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Case 1:20-cr-00330-PAE Document 298 _ Filed 06/04/21 Page5of6
timeframe, the Defendant may make an application to the Court to compel the Government to
adhere to its representation.
Request 11 seeks
Case 1:20-cr-00330-PAE Document 298 Filed 06/04/21 Page4of6
meritless. Lastly, Maxwell’s theory that a forensic analysis could reveal the date that the journal
was written and whether it had been alt
Case 1:20-cr-00330-PAE Document 298 _ Filed 06/04/21 Page2of6
Maxwell appears to proffer two theories of relevance as to the entire journal. While she
studiously avoids using the word, one such theor
Case 1:20-cr-00330-PAE Document 298 _ Filed 06/04/21 Page1of6
Uspc SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT OC ae
SOUTHERN DISTRICT OF NEW YORK DATE FILED: 6/4/21 |
United St
Case 1:20-cr-00330-PAE Document 296 Filed 05/28/21 Pagelof1
800 Third Avenue
New York, NY 10022
COHEN & GRESSER LLP +1 212.957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-760
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 24 of 26
Given the information the defendant already has from the Indictment and discovery, any additional
detail would essentially serve as
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 22 of 26
The S2 Indictment identifies Minor Victim-4 as a victim of the conspiracy charged in
Count Five and the trafficking offense contained
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 21 of 26
VI. A Bill of Particulars Is Not Warranted
The defendant again seeks a bill of particulars, this time related to Counts Five and Si
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 19 of 26
time the defendant was indicted in July 2020 or at the time Jeffrey Epstein was indicted in 2019.
Specifically, although Minor Victi
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 20 of 26
practice.”); United States v. Drago, No. 18 Cr. 0394 (SJF) (AYS), 2019 WL 3072288, at *2
(E.D.N.Y. July 15, 2019) (denying motion to
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 18 of 26
her interests or would have made a “substantial difference” in her case. (/d. at 17). In her current
motion, the defendant offers no
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page17 of 26
Accordingly, for the reasons set forth in the Government’s previous briefing (Dkt. No. 204
at 23-36), and for the reasons set forth i
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 15 of 26
failure to honor a plea agreement.” United States v. Losada, 674 F.2d 167, 169 (2d Cir. 1982).4
There, as here, any barrier to prosecu
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 14 of 26
defendant under the Double Jeopardy Clause. Whatever Epstein’s rights and obligations were
under the NPA, including his obligation t
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 13 of 26
Michigan, 568 U.S. 313, 319 (2013) (distinguishing between a “merits-related ruling” during trial
that “concludes proceedings absolu
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 12 of 26
Circuit has explained, the “key issue” for jeopardy attachment is “whether the disposition of an
individual’s indictment entailed find
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page11 of 26
crimes listed in the NPA overlap with some (but not all)? of the offenses in the S2 Indictment. But
at this stage of the litigation,
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 10 of 26
that Gonzalez could not have reasonably understood the plea agreement to restrict the Western
District of New York.”); United States v
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 9 of 26
Indictment before determining whether the plain-statement rule of Annabi applies. Annabi, the
defendant suggests, creates a three-part
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 8 of 26
this phrase is entirely misplaced. That phrase appears in a specific portion of the Second Circuit’s
opinion, in which the panel reject
Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 7 of 26
district bringing the second prosecution charges offenses different from the offenses resolved by
the plea agreement in the first pro
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 6 of 26
as multiplicitous remains premature. Sixth, a bill of particulars is not warranted, especially when
both the speaking indictment and di
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page5 of 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
AR RE RR RRs Xx
UNITED STATES OF AMERICA
-V.- i S2 20 Cr. 330 (AJN)
GHISLAIN
Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 2 of 26
TABLE OF CONTENTS
PRELIMINARY STATEMENT 1.0... cscssssscccssscsccscscsccssscsccssssscscsesscssessssssesssecssesscsssesssesseseees 1
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Case 1:20-cr-00330-PAE Document 294 _ Filed 05/25/21 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
eee eee a ee 2 ee =e x
UNITED STATES OF AMERICA,
AFFIDAVIT OF CERTIFICATION
Case 1:20-cr-00330-PAE Document 293-4 Filed 05/25/21 Page5of5
Case 9:08-cv-80736-KAM Document14 Entered on FLSD Docket 07/15/2008 Page 4 of 21
—_ —_
had been tried federally and convicted of an enum
Case1:20-c¢r-00330-PAE. .-
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message pads recovered during the search warrant,
2 |recovered during the execution of the state search
3 |warrant that indicates the esntact here.
4 We have statements
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3 received by FedEx from Mr. Epstein. i
4 Bud the grand jury should know- that we
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many o
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Case1-20-6r-00330-PAE—Decument 293-3— Filed 05/254—..Page 15 of 34
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member of the grand jury has hefore them Aa copy af
a chart. Do you also have a copy cf this chart
entitled Revised Indictment Summary Ch
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A The items that aré reseived are in this
box for your review at a later time; but sta
1 (Witness onters the Grand Jury Koon. }
Zz THE FOREPERSON: You de solemniy swear |
3 that the testimony you give wiil be the
4 truth, the whole truth, and nothing but the
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The sworn testimany of SPECEAL AGENT
Federai Grand Jury, West Palm Beach Divisaon,
Federal Builting, U.S. Courthcuse, Palm Beach
|County, State of Florida,
Case 1:19a8e- 4120 61AGRS3HbAmMerPoacementaeae-dn FERRS OSGe/2d5/1 Page d.2 PAS 11 of 15
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
4
ADDENDUM TO THE NON-PROSECUTION AGREEMENT.
IT APPEARING that the
Case 1:16a8e-A12861ACNS 3 HBAMerPacemenie@a-dn FERS OSGe2d5/1P2a0ed Ade 6 of 15
sentenced not later than October 26, 2007. The United States has no
objection to Epstein self-reporting to begin servin
Case 1:16a8¢-A120661AGNS 3 HBAMerPacemenie@a-dn FERS OSGe245/1P20e8 Ab4Ge 7 of 15
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and i
Case 1:16a8e-A12861ACNS3HBAMerPacemenie@a-dn FERS O6Ge245/1P20e6 Ab4Ge 5 of 15
proposed agreements with the State Attommey’s Office prior to entering
into those agreements,
7. The United States shal
~ Case 1:16a8e- A128 61ACNS 3 HBAmerPacymente#@e-an FERS OSGKe2d5/1 Page GbaGe 2 of 15
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
if
NON-PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach P
Case 1:1Ga8¢-d12061AGRS3HbAmMerPacemenieaa-dn FERS DaGe2d5/1 Page? AbdGe 1 of 15
COMPOSITE EXHIBIT A
NON-PROSECUTION AGREEMENT AND
ADDENDUM
DOJ-OGR-00004648
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 342 of 349
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
ADDENDUM TO THE NON-PROSECUTION AGREEMENT
IT APPEARING that the parties seek to clarif
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 340 of 349
EXHIBIT 4
Addendum to the
Non-Prosecution Agreement
DOJ-OGR-00004637
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 334 of 349
sentenced not later than October 26, 2007. The United States has no
objection to Epstein self-reporting to begin serving his sente
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 335 of 349
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported b