20,638 results for "Epstein"
Page 768 of 826
DOJ-OGR-00001124.jpg
...Maxwell, through her counsel, was also in regular contact with the government
from the moment of Epstein’s arrest up the time of her own arrest, as would be customary in
such situations. Defense counsel corresponded by email, spoke on the phone, or had in-
person meetings with government in...
DOJ-OGR-00003683.jpg
...The indictment charges that Epstein sexually abused each of the
alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for
that purpose. Instead, Maxwell contends that charged offenses do not qualify as offenses
involving the sexual abuse of minors because sexual abuse is not an...
DOJ-OGR-00010285.jpg
Case 1:20-cr-00330-PAE Document647 _ Filed 03/11/22 Page 19 of 24
that the core participants of the conspiracies—Epstein and Ms. Maxwell—were consistent
throughout and that Carolyn was a victim of the conspiracies charged in both Count Three and
Count Five. (/d.) The addition of...
DOJ-OGR-00010395.jpg
...But Jane testified about taking numerous flights both on Epstein’s private
plane and on commercial carriers. The note did not specify which of these many flights or other
testimony the jury was considering. The Court could not provide supplemental instruction based
on such a speculative foundation.
Second, the note...
DOJ-OGR-00012790.jpg
...and I
did Maxwell say about how
she said that he was going to love me and that
t it would be great
Epstein would
I was
She seemed
was excited, too.
CO
the attention that
liked to have attention.
Maxwell was
And I
1179
had not
foun
da group...
DOJ-OGR-00016947.jpg
...of the
defens
k here and elsewhere,
correct me, but an issue in the parties'
things like the name
ew York, the name Jeffrey Epstein should all
e recitation of the elements. I think the
t's in the "to wit" clause of
nd the law is quite clear -- and...
DOJ-OGR-00020072.jpg
...testimony of three different victims, who
will each independently describe how the defendant groomed and enticed them to engage in sexual
activity with Jeffrey Epstein. (Tr. 82). The Indictment itself contains a description of the accounts
these victims have provided law enforcement, which corroborate each other in meaningful part.
DOJ...
DocumentCloud_Epstein_Docs_p00073.png
Case 18-2868, Document 276, 08/09/2019, 2628224, Page24 of 77
defamatory statement on a party who had no “actual . . . responsibility for the decision to
republish” the statement. Jd.
A public figure includes a person who “voluntarily injects himself or is drawn into a
particular public controversy and thereby...
DocumentCloud_Epstein_Docs_p00086.png
Case 18-2868, Document 276, 08/09/2019, 2628224, Page37 of 77
Steinhilber court held, “even apparent statements of fact may assume the character of statements
of opinion, and thus be privileged, when made in public debate, heated labor dispute, or other
circumstances in which an audience may anticipate the...
DocumentCloud_Epstein_Docs_p00789.png
Case 18-2868, Document 279, 08/09/2019, 2628231, Page7 of 37
ARGUMENT
I. Ms. Maxwell is not liable for republications of the January 2015 statement.
Under black letter New York law, liability for republication of an allegedly defamatory
statement “must be based on real authority to influence the final...
DocumentCloud_Epstein_Docs_p01092.png
Case 18-2868, Document 283, 08/09/2019, 2628241, Page125 of 883
ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 16
1 was called in to protect Ms. Maxwell's reputation, and 8:37:29
2 to set the record straight. That was -- and that work 8:37:33
3...
DocumentCloud_Epstein_Docs_p01875.png
Case 18-2868, Document 284, 08/09/2019, 2628244, Page24 of 38
of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff
for a job there. Jd. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1.
Ex.U...
Giuffre_Maxwell_Batch4_p00109.png
...While she now knows, based on this discovery, that she was not 15 years old, she now has
conclusive proof that she was an underage minor when Ghislaine Maxwell approached her,
recruited her, introduced her to Jeffrey Epstein, and sexually trafficked her as an underage minor.
While she now knows...
Giuffre_Maxwell_Batch6_p00196.png
...H
19 Epstein a massage? Q. That was a different --
20 A. Yes. A. Different one.
21 Q. And do you remember who any of the names Q. Okay. And the mosaic that you saw where
22 of any of those people were? you saw two girls involved in a...
DOJ-OGR-00001065.jpg
...s that refer to? It refers to on
the themes we have been talking about in our submission a
today your Honor. When Mr. Epstein was arrested, it had
kinds of effects on our client, one of which was that the
in question referenced in the government's submission dro...
DOJ-OGR-00001190.jpg
...But this is Ghislaine Maxwell, the apparent substitute
for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the
significant additional evidence proffered to the Court and further argues that a defendant cannot
be eligible for bail (apparently on any conditions), unless she can provide...
DOJ-OGR-00002000.jpg
...Maxwell, through her counsel, was also in regular contact with the government
from the moment of Epstein’s arrest up the time of her own arrest, as would be customary in
such situations. Defense counsel corresponded by email, spoke on the phone, or had in-
person meetings with government in...
DOJ-OGR-00005979.jpg
...Maxwell “groomed” anyone for her own benefit; instead, the
government contends that she “groomed” them for Epstein’s benefit. But as the government does
not dispute, there is nothing—not a journal article, and not a study, nothing—to validate
Rocchio’s opinions on grooming-by-proxy (even if she...
DocumentCloud_Epstein_Docs_p00606.png
Case 18-2868, Document 278; 08/09/2019, 2628230, Page473 of 648
®
ZacFigueroa, Anthony
Case # 02-12206CFA02
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
You will live and remain at liberty without violating any law. A
conviction in a court of law shall not be necessary in order for...
Giuffre_Maxwell_Batch4_p00431.png
...For example, Defendant should also be required to identify all financial transactions involving
(directly or indirectly) Jeffrey Epstein, the Clinton Foundation, Ellmax LLC, The TerraMar
Project, and any other person listed in the Rule 26 disclosures of either side in this case.
Transactions with potential witnesses in this case are...
Giuffre_Maxwell_Batch7_p00033.png
...Giuffre’s first Request sought “[a]ll documents relating to communications with
Jeffrey Epstein from 1999 — present.”
More important, however, it was this Court’s own Order that required Defendant to
search for, and produce from, all accounts from 1999 through the present. See Schultz Dec. at
Exhibit 1, August...
DOJ-OGR-00020415.jpg
...In June 2020, a grand jury returned a
six—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 indictment shortly thereafter, which
contained only small, ministerial corrections. The S1...
DOJ-OGR-00002355.jpg
...Using a time-
honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the
lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter,
hard-fought, and wide-ranging. It spanned more than a year and included large document
productions, many...
DOJ-OGR-00002591.jpg
...Here, the NPA unambiguously precludes prosecution of Epstein’s potential co-
conspirators, and the indictment in this case must be dismissed.
In support of its July 2020 motion for Ms. Maxwell’s detention, the government raised
three arguments why it contends the NPA does not bar Ms. Maxwell’s prosecution...
DOJ-OGR-00003005.jpg
...In
particular, she contends that, as a result of the passage of time, four witnesses have died, unnamed
Epstein employees have been “lost,” unspecified witnesses now have “failed or corrupted”
memories, and records have been lost or destroyed. She further contends that these collectively
demonstrate actual prejudice. (Def. Mot. 7...
Search Tips
- Use quotes for exact phrases:
"flight manifest" - Use OR for alternatives:
bank OR financial - Use wildcard for partial matches:
invest* - Exclude words:
document -redacted - Search names:
John Smith