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CAROLYN
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This document is page 27 (marked xxvi) of a court filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains a 'Table of Authorities' listing legal statutes, rules (Federal Rules of Criminal Procedure and Evidence), and other academic or congressional authorities cited in the brief. The page includes a DOJ Bates stamp (DOJ-OGR-00002961).
This document contains four phone message slips addressed to 'J.E.' (Jeffrey Epstein). Two slips are dated May 9, 2005. Callers include Kaytana, Nadia (who left a 'Thank you' message), Les Wexner (returning a call), and one redacted individual. The document is marked as part of a Public Records Request from 2017.
This document contains a page from a spiral-bound message book with four phone messages directed to J.E. (Jeffrey Epstein) between January 16 and January 20, 2005. Notable callers include magician David Copperfield, who stated he had 'some info,' and retail billionaire Leslie Wexner, who called from Georgia and did not leave a number, implying a close relationship where the number was known. Other callers include Manuela and Maria, with phone numbers associated with New York (212) and Palm Beach (561) area codes respectively.
This document is a page from a spiral-bound message book containing four phone messages for 'J.E.' or 'JE' (Jeffrey Epstein). One message is dated November 21, 2004. Notable callers include magician David Copperfield, who left a message stating 'It's important' with a Las Vegas number, and hedge fund manager Glen Dubin. Other callers include Jannie Saunders and 'Darren' (possibly Darren Indyke). The document bears Department of Justice stamps indicating it was released via a public records request.
A page from a spiral-bound message pad containing three handwritten phone messages taken by a staff member named Michael on March 24th. One message is for 'GM' (Ghislaine Maxwell) from 'Mr. Pritzer' (phone 212-750-8101) stating he returned her call. Two messages are for 'JE' (Jeffrey Epstein): one from 'Alina' (phone 917-345-3107) asking to be called back, and one from Jeff Schantz asking to be called back. The document bears DOJ and public records request stamps.
This document contains a scanned page of four 'Important Message' slips, three of which are filled out. The slips record phone messages for 'Miss Roginc', 'Miss Epstein', and 'JE' (Jeffrey Epstein). Notable callers include Mary Sarkis (calling from a Palm Beach area code) and Dejana, both inquiring about scheduling times to 'come by' or have another female 'come by'.
This document contains four phone message slips for 'Jeffrey' and 'Mr. Epstein', who are likely the same person, Jeffrey Epstein. Two messages are dated April 24, 2004, from Mark Epstein and Mr. Ladenson, providing callback instructions. The other two undated messages are from a 'Tatum', who wrote 'has girl for tonight', and a 'Dr. Moushwits', who left a phone number.
This is an arrest report from the Palm Beach Police Department for Jeffrey E. Epstein. The report details two felony charges: four counts of 'Unlawful Sex Acts w/Minor' under statute 794.05(1) and one count of 'Lewd/Lascivious Molest' under statute 800.04(5). The document includes Epstein's personal information, multiple addresses in Florida and New York, and identifies Det. Joe Recarey as the arresting officer.
This document is page 54 of a legal filing (Exhibit 310-1) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on July 2, 2021. The text contains legal arguments citing precedents such as *Santobello v. New York* and *Commonwealth v. Zuber* regarding the binding nature of prosecutorial promises and plea agreements under due process principles. It serves as a supporting legal authority, likely arguing that the government must honor previous non-prosecution agreements.
This document appears to be a page from a court filing in the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE), but the text specifically details the 2005 investigation into Bill Cosby regarding Ms. Constand. It summarizes Prosecutor Bruce Castor's rationale for declining to prosecute Cosby at that time, citing insufficient evidence, credibility issues with the accuser, and the existence of phone records and wire interceptions. The document is likely included in the Maxwell docket as a legal exhibit or precedent regarding non-prosecution agreements.
This document is a Court Order filed on June 4, 2021, by Judge Alison J. Nathan in the case of USA v. Ghislaine Maxwell. The order denies Maxwell's request to subpoena Boies Schiller Flexner LLP for specific items, including a victim's teenage diary, a pair of boots allegedly gifted by Epstein and Maxwell, and original photographs. The judge notes that while the victim's diary describes visiting Epstein in New York, there is no indication Maxwell is mentioned in the journal.
This legal document, filed on May 25, 2021, details the discovery provided by the Government to the defense in a case involving Epstein and Minor Victim-4. The evidence includes seized message pads, phone records, Federal Express shipment records, and flight records related to Epstein, his employees, and Minor Victim-4, all pertaining to charges in Counts Five and Six. The document indicates that further details about abuse and interactions will come from witness testimony, focusing on approximate timeframes due to the events occurring over a decade ago.
This legal document, page 22 of a filing from May 25, 2021, outlines the prosecution's argument against a defendant's motion. It details allegations from the S2 Indictment, stating the defendant facilitated the sex trafficking of 'Minor Victim-4' to Epstein by scheduling appointments, making payments, and encouraging recruitment of others. The document argues these details are sufficient to deny the defendant's request for a bill of particulars, citing several legal precedents.
