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Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 26 of 34
The balance of these considerations favors severance. “Motions to sever are committed
to the sound discretion of the trial judge.” Uni
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 20 of 34
to describe the window of when a violation occurred.” United States v. Kidd, 386 F. Supp. 3d
364, 369 (S.D.N.Y. 2019) (quoting United
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 19 of 34
II. The indictment describes the charged offenses with specificity
Maxwell seeks to dismiss the Mann Act counts for lack of specifici
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 18 of 34
provides no indication of what many of these potential witnesses might have testified to. The
testimony she suggests the detective mig
Case 1:20-cr-00330-PAE Document207 Filed 04/16/21 Page17 of 34
171 F.3d 748, 751 (2d Cir. 1999) (cleaned up) (quoting United States v. Marion, 404 U.S. 307,
322 (1971)). There is a strong presumption
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 9 of 34
I. The indictment is timely
A. The indictment complies with the statute of limitations
Federal law imposes a five-year limitations pe
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 8 of 34
C. Maxwell is not entitled to an evidentiary hearing
In the alternative to dismissing the indictment, Maxwell requests that the Court
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 7 of 34
Dkt. No. 142-1 at 2. The NPA makes clear that the covered charges are those relating to
and deriving from a specific investigation of c
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page4of34
A. The non-prosecution agreement does not bind the U.S. Attorney for the
Southern District of New York
United States Attorneys speak for
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 2 of 34
related to the newly added sex trafficking charges. For the reasons that follow, the Court denies
Maxwell’s motions to dismiss the S1 s
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page 3 of 34
I. Jeffrey Epstein’s non-prosecution agreement does not bar this prosecution
In September 2007, under investigation by both federal an
Case 1:20-cr-00330-PAE Document 207 Filed 04/16/21 Page1of34
Uspc SDNY
DOCUMENT
UNITED STATES DISTRICT COURT we
SOUTHERN DISTRICT OF NEW YORK putt peo ie
United States of America,
_y_
20-cr-330 (A
Case 1:20-cr-00330-PAE Document 206 Filed 04/16/21 Page1of22
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
20 Cr. 330 (AJN)
V.
GHISLAINE MAXWELL,
Defendant.
Case 1:20-cr-00330-PAE Document 204-12 Filed 04/16/21
APPENDIX B
SDNY_JA_ 000001 BronxCounty
SDNY _JA_000002 DutchessCounty
SDNY_JA_000749 ManhattanCounty
SDNY_JA_ 000750 OrangeCounty
SDNY _JA_ 000
Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page1 of 21
Confidential
‘D STATES DISTRICT COURT
PRN DISTRICT OF NEW YORK
Se Aa ae ase a PF
N . UFFRE,
Plaintiff,
Case No.:
-against- 15-cv-
Case 1:25-cwO023G42AP Didouureanti2G4-16 FitdddlOA/?67/01 Pagagk82Db145
G Maxwell -
Confidential
Q. Did you have an attorney to consult
with during the criminal investigation of
Jeffrey Epstein?
Case 1:20-cr-00330-PAE Document 204-9 _ Filed 04/16/21 Page6of6
Page 6
Chemical Bank, 154 F.R.D. at 94 (describing such materials a “technological trade secrets,
currently sensitive customer lists,
Case tabave02secehAtP Duamuneitleris iti Wiese Papye dictebl
JISTRICT COURT
CT OF NEW YORK
UFFRE
Plaintiff,
Case No.:
-against- 15—-ov—-0 743 3-BWS
SLAINE MAXWELL,
Defendants.
io te ON F
Videot
Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page5of6
Page 5
persons protected by a constitutional, common-law, or statutory privilege is particularly applicable
to grand jury proceedings.”)
Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page4of6
Page 4
uncontested subpoena for documents—precisely the scenario here—such relief would be
appropriate. Chemical Bank, 154 F.R.D. at 94.
Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page3of6
Page 3
Indeed, the Chemical Bank opinion specifically rejected judicial protection for the type of
information the Protective Order appe
Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page 2 of6
Page 2
Discussion
Where, as here, a grand jury subpoena has validly issued, and the recipient of the subpoena
is not contesting compl
_ Case 1:20-cr-00330-PAE Document 204-9 Filed 04/16/21 Page 1of6
vase U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's
Case 1:20-cr-00330-PAE Document 204-8 Filed 04/16/21 Page5of6
Page 5
persons protected by a constitutional, common-law, or statutory privilege is particularly applicable
to grand jury proceedings.”)
Case 1:20-cr-00330-PAE Document 204-8 Filed 04/16/21 Page6of6
Page 6
Chemical Bank, 154 F.R.D. at 94 (describing such materials a “technological trade secrets,
currently sensitive customer lists, or
Case 1:20-cr-00330-PAE Document 204-8 Filed 04/16/21 Page4of6
Page 4
Martindell, the district court opined that had the Government obtained judicial relief to issue an
uncontested subpoena for docum
Case 1:20-cr-00330-PAE Document 204-8 Filed 04/16/21 Page3of6
Page 3
Indeed, the Chemical Bank opinion specifically rejected judicial protection for the type of
information the Protective Order appe
Case 1:20-cr-00330-PAE Document 204-8 Filed 04/16/21 Page2of6
Page 2
Discussion
Where, as here, a grand jury subpoena has validly issued, and the recipient of the subpoena
is not contesting complia
_ Case 1:20-cr-00330-PAE Document 204-8 Filed 04/16/21 Page 1of6
vase U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 341 of 348
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
ADDENDUM TO THE NON-PROSECUTION AGREEMENT.
IT APPEARING that the parties seek to clarify
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 339 of 348
EXHIBIT 4
Addendum to the
Non-Prosecution Agreement
DOJ-OGR-00003515
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 334 of 348
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported b
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 333 of 348
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 204-3 Filed 04/16/21 Page 332 of 348
proposed agreements with the State Attorney’s Office prior to entering
into those agreements.
7. The United States shall provide
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 329 of 348
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
/
NON-PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach Police Department
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 325 of 348
3. Epstein shall waive all challenges to the Information filed by the State
Attorney’s Office and shall waive the right to appeal
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 326 of 348
agreement. Epstein further asserts and certifies that he understands that the Fifth Amendment
and Rule 7(a) of the Federal Rules o
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 327 of 348
EXHIBIT 3
September 24, 2007
Non-Prosecution
Agreement
DOJ-OGR-00003503
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 323 of 348
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
NON-PROSECUTION AGREEMENT
IT APPEARING that Jeffrey Epstein (hereinafter “Epstein’”) is
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 319 of 348
INDICTMENT
lio
i
ATRUEBILL (6- 94SEC iss & 4
IN THE NAME OF AND BY THE AUTHORITY OF THE a 4s OF FLORIDA = =
Nose 4 ~
IN THE CIR
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 321 of 348
EXHIBIT 2
September 6, 2007
Draft Non-Prosecution
Agreement
DOJ-OGR-00003497
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 308 of 348
to be paid to the FBI’s communications to ensure that the victims were receiving accurate and
timely information that was consiste
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 307 of 348
Villafafia informed Edwards about the state plea, but did not mention the NPA or the fact that the
state pleas would resolve the f
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 306 of 348
intentionally concealing information from them and was part of a series of interactions with
victims that led to condemnation of t
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 304 of 348
previously noted, there is some contemporaneous evidence supporting her assertion. Villafafia’s
mention of the agreement, even if
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 302 of 348
not plead guilty in October 2007 as the USAO expected, it was a “very open question” whether
the case would go to trial, and Acost
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 300 of 348
agent and Villafafia consulted with the USAO’s Professional Responsibility Officer about the
matter, and thereafter stopped notify
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 297 of 348
investigation. Because the state indictment and information appeared to pertain to far fewer than
the total victims identified in
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 294 of 348
particular charges and victims at issue. Once the hearing was scheduled, Sloman told Villafafia to
contact PBPD Chief Reiter about
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 292 of 348
strongly objected to the government’s plan to notify victims of the state proceedings, which he
described as “highly inappropriate