Event Details

This document is page 46 of a court filing (Document 204) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text presents legal arguments refuting the defendant's claim that she has standing to enforce a Non-Prosecution Agreement (NPA) as a third-party beneficiary. It cites previous case law to argue that third-party standing principles from contract law do not necessarily apply to plea agreements.

This legal document, filed on April 16, 2021, is a government response in a criminal case. The prosecution argues that evidence concerning 'Minor Victim-3' is admissible to prove a conspiracy, even though a direct charge based on her testimony is time-barred because she turned 25 before 2003. The government asserts that the charges remain timely due to the involvement of 'Minor Victim-1' and 'Minor Victim-2' and distinguishes the current case from a cited precedent (*Hsia*) by stating the alleged conduct, grooming a minor for Jeffrey Epstein, is central to the conspiracy.

A page from a court filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text argues against Maxwell's motion claiming prejudice due to pre-indictment delay, specifically rejecting her assertion that the deaths of potential witnesses (Jeffrey Epstein, his mother, Michael Casey, and Detective Recarey) harmed her defense. The court/prosecution argues it is highly speculative to assume Epstein would have waived his Fifth Amendment rights to testify in Maxwell's favor and be found credible by a jury.

This document is page 19 of 239 from Document 204 filed on April 16, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It is a Table of Authorities page (numbered xviii) listing legal precedents cited in the filing, specifically cases beginning with 'United States v.' followed by names starting with M through N. It contains standard legal citations and page references for the brief.

This document is page 165 of a legal filing (Document 204) from April 2021 in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The prosecution argues against the defendant's motion to sever Counts Five and Six, stating that the perjury charges and sex abuse charges are logically connected by a common scheme. The text cites Federal Rule of Criminal Procedure 8(a) and various case precedents to support the joinder of offenses.

This document is a page from a Government legal filing in the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), arguing that certain evidence (depositions from April and July 2016) would have been 'inevitably discovered' regardless of protective order modifications. A significant footnote details Judge Preska's refusal in the related civil case to keep Maxwell's testimony sealed, specifically highlighting testimony where Maxwell denied giving massages to Jeffrey Epstein or 'Minor Victim-2,' which forms the basis of perjury charges (Count Six).

This document is page 196 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues for the admissibility of evidence regarding 'Minor Victim-3' to demonstrate the defendant's intent and modus operandi, citing legal precedents (McDarrah, Brand). It also argues that the defendant's motion to dismiss Counts One or Three based on multiplicity is premature under Second Circuit precedent.

This page is from a legal filing (Document 204) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues that the Defendant failed to prove the Indictment was delayed for an improper purpose. The text discusses the legal standards for pre-indictment delay, citing Supreme Court and Circuit precedents, and rejects the Defendant's request for a 'balancing test' regarding prejudice.

This page from a 2021 court filing (Case 1:20-cr-00330-PAE) presents arguments regarding the defendant's (Ghislaine Maxwell) perjury or false statements. It quotes a deposition where the defendant unequivocally denies ever giving anyone a massage, specifically denying giving massages to Mr. Epstein or '[Minor Victim-2].' The government argues that these answers were not ambiguous and that a jury could conclude the defendant lied.

This document is page 35 (pacer page 62) of a legal filing in the case United States v. Ghislaine Maxwell. The text is a legal analysis rejecting Maxwell's arguments to dismiss the indictment based on the statute of limitations. The court distinguishes the precedents cited by Maxwell (specifically Thom v. Ashcroft and Toussie v. United States), arguing that they do not prevent the retroactive application of the relevant statute of limitations.

This document is page 170 of a legal filing (Document 204) in the case USA v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The text presents a legal argument supporting the joinder of perjury charges with substantive offenses, citing the precedent of *United States v. Ruiz* regarding a NY State Senator who lied to conceal a financial scheme. The prosecution argues that, like in *Ruiz*, the current defendant's perjury was part of a common scheme to conceal her role in the charged sexual offenses.

This document is page 34 of a legal filing (Document 204) from the Ghislaine Maxwell case (1:20-cr-00330), filed on April 16, 2021. It discusses the legal interpretation of Jeffrey Epstein's Non-Prosecution Agreement (NPA), specifically rejecting the defendant's argument that the NPA binds the entire federal government rather than just the Southern District of Florida. The text quotes the specific NPA section granting immunity to potential co-conspirators, explicitly naming Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova.

This document is a page from a Government filing in the Ghislaine Maxwell case (1:20-cr-00330) arguing that the Southern District of New York (USAO-SDNY) was not involved in Jeffrey Epstein's Non-Prosecution Agreement (NPA). The Government asserts that communications between the Southern District of Florida (USAO-SDFL) and SDNY were solely regarding an old civil lawsuit from the 1990s, not plea negotiations. The text refutes defense claims involving 'Main Justice' and provides context on an AUSA who left the SDNY in April 2007.

