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Case 1:20-cr-00330-PAE Document 212-2
GALMGIUC
UNITED) STATES DISTRICT’ COURT
SOUTHERN DISTRICT OF NEW YORK
Filed 04/16/21
App.-080
CasetQ025-ON S302 AR NVAD GSH RENEALLSD, FRAGA BGIS2 1p AcaceRS of 8
App.-0134
has attempted to join. Ms. Villafana’s response was that she was unaware of any such
investigation.
Plaintiff also seem
Casets2025-ON S302 AR NVAD GSH RENEALASD, PHUGCIUA/ BGIS2 | PAracERF of 8
App.-0133
INTRODUCTION
Ms. Maxwell, through counsel, requests, pursuant to Rules 37( a) and 26(c) of the
Federal Rules of Ci
CasetQ025-ONS3 OAR NAD GSH RENEALASD, FHAGCA/ BGIS2 |B agacERA of 8
App.-0132
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ee xX
Virginia L. Giuffre,
Plaintiff,
V.
Ghislaine Maxwell, 1
Case 1:20-cr-00330-PAE Document212 Filed 04/16/21 Page 18 of 20
government’s claim that its investigation of Maxwell did not start until 2018. But based on the
discovery provided to Maxwell in respon
Case 1:20-cr-00330-PAE Document 212 Filed 04/16/21 Page 8 of 20
First, the Court recognized that
[t]here is a world of difference between the limited types of personal information
addressed in Smit
Case 1:20-cr-00330-PAE Document 212 Filed 04/16/21 Page5of20
TABLE OF EXHIBITS
EXHIBIT A: Motion to Compel Plaintiff to Disclose Alleged “On-going Criminal Investigations
by Law Enforcement” or, In t
Case 1:20-cr-00330-PAE
Document 211 Filed 04/16/21 Page11of11
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
Case 1:20-cr-00330-PAE Document 211 Filed 04/16/21 Page2of11
TABLE OF CONTENTS
Page
I. The Relevant “Community” for Comparison Purposes Is the Manhattan Counties
or, in the Alternative, the Southern
Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 12 of 15
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14
new victims will simply join in a single summar
Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page15of15
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14
CERTIFICATE OF SERVICE
I certify that the foregoin
Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page5of15
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 4 of 14
business, personal, political, and financial gain, a
Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 2of15
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF F
CasGAss-4)2956500830-PAR umbocument 208:4 on FilethO4,264 b4/cPage Ht Of ade 3 of 10
on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the
amendment, [
CascGAS8-4:2950609890-PAR umbecument 2084 on FilethO4¥Le4b4/oPage 3 Of dde 2 of 10
On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this act
Case 1:20-cr-00330-PAE Document 208 Filed 04/16/21 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 208 Filed 04/16/21 Page 2 of16
TABLE OF CONTENTS
TABLE OF CONTENTS 1.00. ..cccccccccceccecceccsseeseneeeetaecacaecaeenecessseenasesesaecseeaecaeesecsasesenaseaesaeeee
Case 1:20-cr-00330-PAE Document 208 Filed 04/16/21 Page4of16
TABLE OF EXHIBITS
EXHIBIT L: Order Denying Motion to Join Under Rule 21 Doe v. United States, No. 08-80736-
Civ-Marra/Johnson (S.D. Fla.
Case 1:20-cr-00330-PAE Document207 Filed 04/16/21 Page 28 of 34
(PGG), 2014 WL 3057917, at *3 (S.D.N.Y. July 7, 2014) (collecting cases). The Court therefore
denies Maxwell’s motion to dismiss multip
Case 1:20-cr-00330-PAE Document207 Filed 04/16/21 Page 21 of 34
Moreover, the Government has agreed to disclose their names in advance of trial. There is thus
no unfairness here. See Stringer, 730 F.
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page5of34
its entirety, reads as follows: “the United States also agrees that it will not institute any criminal
charges against any potential co-co
Case 1:20-cr-00330-PAE Document 206 Filed 04/16/21 Page 22 of 22
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 206 Filed 04/16/21 Page 6 of 22
Ghislaine Maxwell respectfully submits this Reply Memorandum in Support of her
Motion to Dismiss Counts One Through Four of the Superse
Case 1:20-cr-00330-PAE Document 205 _ Filed 04/16/21 Page1of2
Uspc SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT DOC #:
SOUTHERN DISTRICT OF NEW YORK DATE FILED: 4/16/21
United St
Case 1:20-cr-00330-PAE Document 205 _ Filed 04/16/21 Page2of2
The Defendant is ORDERED to docket Reply Briefs 2, 4, 7, 8, 9, 11, and 12 on ECF
today, as she did not propose any redactions to these an
Case 1:20-cr-00330-PAE Document 204-12 Filed 04/16/21 Page 6 of 30
Plains community benchmark for African Americans increased from 1.25% to 3.69% and for
Hispanics increased from 1.15% to 3.64%.
11.
Case 1:25-cwO0a23G42AP Didouureantii2G4-16 FitddclOA/?67/01 Pagagk83Db145
Page 384
G Maxwell - Confidential
Jeffrey that was under the age of 18?
MR. PAGLIUCA: Objection to form
and foundation. Mi
Case 1:20-cr-00330-PAE Document 204-6 Filed 04/16/21 Page 2 of 2
Ce: "[email protected]" <[email protected]>, "[email protected]”
<[email protected]>
Subject: Virginia Guiffre
Ama
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 331 of 348
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 204-3 Filed 04/16/21 Page 324 of 348
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 204-3 Filed 04/16/21 Page 313 of 348
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 204-3 Filed 04/16/21 Page 309 of 348
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 204-3 Filed 04/16/21 Page 217 of 348
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 204-3 Filed 04/16/21 Page 206 of 348
“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 204-3 Filed 04/16/21 Page 176 of 348
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
wa
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 157 of 348
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 204-3 Filed 04/16/21 Page 145 of 348
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 204-3 Filed 04/16/21 Page 132 of 348
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 204-3 Filed 04/16/21 Page 48 of 348
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 204-3 Filed 04/16/21 Page 35 of 348
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 204-3 Filed 04/16/21 Page 31 of 348
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 204-3 Filed 04/16/21 Page 1 of 348
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 204 _ Filed 04/16/21 Page 234 of 239
how the particular Master Wheel is selected. It says nothing about the process by which a Master
Wheel is reduced to the subset of
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 217 of 239
the court and defense counsel that it recognizes and has complied with its disclosure obligations
under Brady,’ defendants’ reques
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 212 of 239
to review the statements of testifying witnesses. The Government remains open to engaging in
good faith discussions with the defen
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 200 of 239
with the intent that they engage in illegal sex acts. In other words, Count One requires proof of an
agreement to transport, while
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 188 of 239
C. Discussion
The defendant’s motion to strike should be denied—or at a minimum deferred until after
the conclusion of the Govern
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 184 of 239
against her. The Indictment also cites the relevant state criminal statute under which the defendant
is charged constituting “sexu