Document s2-20-cr-330-ajn

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. GHISLAINE MAXWELL Defendant. STIPULATION S2 20 Cr. 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The witness referred to as Kate and her counsel attended a meeting with the government prosecutors on September 3, 2021. 2. At that meeting, Kate's counsel provided the government prosecutors with a partially completed visa application for a U-Visa and asked to discuss Kate's visa status. S2 20 Cr. 330 (AJN) Defendant's Ex. A-1 DOJ-OGR-00015164 --- PAGE BREAK --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA - v. - GHISLAINE MAXWELL, Defendant. STIPULATION S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. On August 17, 2021, Robert Glassman, counsel for the witness testifying using the pseudonym Jane, spoke by phone with a prosecutor in this case. The notes of the call reflect that: 2. Glassman stated that before the Government charged the case, Jane had discussed with Glassman whether to cooperate with the case, and during those conversations Glassman had advised Jane to cooperate and discussed with Jane that cooperating with the case was the morally right thing to do, and they had discussed how testifying at trial was the right thing to do. Glassman also mentioned that Glassman had told Jane it would "help her case." S2 20 Cr. 330 (AJN) Defendant's Ex. A-6 DOJ-OGR-00015169 --- PAGE BREAK --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. STIPULATION S2 20 Cr. 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. Sgt. Michael Dawson, who previously testified in this case, would have given the following additional testimony on cross-examination: a. The cardboard box shown in GX-294, which was recovered during the search of Jeffrey Epstein's Palm Beach residence on October 20, 2005, was found in the closet of one of the guest bedrooms on the second floor of the residence. b. The two items inside the cardboard box, which are visible in GX-294, were still in their original boxes, unopened. DEFENDANT'S EXHIBIT B S2 20 Cr. 330 (AJN) DOJ-OGR-00015185 --- PAGE BREAK --- DEFENDANT'S EXHIBIT CE-3 S2 20 Cr. 330 (AJN) MS. DOJ REDACTION c/o Epstein & Co. 457 Madison Ave. 4th Fl. New York, N.Y. 10022 DOJ-OGR-00015203 --- PAGE BREAK --- IMPORTANT MESSAGE FOR JE Eps tein DATE 02/01/03 TIME 3454 A.M. P.M. MR DORON OF PHONE 310 779 AREA CODE NUMBER TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED Evelyn 1184 IMPORTANT MESSAGE FOR JE DATE 01/02/03 TIME 12:05 A.M. P.M. MR DOJ REDACTION OF PHONE 478 AREA CODE NUMBER 5 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED 1184 IMPORTANT MESSAGE DOJ REDACTION FOR DATE DOJ REDACTION TIME A.M. P.M. MR OF PHONE AREA CODE NUMBER EXTENSION TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE She will be here tomorrow Ham SIGNED 1184 IMPORTANT MESSAGE FOR JE DAT DOJ REDACTION TIME 2:25 A.M. P.M. MR OF PHONE 91391 AREA CODE NUMBER EXTENSION TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED 1184 GOVERNMENT EXHIBIT 2-D-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015472 --- PAGE BREAK --- GOVERNMENT EXHIBIT 3-A S2 20 Cr. 330 (AJN) CARBONLESS 2 PART adams Important Message Book 200 sets 8 1/16" x 11" (20.4 cm x 27.9 cm) SC1184D DOJ-OGR-00015492 --- PAGE BREAK --- IMPORTANT MESSAGE FOR Jeffrey DATE DOJ REDACTION TIME 1:35 A.M. P.M. OF PHONE/MOBILE 917 603 TELEPHONED X PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE He She called again M SIGNED ru IMPORTANT MESSAGE FOR Jeffrey DATE 01/09/05 TIME 12:20 A.M. P.M. OF PHONE/MOBILE 917 304 TELEPHONED X PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Returning phone call SIGNED Kay IMPORTANT MESSAGE FOR Jeffrey Israeli DATE TIME A.M. P.M. OF PHONE/MOBILE 516 883 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED IMPORTANT MESSAGE FOR Jeffrey DATE 01/10/05 TIME 12:40 A.M. P.M. OF PHONE/MOBILE 917 855 TELEPHONED X PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Just that she called SIGNED GOVERNMENT EXHIBIT 3-AA-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015493 --- PAGE BREAK --- IMPORTANT MESSAGE FOR: Jeffrey DATE: 02/09/05 TIME: 4:20 A.M. M: Doritin Krauss OF: PHONE/MOBILE: 216 910 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE: Calling regarding Santo Fee Institute thanking for hospitality - if you could let him look at his book Please call him back SIGNED: IMPORTANT MESSAGE FOR: DATE: TIME: A.M. P.M. M: OF: PHONE/MOBILE: TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE: Alan Distante