This document is a page from a confidential Grand Jury testimony transcript filed in Case 1:20-cr-00330-PAE (U.S. v. Ghislaine Maxwell). The witness testifies about a redacted individual whose primary role was scheduling massages for Mr. Epstein, sometimes from New York, and escorting the massage provider from the kitchen to the upstairs bedroom. The testimony explicitly describes a sexual encounter involving Mr. Epstein, a redacted individual, and an unidentified female introduced by Epstein.
This document is the conclusion section of an OPR report detailing an investigation into the USAO's handling of the Jeffrey Epstein case, specifically regarding the 2007 Non-Prosecution Agreement (NPA) authorized by R. Alexander Acosta. The report confirms that the government violated the Crime Victims' Rights Act (CVRA) by concealing the NPA from victims and sending misleading letters. It identifies five former USAO attorneys (Acosta, Sloman, Menchel, Lourie, and Villafaña) as subjects of the investigation due to their involvement in the NPA negotiations.
This document is a page from a DOJ OPR report detailing the final days of plea negotiations between the USAO and Jeffrey Epstein's legal team in August 2007. It includes a transcript of a letter signed by Matthew Menchel (on behalf of U.S. Attorney Acosta) setting a non-negotiable two-year incarceration term and an August 17 deadline. The narrative explains that the deadline was set to allow prosecutor Villafaña time to investigate Epstein's assistants and computers in New York if the deal was rejected, and notes that Menchel sent this letter on his final day at the USAO.
This document is a court transcript from August 10, 2022, capturing a legal argument between attorney Mr. Everdell and the presiding judge. Mr. Everdell argues that conduct and travel occurring solely in New Mexico cannot legally form the basis for a conviction of his client, Ms. Maxwell, under New York law, and he requests a supplemental jury instruction to this effect. The judge rejects the request, stating the proposed instruction is incorrect and that Mr. Everdell failed to seek to exclude the related testimony earlier.
This document is a page from a court transcript filed on August 10, 2022, detailing a legal argument about jury instructions. An attorney argues that the existing instructions are sufficient and that sending new, confusing ones would be a mistake. The judge ('THE COURT') then critiques the defense's newly proposed instruction, stating it addresses a count the jury didn't ask about and contains a legally incorrect paragraph concerning sexual activity involving a person named 'Jane' in states other than New York.
This document is a court transcript from August 10, 2022, detailing a discussion between a judge (THE COURT) and two lawyers (Ms. Moe and Mr. Everdell) about a jury's confusion. The jury appears to be mistaking New Mexico law for New York law regarding Count Four. Despite Mr. Everdell's concerns about ongoing confusion, the judge decides to simply refer the jury back to the original charge, which Ms. Moe argues clearly specifies a New York statute.
This document is a court transcript from case 1:20-cr-00330-PAE, filed on August 10, 2022. It captures a legal discussion between two attorneys, Ms. Moe and Ms. Sternheim, and the judge regarding jury confusion over 'Count Four'. The jury is questioning the relevance of flights to New Mexico for a charge that must be considered under New York law, and the counsel debate whether simply referring the jury to the existing instructions is sufficient to resolve the issue.
This document is a court transcript from August 10, 2022, capturing a legal discussion between a judge and Ms. Menninger. Ms. Menninger argues that for a conviction on a specific count, the jury does not need to find that a flight was specifically to New Mexico, as the indictment only requires that the flight's purpose was to engage in illegal sexual activity, regardless of the destination. The judge questions this position for clarity and ultimately agrees with her interpretation.
This legal document, filed on August 10, 2022, details overt acts from an indictment related to conspiracy charges. It alleges that between 1994 and 2002, Maxwell, along with co-conspirator Epstein, engaged in sexual abuse and trafficking of minors identified as Jane, Annie, and Carolyn. The alleged acts occurred in New York, Florida, and New Mexico.
This document is a page from a court transcript detailing jury instructions for 'Count Four' in the case against Ms. Maxwell (Case 1:20-cr-00330-PAE), filed on August 10, 2022. The instruction explains that the government must prove Ms. Maxwell knowingly transported a minor named 'Jane' across state lines with the intent for her to engage in illegal sexual activity violating New York Penal Law. The document clarifies that this illegal intent did not need to be Ms. Maxwell's sole purpose for the transportation.
This document is a page from a legal filing, specifically a jury instruction from a criminal case dated August 10, 2022. It outlines the legal elements the government must prove to find the defendant, Ms. Maxwell, guilty of Count Four: knowingly transporting a minor named Jane across state lines for illegal sexual activity, as defined by Title 18 of the United States Code and prosecutable under New York law.
This document is page 198 of a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It contains the Judge's charge to the jury regarding Ghislaine Maxwell, specifically defining legal concepts such as 'acting knowingly,' 'interstate commerce,' and 'intent' in the context of Count Two: Enticement to engage in illegal sexual activity. The text outlines the government's burden of proof regarding Maxwell's intent for individuals to engage in criminal sexual activity under New York law.
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