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Case 1:19-cr-00490-RMB Document 20
j782epsC kjc
Filed 07/16/19
Page 18 of 24 18
1 traditional issues that we look at, the issues involved, let's
2 start with that, we believe we hav xtremely powerf
Case 1:19-cr-00490-RMB Document19 Filed 07/16/19 Pageiof1
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
USA / Plaintiff(s)
19CR490
Case No.:
J
CasSecdesbe-cr-00490-RMB Document 18
Filed 07/16/1
9 Page 11 of 18 La
1 that.
2 THE COURT: Do you anticipate that there is going to
5 be any discussion here about the legality of the NPA?
4 MR.
Case 1:19-cr-00490-RMB Document17_ Filed 07/16/19 Pageiof1
Case 1:19-cr-00490-RMB Document 13-2 Filed 07/15/19 Page 1of1
| USDC SDNY
UNITED STATES DISTRICT COURT DOCUMENT
SOUTHERN DISTRICT OF NEW YO
Case 1:19-cr-00490-RMB Document16- Filed 07/16/19 Pageiof1
Case 1:19-cr-00490-RMB Document 15 Filed 07/15/19 Page 1 of 1
7 U.S. Department of Justice
United States Attorney
Southern District of New
Case 1:19-cr-00490-RMB Document15- Filed 07/15/19 Pageiofi
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New Y
Case 1:19-cr-00490-RMB Document13-2 Filed 07/15/19 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
)
|
Vv. ) Criminal No. 19 Cr 490 (RMB)
)
)
JEFFREY
Case 1:19-cr-00490-RMB Document14 _ Filed 07/15/
USDC SDNY
| DOCUMENT
UNITED STATES DISTRICT COURT - SLECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK f LOC #:
----------------~-++-----------------
Case 1:19-cr-00490-RMB Document13-3 Filed 07/15/19 Pagelof1
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Vv.
CRIMINAL NO, 19-CR-490
JEFFREY EPSTEIN,
Case 1:19-cr-00490-RMB Document13 _ Filed 07/15/19 Page1of2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
)
|
Vv. ) Criminal No. 19 Cr 490 (RMB)
)
)
JEFFREY
Case 1:19-cr-00490-RMB Documenti2-2 Filed 07/15/19 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
)
|
Vv. ) Criminal No. 19 Cr 490 (RMB)
)
)
JEFFREY
Case 1:19-cr-00490-RMB Document12_ Filed 07/15/19 Page1of2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
)
|
Vv. ) Criminal No. 19 Cr 490 (RMB)
)
)
JEFFREY E
Case 1:19-cr-00490-RMB Document11-1 Filed 07/12/19 Page 10 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 10
CONCLUSION
As set forth above, in this case, the risk of
Case 1:19-cr-00490-RMB Documentii-1 Filed 07/12/19 Page1of10
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New
Case 1:19-cr-00490-RMB Document11_ Filed 07/12/19 Page 14 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 14
Second, he is also wrong on the law. Courts have found
Case 1:19-cr-00490-RMB Document10- Filed 07/12/19 Page1of2
Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New Yor
Case 1:19-cr-00490-RMB Document10_ Filed 07/12/19 Page 2of2
Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 2 of 2
Honorable Richard M. Berman
United States District Judge
July 11, 2019
Page 2
Case 1:19-cr-00490-RMB Document9 Filed 07/11/19 Pagei1of2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: _
ae
ITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
)
)
UNITED STATES
Case 1:19-cr-00490-RMB Document8 Filed 07/11/19 Pagei1of2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New Yo
Case 1:19-cr-00490-RMB Document8 Filed 07/11/19 Page 2of2
Honorable Richard M. Berman
United States District Judge
July 11, 2019
Page 2
that require adjourning the bail hearing, the Government resp
Case 1:19-cr-00490-RMB Document7 - Filed 07/11/19 Page1of3
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
)
)
UNITED STATES OF AMERICA )
)
Vv. )
) CRIMINAL NO. 19-CR-490
JEFFREY
Case 9:08 a6 b 236K ANH IB deiRentBegumephfered driled SH DééRet d7aas/adiel Ibage 14 of
20
Jurisdiction to hear the case.”)); Reahard v. Lee County, 30 F.3d 1412, 1415 (11th Cir. 1994)
(“The questio
Case 9:08-CAS® 22 KAIMO498cRMEnt 2deczmMeniched orFtesS DEE o7RAGeRL Sf Page 9 of 20
48 at 6 J 8; see also DE 99 at 3, and government attorneys have on multiple occasions offered to
confer with Petit
Case 9:08-CAS® 22 KAIMO498cRMEnt 2d9eczmMeniched orFtesO DEEG o7RAGeG Sf Page 3 of 20
Petitioners lack Article III standing and because the claims raised by Petitioners in these
proceedings are not c
Case 9:08-CAS® 22 KAIWO498cRMEnt 2deczmMeniched orFtesS DEE o7RAGeC Sf Page 2 of 20
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA/JOHNSON
JANE DOE #1 AND JAN
Case 1:19-cr-00490-RMB Document6-1 Filed 07/11/19 Page4of15
Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 4 of
15
i
Terms of the Agreement:
1.
