This document contains a chain of emails between Ghislaine Maxwell's defense team (Haddon, Morgan & Foreman; Cohen & Gresser) and the US Attorney's Office regarding the logistics of reviewing evidence for the case US v. Maxwell. The correspondence details disputes and arrangements for reviewing 'highly confidential' materials, including over 2,100 nude/partially nude images seized from Jeffrey Epstein's devices, as well as physical evidence stored at an FBI warehouse in the Bronx. Specific items discussed include massage tables, plaster busts of female torsos, a stuffed dog, cash held at Federal Plaza, and various electronic recording media.
This document is a highly sensitive internal email chain and status update from the US Attorney's Office (SDNY) dated September 3, 2019. It details the progress of the investigation into Epstein's co-conspirators following his death, listing specific interviews conducted with victims (including Victim-2 and Victim-3) and scheduling plans for upcoming interviews with former staff, including a 'house man' and assistants. The memo discusses evidence against Ghislaine Maxwell regarding recruitment and details the involvement of a specific scheduler who denied knowing the victims' ages.
This document is an email dated July 5, 2019, from an Assistant United States Attorney in the Southern District of New York to Judge Moses. The email submits a search warrant application for a 'New York Residence' (indicated by the attachment filename), coinciding with the investigation leading to Jeffrey Epstein's arrest. The sender apologizes for the submission during a court holiday (Independence Day weekend).
This document is an email sent on July 5, 2019, by an Assistant United States Attorney from the Southern District of New York. The subject is 'SW' (likely Search Warrant), and it attaches a file titled '2019.07.05_New_York_Residence_SW.pdf', indicating a search warrant for Jeffrey Epstein's New York property was being transmitted the day before his arrest.
This document is an email chain from July 5, 2019, the day before Jeffrey Epstein's arrest. An Assistant United States Attorney (AUSA) from the Southern District of New York forwards an email they sent to Judge Moses containing a search warrant application for a 'New York Residence' (presumably Epstein's Manhattan mansion). The email notes the submission is happening during a court holiday (Independence Day weekend).
An email from an Assistant U.S. Attorney (SDNY) to Marc Weinstein and Andrew Tomback regarding the investigation into the Epstein estate. The email outlines protocols for producing evidence found at the New York residence, specifically photographs and discs, and raises the issue of whether the estate will waive attorney-client privilege for the purpose of the United States v. Maxwell case.
This document is an email chain from November 12, 2019, between the FBI (NY field office) and the U.S. Attorney's Office (SDNY) regarding the processing of digital evidence seized from Jeffrey Epstein. The correspondence discusses the transfer of large amounts of data to the 'Relativity' platform, specifically mentioning '5-6 iMacs and 5 laptop computers' from the New York residence and a 'DVR system' from the Island. The Assistant U.S. Attorney explicitly asks if the Island materials are being checked for 'CP images' (Child Pornography).
This document is an email chain from November 12, 2019, between the FBI (NY office) and the US Attorney's Office (SDNY) regarding the processing of electronic evidence seized from Jeffrey Epstein. The discussion focuses on transferring processed emails to the USAO on a 1TB drive, the status of evidence from Epstein's NY residence (specifically 5-6 iMacs and 5 laptops), and the processing of a DVR system from 'the Island' (Little St. James) by FBI HQ. The USAO specifically inquires if the island materials are still being checked for 'CP images' (Child Pornography).
Email correspondence from November 12, 2019, between an Assistant U.S. Attorney (SDNY) and a Senior Forensic Examiner regarding the processing of electronic evidence seized from Jeffrey Epstein. The AUSA expresses concern that while the New York residence evidence (approx. 10-11 computers) was expected by late October, the 'island materials' (likely Little St. James) appear untouched by the FBI, which they describe as the 'tip of the iceberg.' The examiner responds that the process is complex but anticipates files will be ready by the following Thursday.
This document is a page from a legal filing (Case 1:20-cr-00330-PAE) detailing overt acts for Counts Three and Five of an indictment against Ghislaine Maxwell. It lists specific allegations of sexual abuse and recruitment involving minors named Jane and Carolyn between 1994 and 2004 in New York and Florida. The document is heavily edited with strike-throughs, notably removing allegations related to victims named Annie and Kate, and adjusting the age of victims from 17 to 18.
This document is a page from jury instructions (Instruction No. 36) in a federal criminal case, filed on December 18, 2021. It details the 'overt act' element required to prove a conspiracy charge, listing specific allegations from the indictment against conspirators Maxwell and Epstein. The alleged overt acts, occurring between 1994 and 2002, involve the sexual abuse and exploitation of underage victims identified as Jane, Annie, Kate, and Carolyn across multiple locations including New York, Florida, New Mexico, and London.
This legal document, part of an indictment, details overt acts related to a criminal case against Epstein and Maxwell. It outlines specific instances between 1994 and 2004 where they allegedly conspired to recruit and sexually abuse several minors, identified as Jane, Annie, Kate, and Carolyn, in various locations including New York, Florida, New Mexico, and London. The document describes methods of enticement, such as arranging travel and providing cash payments, and alleges that one victim, Carolyn, was also encouraged to recruit other girls.
