EFTA00103758.txt

"Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell"

"Epstein paid $446,000 to the person we believe to be Accuser-4 and her attorneys"

"prosecuting Ms. Maxwell on Counts Five and Six would also violate her rights"

"the bargain struck in the NPA, which Epstein fully performed"

"the USAO-SDNY is trying to prosecute Ms. Maxwell in Counts Five and Six"

"Mr. Epstein provided [gifts] to [Accuser-4].... Epstein would provide her with lingerie"

"Sarah Kellen, who was Epstein's primary assistant during the 2001-2004 timeframe"

"on or about April 23th, 2004, Defendant Sarah Kellen placed a telephone call to a telephone used by [Accuser-4]"

"Kellen paid Accuser-4 $500 to take nude photographs of her at the Palm Beach residence at Epstein's request"

"Accuser-4—who alleges that Epstein sexually abused her from approximately 2001-2004"

"Ms. Maxwell conspired with Epstein and others to recruit 'a person'"

"massages took place in Epstein's Palm Beach residence"

"[Accuser-4] provided nude massages to Epstein at the Palm Beach Residence"

"FBI Special Agent Elizabeth Nesbitt Kuyrkendall"

"Counts One and Three of the S2 Indictment allege that Ms. Maxwell conspired"

"Christian R. Everdell... Attorneys for Ghislaine Maxwell"

"Jeffrey S. Pagliuca... Attorneys for Ghislaine Maxwell"

"Laura A. Menninger... Attorneys for Ghislaine Maxwell"

"Bobbi C. Stemheim... Attorneys for Ghislaine Maxwell"

"Christian R. Everdell COHEN & GRESSER LLP... Attorneys for Ghislaine Maxwell"

"Jeffrey S. Pagliuca HADDON, MORGAN & FOREMAN P.C.... Attorneys for Ghislaine Maxwell"

"Laura A. Menninger HADDON, MORGAN & FOREMAN P.C.... Attorneys for Ghislaine Maxwell"

"Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim... Attorneys for Ghislaine Maxwell"

"GHISLAINE MAXWELL, Defendant... RELATING TO THE S2 SUPERSEDING INDICTMENT"

"Epstein's primary assistant at the time, Sarah Kellen"

"The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 "

"Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim"

"Epstein negotiated immunity for Ms. Maxwell and any other 'potential co-conspirators' as part of the terms of the NPA"

"prosecuting Epstein for Counts Five and Six would violate the Double Jeopardy Clause"

"Counts Five and Six of the S2 Indictment are based on the same alleged conduct involving Accuser-4 from 2001-2004"

"declaration of AUSA A. Marie Villafaiia noting that Epstein 'sought a global resolution of the matter'"

"Epstein ... encouraged [Accuser-4] to recruit other young females to provide sexualized massages"

"Jeffrey Epstein and Sarah Kellen procured [Accuser-4] to engage in commercial sex acts knowing that she was under 18"

"Jeffrey Epstein and Sarah Kellen procured [Accuser-4] to engage in commercial sex acts knowing that she was under 18"

"Accuser-4—who alleges that Epstein sexually abused her from approximately 2001-2004 and that Ms. Maxwell allegedly facilitated that abuse."

"Count Six charges Ms. Maxwell with a substantive violation of § 1591(a), claiming she 'did recruit, entice, harbor, transport, provide, and obtain by "

"Accuser-4 allegedly provided 'nude massages' to Epstein, during which Epstein 'engaged in multiple sex acts' with Accuser-4"

"three-year investigation of Epstein's alleged sexual abuse... Accuser-4... reported that Epstein's primary assistant at the time, Sarah Kellen, facili"

"she reported that Epstein's primary assistant at the time, Sarah Kellen, facilitated her sexual abuse"

"Accuser-4 took full advantage of the NPA; she received both the benefit of experienced counsel and $446,000 to resolve her claims against Epstein"

"the co-conspirator provision of the NPA provides that if Epstein abides by the terms of the agreement, 'the United States' will not institute any crim"

"The document is on the letterhead of Law Offices of Bobbi C. Stemheim and signed by Christian R. Everdell."

"[Accuser-4] was paid between $200 and $400 for each massage"

"nude photographs of her at the Palm Beach residence at Epstein's request"

"Ms. Maxwell conspired with Epstein and others to recruit 'a person'"

"S2 Indictment does not specify when Ms. Maxwell 'interacted' with Accuser-4 or allegedly 'recruited' her 'to engage in sex acts with Epstein'"

"Ms. Maxwell allegedly paid Accuser-4 'hundreds of dollars in cash.'"

"Accuser-4 implicated Sarah Kellen, not Ms. Maxwell... named as a co-conspirator in the proposed 60-count indictment like Kellen"