EFTA00102999.txt

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

"AUDREY STRAUSS United States Attorney Southern District of New York"

"GHISLAINE MAXWELL, Defendant. S 1 20 Cr. 330 (AJN)"

"On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts."

"Count One of the Indictment charges the defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in illegal sex "

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

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

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

"Maxwell contends that Section 3283 should not be applied to conduct that predated its amendment in 2003... in the face of substantial contrary evidenc"

"the NPA barred the USAO-SDFL from prosecuting Epstein for the specific offenses enumerated in the NPA"

"the particular provisions charged in the Indictment against Maxwell, which alleges violations of §§ 2422(a) and 2423(a)"

"the USAO-SDFL interviewed Minor Victim-2"

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

"OPR interviewed Maria Villafatia"

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

"the prosecutor at the USAO-SDFL reached out to an Assistant U.S. Attorney at the USAO-SDNY to ask about a civil lawsuit relating to Epstein"

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

"Assistant Attorney General Fisher"

"USAO-SDFL supervisor Lourie"

"the USAO-SDFL's position was that the NPA did not bind other districts... obligated the government not to prosecute Epstein in the Southern District o"

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

"Palm Beach Police Department Detective Joseph Recarey"

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

"AUSA-1 met with a lawyer from Boies Schiller and two other attorneys about Epstein in February 2016"

"the Government issued a valid grand jury subpoena... and obtained materials from Boies Schiller"

"The USAO-SDNY opened its investigation into Epstein and his co-conspirators in late November 2018"

"Minor Victim-1 first agreed to be interviewed in September 2019"

"Minor Victim-3 first agreed to be interviewed in August 2019"

"the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the civil litigation"

"caused the Government to proceed via subpoena [to Boies Schiller]"

"Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016"

"the Government issued a valid grand jury subpoena for the materials... to Boies Schiller"

"Chief Judge McMahon found that Martindell applied and analyzed the Government's application"

"both Chief Judge McMahon and Judge Netburn found that Martindell applied"

"v. Maxwell, 15 Civ. 7433 (RWS)"

"Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN)"

"Jane Doe 43 v. Epstein, et al."

"the defendant asked Judge Preska to reconsider her order unsealing certain portions of her testimony... (See 15 Civ. 7433 (LAP))"

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

"Boies Schiller... deposed the defendant"

"the Government... charged the defendant with perjury based on the deposition transcript... basis of Count Five"

"the Government... charged the defendant with perjury based on the deposition transcript... basis of Count Six"

"the defendant denying that she has given a massage to anyone, including Epstein... (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1 at 113)"

"the defendant denying that she has given a massage to anyone, including Epstein or Minor Victim-2"

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

"the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019"

"At the April 2016 deposition, counsel asked the defendant"

"Trying the perjury counts with the Mann Act counts they concern makes eminent sense."

"the defendant argues that the trial on the perjury counts will require a 'full-blown re-litigation'"

"the Government is amenable to presenting that information through a stipulation"