EFTA00095067.txt

"GHISLAINE MAXWELL, Defendant. S 120 Cr. 330 (AJN)"

"AUDREY STRAUSS United States Attorney... Attorney for the United States of America"

"UNITED STATES OF AMERICA S 1 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant"

"the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida"

"Count One of the Indictment charges the defendant with conspiring with Jeffrey Epstein and others to entice minors"

"On July 2, 2020, the Federal Bureau of Investigation ("FBP") arrested the defendant"

"2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida"

"charging the defendant in six counts"

"the charges against Epstein if any, will be dismissed. NPA at 2."

"the particular provisions charged in the Indictment against Maxwell"

"the fact that the USAO-SDFL interviewed Victim-2"

"Maxwell argues that Section 3283 is inapplicable because the offenses charged in the Indictment do not "involv[e] the sexual or physical abuse .. . of"

"In consideration of Epstein's agreement to plead guilty... the United States also agrees that it will not institute any criminal charges"

"promising not to prosecute 'any potential co-conspirators of Epstein'"

"Epstein's counsel, Kenneth Starr, protesting about complying with certain parts of the NPA"

"Chief of the Department of Justice Child Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan"

"Villafafta sent the NPA and its addendum to Lourie and Oosterbaan"

"the USAO-SDFL's resolution of its 2006-2008 federal criminal investigation of Jeffrey Epstein"

"The Government obtained an indictment charging the defendant on June 29, 2020"

"Palm Beach Police Department Detective Joseph Recarey"

"unavailability of Jeffrey Epstein, Epstein's mother"

"the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997.""

"As to Epstein's mother, who died in April 2004"

"Palm Beach Police Department even began investigating Epstein in 2005"

"Epstein was charged by indictment on July 2, 2019"

"the Government sought [the Indictment] on June 29, 2020"

"The Giuffre v. Maxwell litigation was settled and complete well before the Government even opened its investigation... resolved in 2017"

"the USAO-SDNY opened an investigation first, on either November 30, 2018 or December 3, 2018... on Epstein"

"the Government issued a subpoena to Boies Schiller in connection with its investigation"

"Attorney Peter Skinner of Boies Schiller"

"on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger"

"on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger"

"on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger"

"AUSA-1, who was at that time the Human Trafficking and Project Safe Childhood Coordinator of the USAO-SDNY"

"The Government Did Not Violate Maxwell's Due Process Rights"

"the Government's investigation of Maxwell"

"AUSA-1 was not involved in that decision"

"AUSA-1 did meet with the three attorneys in February 2016"

"Giuffre v. Maxwell, No. 20-2413 (2d Cir.)"

"Giuffre v. Maxwell, No. 20-2413 (2d Cir.)"

"unsealed by Judge Preska in the underlying civil litigation"

"Boies Schiller... deposed the defendant"

"the defendant asked Judge Preska to reconsider her order... (See 15 Civ. 7433 (LAP)"

"Judge Preska 'decline[d] Ms. Maxwell's invitation to reconsider its order' ... (See 15 Civ. 7433 (LAP)"

"the Indictment charges the defendant with two counts of perjury"

"statements made during the April 2016 deposition"

"the defendant sat for a second deposition on July 22, 2016"

"a spokesman for the defendant, Ross Gow"

"Giuffre sued the defendant for defamation. (See 15 Civ. 7433 (LAP), Dkt. No. 1)"

"The perjury counts should be tried jointly with Counts One through Four... the offenses charged in Counts One through Four and those charged in Counts"