Epstein shall plead g
Case 1:19-cr-00490-RMB Document6 - Filed 07/11/19 Page 8 of 16
The NPA required Mr. Epstein to plead guilty to a state felony charge (Fla. Stat.
§ 796.07), then pending in the State of Florida and to
Case 1:19-cr-00490-RMB Document6 Filed 07/11/19 Page 7 of 16
that was unsealed and became public in July 2013, specifically noted that “a number of districts
outside the Southern District of Florida
Case 1:19-cr-00490-RMB Document6 - Filed 07/11/19 Page 6 of 16
future danger when viewed in the context of the unparalleled global media attention the case has
gamered, including the creation of a we
Case 1:19-cr-00490-RMB Document6 - Filed 07/11/19 Page 1of16
Reid Weingarten
1114 Avenue of the Americas Steptoe
New York, NY 10036
212 506 3900 main
212 506 3955 direct
www.steptoe.com
rweingarte
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page 10 of 14
a telephone call to Minor Victim-1 in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN «
d.
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page 9 of 14
commercial sex act, in violation of Title 18, United States
Code, Sections 1591l(a) and (b) (2).
Overt Acts
22. In furtherance of the co
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page 8 of 14
19. Moreover, as in New York, to ensure a steady
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
and enticed certain vict
8
throughout its brief. What a prosecutor should have
done is not relevant; whether or not the Southern
District of Florida should have prohibited the
Southern District of New York from prosecuting
G
7
It means recognizing that when the parties intended
to mean “only in the Southern District of Florida,”
they said so explicitly, and that their use of the
all-encompassing term “the United States”
3
The government seeks to minimize the split as of
“limited importance” because “the scope of a plea or
similar agreement is under the control of the parties
to the agreement.” Opp.14. This turns a b
12
(the USAO) and the corresponding geographic limita-
tions of that agreement, as reflected in its promises re-
garding the prosecution of Epstein himself.
Petitioner’s remaining arguments are like
7
The court of appeals observed that “[t]he only lan-
guage in the NPA that speaks to the agreement’s scope
is limiting language” referring specifically to the South-
ern District of Florida. Pet. Ap
97a
minimum-security Palm Beach County facility. A copy
of the NPA was filed under seal with the state court.
On July 7, 2008, a victim, identified as “Jane Doe,”
filed in federal court in the South
95a
charges against Epstein. She also provided a lengthy
memorandum summarizing the evidence she had
assembled in support of the charges and addressing
the legal issues related to the proposed charge
92a
APPENDIX E
UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
Docket No: 22-1426
At a stated term of the United States Court of Appeals
for the Second Circuit, held at the Thurgood Marshall
76a
IV. The perjury charges are legally tenable
The Court turns next to Maxwell’s motion to dismiss
the perjury counts stemming from her answers to
questions in a deposition in a civil case. She cont
39a
APPENDIX C
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Case Number: S2 20 CR 330 (AJN)
USM Number: 02879-509
UNITED STATES OF AMERICA
Vv.
GHISAINE MAXWELL
BOBBI C. STERNHEIM
De
28a
. The terms contained in paragraphs 1 and 2,
supra, do not foreclose Epstein and the State
Attorney’s Office from agreeing to recommend
any additional charge(s) or any additional
term(s) of proba
27a
Terms of the Agreement:
1.
3.
Epstein shall plead guilty (not nolo contendere)
to the Indictment as currently pending
against him in the 15th Judicial Circuit in and
for Palm Beach County (Cas
la
APPENDIX A
IN THE UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
AUGUST TERM 2023
No. 22-1426-cer
UNITED STATES OF AMERICA,
Appellee,
Vv.
GHISLAINE MAXWELL, also known as
Sealed Defenda
19
III. This case is an ideal vehicle for resolving the
split over this important and recurring
question.
This case is especially worthy of review because it
cleanly presents the issue at hand, whic
5
Maxwell’s motion was denied without a hearing.
Although the district court did not order discovery, it
did order the government to disclose to Maxwell
“any evidence supporting a defense under the N
V
TABLE OF CONTENTS—Continued
C. The available evidence suggests that
the NPA was meant to bind the
Southern District of New York ...........
III. This case is an ideal vehicle for resolving
the spl
App. No: 244709
In the
Supreme Court of the Gnited States
GHISLAINE MAXWELL,
Petitioner,
Vv.
UNITED STATES OF AMERICA,
Respondent.
PETITIONER’S AMENDED APPLICATION TO EXTEND TIME
TO FILE PETITION