
United St
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 26 of 26
prior statements of Minor Victim-4 in its possession, including the transcript of this civil deposition
and reports of more recent i
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 1 of 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
AR RE RR RRs Xx
UNITED STATES OF AMERICA
-V.- i S2 20 Cr. 330 (AJN)
GHISLAI
ee |
Case 1:20-cr-00330-PAE Document 293-4 Filed 05/25/21 Page4of5
Case 9:08-cv-80736-KAM Document14 Entered on FLSD Docket 07/15/2008 Page 3 of 21
— nl
federal aeuite on May 28, 2008. The FBI's Vic
ee
Case 1:20-cr-00330-PAE Document 293-4 Filed 05/25/21 Page2of5
Case 9:08-cv-80736-KAM Document14 Entered on FLSD Docket 07/15/2008 Page 1 of 21
a" —
UNITED STATES DISTRICT COURT
SOUTHERN DISTRIC
Case 1:16a8¢-212061ACNS 3 HBAMMerPacemenieaa-dn FERS OSGe245/1P20e® AbdGe 4 of 15
Terms of the Agreement:
L Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending ag
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 332 of 349
Terms of the Agreement:
1. Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 325 of 349
signature on this Agreement; and
IT APPEARING, after an investigation of the offenses and Epstein’s background, that
the interest
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 314 of 349
METHODOLOGY
A. Document Review
As referenced in the Executive Summary, OPR obtained and reviewed hundreds of
thousands of pages
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 310 of 349
CONCLUSION
In November 2018, the Miami Herald published an extensive investigative report about
state and federal criminal invest
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 218 of 349
Bill of Rights in the VRRA.7® Following multiple Senate Judiciary Committee subcommittee
hearings and various revisions of the pro
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 207 of 349
“T’m reconstructing memories of... 12 years ago. I can speculate that at some point, the matter
came up, and I or someone else sai
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 177 of 349
reconsider the provision. Acosta could certainly have modified or eliminated the provision entirely
if his motivation was to benef
and guaranteed sexual offender registration by Epstein . . . were
among the factors [that led to the NPA].7!°
go forward with a trial:
[W]hen we would meet with victims, we would ask them how they
w
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 158 of 349
4. FRPC 4-8.4 — Conduct Prejudicial to the Administration of Justice
FRPC 4-8.4(c) states that a lawyer shall not engage in condu
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 146 of 349
CHAPTER TWO
PART TWO: APPLICABLE STANDARDS
I. OPR’S ANALYTICAL FRAMEWORK
OPR finds professional misconduct when an attorney int
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 133 of 349
appeal an adverse determination by him within the DOJ. Ken [Starr]
and I appreciate that you understand this and have no objection
Why don’t we agree to mutual recission [sic] and indict him?
that read “This has to stop,” in which he stated:
Just read the letter.
1. We specifically refused to include the provision saying that
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 49 of 349
also informed Sloman and Lourie that the FBI was re-interviewing victims who had given taped
statements to the PBPD, to ensure thei
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 36 of 349
whose law firm website cites his “national reputation for the aggressive defense” of “high-profile
defendants in criminal matters.”
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 32 of 349
Kirkland & Ellis, which was representing Epstein, because Acosta had begun discussions with the
firm about possible employment.
Af
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 2 of 349
DEPARTMENT OF JUSTICE
OFFICE OF
PROFESSIONAL RESPONSIBILITY
REPORT
Investigation into the
U.S. Attorney’s Office for the Southern
Case 1:20-cr-00330-PAE Document 293 _ Filed 05/25/21 Page 30 of 32
VIII. Ms. Maxwell Incorporates All of the Arguments Raised in Her Initial Pretrial
Motions and Reasserts Them as to the 82 Indictmen
Case 1:20-cr-00330-PAE Document 293 _ Filed 05/25/21 Page 32 of 32
CERTIFICATE OF SERVICE
Thereby certify that on May 7, 2021, I served by email, pursuant Rule 2(B) of the Court’s
individual practic
Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 2 of 32
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT 0000....0..00cccccccccccescccsscceseceseeceeecssecsecesseecseecnseenseeeseeeseessseenseee
Case 1:20-cr-00330-PAE Document291 Filed 05/21/21 Page13o0f13
Page 13
three weeks after receipt of the witness statements. Ms. Maxwell requests the same deadline.
Defense Disclosures Pursuant to Rul
Case 1:20-cr-00330-PAE Document291 Filed 05/21/21 Page12o0f13
Page 12
documentary evidence) at the same time as it discloses /3500 material.
Defense Expert Disclosures
The government's proposal tha
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page9of13
Page 9
of the fact that some accusers have spoken publicly about this case. The government’s
principal justification for withholding thei
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page10of13
Page 10
(2 year conspiracy charged the following year); Jones (1 year conspiracy charged the same
year); Lebedev (2 year conspiracy char
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page8of13
Page 8
the identity of any unindicted co-conspirator.
e Oct. 11 (7 weeks before trial) — government discloses exhibit list.
¢ Oct. 18 (
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page6of13
Page 6
Government’s Proposed Exhibit List and Marked Exhibits
The Government is prepared to provide the defense with its proposed exhibi
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page5of13
Page 5
v. Cole, 19 Cr. 869 (ER), Dkt. No. 23 (S.D.N.Y. Feb. 18, 2020) (contemplating 3500 material four
weeks before trial in complex acc
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page3of13
Page 3
to Federal Rule of Evidence 404(b) by October 11, 2021, or 7 weeks in advance of trial. These
materials will include testifying wi
Case 1:20-cr-00330-PAE
pyle.
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Do
Case 1:20-cr-00330-PAE Document 290 _ Filed 05/21/21 Pagelof2
: on U.S. Department of Justice
United States Attorney :
Southern District of Nev\ USC SDNY
DOCUMENT
The Silvio J. Mollo Building ELECT
Case 1:20-cr-00330-PAE Document 290 Filed 05/21/21 Page2of2
Page 2
The Government has conferred with defense counsel in accordance with the Order. The
defense has indicated that it has no objection
__ Case 1:20-cr-00330-PAE
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Docume
Case 1:20-cr-00330-PAE Document 288 Filed 05/20/21 Page2of2
Page 2
The Government has conferred with defense counsel in accordance with the Order. The
defense has indicated that it has no objection
Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 16 of 16
CERTIFICATE OF SERVICE
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court’s individual pract
Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page4of16
Ghislaine Maxwell respectfully submits this Reply Memorandum in Support of her
Motion for a Bill of Particulars and Pretrial Disclosures (
Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page1of16
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
20 Cr. 330 (AJN)
V.
GHISLAINE MAXWELL,
Defendant.
Case 1:20-cr-00330-PAE Document 286 Filed 05/20/21 Page14o0f14
CERTIFICATE OF SERVICE
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court’s individual practic
Cagnde20-t5- 009M BARWDopsHanetBIa Filled OHGOes PHEIS 4? pf 12
occurred or that they occurred with the people she claims to have been involved. Rather, each
witness identified as being able to provi
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“circumstances.” See Complaint. Ms. Maxwell denied the allegations made stating they were
“untrue” and “obvious lies.” Plaintiff cl
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associated with attending any deposition occurring outside 100 miles of the Courthouse for the
Southern District of New York purs