This document is a legal filing from April 16, 2021, arguing that an indictment against a defendant is legally sufficient. It cites several legal precedents, including Russell v. United States and United States v. Pirro, to establish the standards for specificity in indictments. The author contends that the indictment in question meets these standards by laying out all essential elements of the crimes charged and that the defendant has provided no legal authority to suggest otherwise.

This legal document, a page from a court filing, presents an argument against a defendant's motion. The author contends that Section 3283, concerning sexual abuse offenses, should be interpreted broadly, citing precedents like 'Vickers' and 'Schneider'. The document argues that the defendant's reliance on the 'essential ingredients' test from 'Bridges v. United States' is misplaced because that case dealt with a different, more narrowly drafted statute (the Wartime Suspension of Limitations Act) and is therefore inapplicable.

This document is a page from a government legal filing (Document 204) in the case against Ghislaine Maxwell. It includes excerpts from Maxwell's deposition where she denies interacting with anyone under 18 at Epstein's properties, other than Virginia [Giuffre]. The filing argues against the defense's motion to dismiss perjury charges based on ambiguity, asserting that terms like 'Jeffrey,' 'properties,' and 'interact' were clear in context.

This document is page xiii from a legal filing, specifically a Table of Authorities from Document 204 in case 1:20-cr-00330-PAE, filed on April 16, 2021. It lists numerous U.S. federal court cases cited within the larger document, providing the case name, legal citation, and the page numbers where each case is referenced. The cases listed involve the United States as the plaintiff against various individual defendants.

This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents the government's argument against defendant Maxwell's motion to dismiss an indictment. The government contends that a Non-Prosecution Agreement (NPA) does not cover the specific crimes Maxwell is charged with under the Mann Act, as the statutes listed in the NPA differ from those in the indictment. Furthermore, the document argues that the NPA does not confer enforceable rights upon Maxwell to preclude the current prosecution, even under contract law principles.

This is a page from a Government legal filing (Case 1:20-cr-00330-PAE) responding to defense motions regarding discovery. The Government argues that witness statements (Jencks Act material) need not be disclosed immediately, and that a request for an unredacted FBI report is moot because it was already provided in November 2020. A key revelation in the footnotes is that a redacted version of an FBI report submitted by the defense was actually recovered directly from one of Jeffrey Epstein's personal devices during a search warrant execution.

This document is page 10 (labeled 'ix') of a Table of Authorities from a legal filing dated April 16, 2021, in the case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It lists legal precedents beginning with 'S' through 'U', including citations for *United States v. Nader* (marked 'passim', meaning cited frequently) and various Second Circuit decisions. The footer indicates this document was processed by the DOJ Office of Government Relations.

This page is from a legal filing (Document 204) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against the defendant's claims that the indictment is vague or that 'grooming' is not illegal behavior, citing Second Circuit precedents that define grooming as a form of enticement or inducement of minors for illegal sexual activity. The document asserts that the indictment adequately informs the defendant of the charges under 18 U.S.C § 371, § 2422, and § 2243.

This document is page 152 of a legal filing (Document 204) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against dismissing a perjury count, stating that the defendant's denial of knowledge regarding Epstein's scheme to recruit underage girls for sexual massages was not due to fundamental ambiguity in the questioning. It includes a transcript excerpt from a deposition where Giuffre's counsel asks the defendant to list girls under 18 she brought to Epstein's house, to which Mr. Pagliuca objects.

This is page 200 of a legal filing (Document 204) in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text outlines the Government's argument that separate counts for 'conspiracy to transport' and 'conspiracy to entice' minors are not multiplicitous because a jury could theoretically convict on one while acquitting on the other. The Government asserts it intends to prove the defendant did both.

This page from a court filing (Case 1:20-cr-00330-PAE) outlines the Government's argument that the defendant has failed to prove prejudice regarding the unavailability of Detective Recarey and various unnamed 'Epstein employees.' The text argues that fading memories and lost witnesses do not automatically justify dismissing the indictment. A footnote clarifies that Minor Victim-2 was interviewed by the FBI, but not by Detective Recarey.

This document is page 35 of a court filing (Document 204) in the case against Ghislaine Maxwell (Case 1:20-cr-00330), filed on April 16, 2021. The text argues that Jeffrey Epstein's Non-Prosecution Agreement (NPA) was strictly limited to the Southern District of Florida (USAO-SDFL) and did not provide national immunity for co-conspirators. It contends that the defendant's interpretation—that Epstein secured broader immunity for co-conspirators than himself—is counterintuitive and unsupported by the text.