This document outlines Jury Instruction No. 36 regarding the 'Third Element' of a conspiracy charge, specifically requiring proof of an 'overt act.' It details specific allegations from the indictment against Maxwell involving Epstein and victims identified as Jane, Annie, Kate, and Carolyn across various years and locations.
This document is a page from a legal indictment detailing allegations against Maxwell involving the abuse of three minor victims between 1994 and 1997 in locations including New York, Florida, New Mexico, and London. It lists specific acts such as group sexual encounters and unsolicited massages, and introduces 'Count Two' regarding the enticement of a minor to travel for illegal sex acts.
This is a page from a legal document filed on July 6, 2020, detailing allegations against Ghislaine Maxwell. It states that between approximately 1994 and 1997, Maxwell, the defendant, facilitated Jeffrey Epstein's access to minor victims for the purpose of abuse. The document identifies a multi-story private residence on the Upper East Side of Manhattan, owned by Epstein, as one of the locations where victims were groomed and abused.
This page of a legal indictment details specific allegations against Ghislaine Maxwell. It accuses her of facilitating the sexual abuse of two minors in the mid-1990s: providing an unsolicited massage to 'Minor Victim-2' in New Mexico and encouraging 'Minor Victim-3' to massage Jeffrey Epstein in London. The document also outlines Count Four, charging Maxwell with the transportation of a minor between 1994 and 1997 for the purpose of criminal sexual activity.
This legal document, part of a court filing, argues for the pretrial detention of Mr. Epstein. The prosecution contends that a July 2019 search of his New York City mansion uncovered a 'vast trove' of sexually suggestive photographs of young women and girls, which they describe as 'photographic trophies.' This evidence, combined with his 2008 Florida sex crime convictions, is presented to demonstrate that he poses an 'ongoing and forward-looking danger' to the community and should not be released pending trial.
This document is a legal memorandum filed by the government arguing that Jeffrey Epstein poses a danger to the community and has a history of obstruction. It details a July 2019 search of his Manhattan mansion which uncovered thousands of lewd photos and CDs labeled with references to young girls and nudes. The document also highlights a past incident where Epstein's private investigators forced a witness's father off the road.
This document is Page 6 of a legal filing (likely a bail/detention memorandum) submitted to Magistrate Judge Henry Pitman on July 8, 2019, in the case against Jeffrey Epstein. The prosecution argues for detention based on overwhelming evidence, including an 'extraordinary volume' of nude photographs of minors found at Epstein's New York residence and call records linking him and his agents to victims. The document also argues that the previous Non-Prosecution Agreement (NPA) with the Southern District of Florida does not prevent the Southern District of New York from prosecuting this case.
This document, a page from a legal filing dated July 2, 2019, details "Overt Acts" committed in furtherance of a conspiracy involving commercial sex acts. It describes how JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims (Minor Victim-1, Minor Victim-2, Minor Victim-3) for sex acts at his residences in New York and Florida, paying them hundreds of dollars. The document also notes that EPSTEIN encouraged Minor Victim-1 to recruit other girls, and mentions an "Employee-1" acting on EPSTEIN's behalf.
This legal document, part of an indictment against Jeffrey Epstein, details his methods for sexually abusing minor girls in New York and Florida. It describes how he would recruit victims for "massages" which would become sexual, paying them hundreds of dollars per encounter. The document also outlines how Epstein incentivized victims to become recruiters themselves, paying them for each new girl they brought to him, thereby maintaining a steady supply of victims, specifically mentioning abuse at his New York Residence between 2002 and 2005.
This legal document, page 2 of a court filing dated July 2, 2019, outlines allegations against Jeffrey Epstein. It states that he created a network to sexually exploit underage victims, some as young as 14, in locations including New York and Palm Beach. The document further alleges that Epstein conspired with employees and associates who facilitated the abuse by contacting victims and scheduling encounters at his residences, with these activities beginning in at least 2002.
This legal document is a page from a court filing arguing against the defendant's (Maxwell's) appeal regarding jury instructions. The filing asserts that the trial court correctly rejected the defendant's proposed instruction because it was unresponsive, redundant, and legally inaccurate. The core issue revolves around whether sexual activity outside of New York could form the basis for a conviction, with the filing arguing that the existing jury charge sufficiently clarified that the violation had to be under New York Penal Law.
This legal document, part of a court filing, discusses limiting instructions given to a jury. The instructions clarified that the testimony of two witnesses, Kate and Annie, could not be the sole basis for conviction on certain counts because their experiences either involved someone not legally a victim under the specific charges (Kate) or occurred in a different jurisdiction (Annie in New Mexico). The court aimed to focus the jury's attention on the specific alleged crime: the transport of a minor, Jane, to New York for sexual activity illegal under New York law.
This document is page 13 of a legal indictment (Case 1:20-cr-00330-AJN) against Ghislaine Maxwell, filed on March 29, 2021. It details several allegations of Maxwell's involvement in the sexual abuse of minors, including arranging for victims to provide massages to Epstein and travel with him between 1994 and 2002. The page outlines specific incidents involving three unnamed minor victims in locations such as New Mexico, London, and Florida, and introduces COUNT TWO: "Enticement of a Minor to Travel to Engage in Illegal Sex Acts."
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