SIGNED: IMPORTANT MESSAGE FOR: Jeffrey DATE: 04/09/05 TIME: 7:40 A.M. M: OF: PHONE/MOBILE: TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE: She is wondering if she could come later tomorrow SIGNED: IMPORTANT MESSAGE FOR: Jeffrey DATE: 02/09/05 TIME: 6:50 A.M. M: OF: PHONE/MOBILE: 914 855 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE: She needs to speak to you SIGNED: AJ7 GOVERNMENT EXHIBIT 3-BB-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015494 --- PAGE BREAK --- IMPORTANT MESSAGE FOR JEFF DATE DOJ REDACTION TIME 11:15 A.M. OF PHONE/MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED a 1184 IMPORTANT MESSAGE FOR Jeffery DATE 6/9/05 TIME 11:26 A.M. M Chishlaine OF PHONE/MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Just that she has called. It's not important SIGNED a 1184 IMPORTANT MESSAGE FOR Jeffery DATE 6/9/05 TIME 1:30 P.M. M Cecilia OF PHONE/MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Yes she called SIGNED AM a 1184 IMPORTANT MESSAGE FOR Jeffery DATE 2/9/05 TIME 12:25 P.M. M Darrien OF PHONE/MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Just that he called. GOVERNMENT EXHIBIT 3-EE S2 20 Cr. 330 (AJN) DOJ-OGR-00015500 a 1184 --- PAGE BREAK --- IMPORTANT MESSAGE FOR Jeffrey DATE 01/20/05 TIME 5:00 A.M. P.M. M Christine OF PHONE/ MOBILE TELEPHONED RETURNED YOUR CALL PLEASE CALL WILL CALL AGAIN SPECIAL ATTENTION MESSAGE SIGNED a 1184 IMPORTANT MESSAGE FOR Sarah DATE 01/20/05 TIME 4:15 A.M. P.M. M GM OF PHONE/ MOBILE TELEPHONED PLEASE CALL MESSAGE Call her at home SIGNED a 1184 IMPORTANT MESSAGE FOR Joe DATE 8:30 A.M. P.M. M DOJ REDACTION OF PHONE/ MOBILE 917 330 TELEPHONED RETURNED YOUR CALL PLEASE CALL MESSAGE Wishing you a Happy Bday SIGNED a 1184 IMPORTANT MESSAGE FOR DATE DOJ REDACTION TIME 11:20 A.M. P.M. M OF PHONE/ MOBILE 6067 TELEPHONED RETURNED YOUR CALL PLEASE CALL MESSAGE The girl who was referred to you by DOJ REDACTION that we sent home SIGNED GOVERNMENT EXHIBIT 3-FF-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015502 a 1184 --- PAGE BREAK --- IMPORTANT MESSAGE FOR Jeffrey DATE 11/25/05 TIME 3:40 A.M. M George son OF PHONE/ MOBILE 8881274 TELEPHONED CAME TO SEE YOU PLEASE CALL WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE It's regarding the letter you have recured about invest in Texico Number you should refer to is 310B SIGNED Mark Doe IMPORTANT MESSAGE FOR Jeffrey DATE 01/25/05 TIME 2:55 A.M. M Ghislane OF PHONE/ MOBILE her cell phone TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Please call back SIGNED Eric to Mark IMPORTANT MESSAGE DOJ REDACTION FOR DATE TIME A.M. P.M. M OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE U 30 SIGNED IMPORTANT MESSAGE FOR Jeffrey DATE DOJ REDACTION 11/25/05 TIME 12:45 A.M. M OF PHONE/ MOBILE 1561379 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE called again about waiting today SIGNED GOVERNMENT EXHIBIT 3-II-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015508 --- PAGE BREAK --- IMPORTANT MESSAGE FOR SARAH RN DATE 07/10/04 TIME 6:33 A.M. P.M. M SCHANZ OF RAGHU PHONE/MOBILE 66 C1G 791 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE PL CALL SIGNED IMPORTANT MESSAGE FOR AR EPSTEIN DATE TIME A.M. P.M. M CECILIA (OFFICE) OF PHONE/MOBILE 917 759 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED IMPORTANT MESSAGE FOR SARRAH DATE 7/9/04 TIME 10:31 A.M. P.M. M MILES OF LESLIE (NY OFFICE) PHONE/MOBILE 203 972 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SHE IS WORKING FROM SCHEDULED DAY I'LL BE IN THE ABOVE #1 ASAP SIGNED IMPORTANT MESSAGE FOR MR EPSTEIN DATE 7/9/04 TIME 7:50 A.M. P.M. M DOJ REDACTION OF PHONE/MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE DOJ REDACTION IS AVAILABLE ON TUESDAY NO ONE FOR TOMORROW SIGNED GOVERNMENT EXHIBIT 3-L-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015514 --- PAGE BREAK --- IMPORTANT MESSAGE FOR JE DATE 7/19/04 TIME 430 P.M. M GLEN ROBIN OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE WILL BE HOME IN 20 MIN PLEASE CALL SIGNED IMPORTANT MESSAGE FOR MR EPSTEIN DATE 11/8/04 TIME 3:00 P.M. M ROGER OF PHONE/ MOBILE (He has my #) TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE "TELL HIM I SENT ANOTHER ONE TO READ" SIGNED RV IMPORTANT MESSAGE FOR MR EPSTEIN DATE 7/19/04 TIME 300 P.M. M DOJ REDACTION OF PHONE/ MOBILE 5611 201 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE "IS IT OK TO TAKE A TAXI" SIGNED IMPORTANT MESSAGE FOR MS. EPSTEIN DATE 07/17/04 TIME 2:48 P.M. M OF PETER FROM LONDON PHONE/ MOBILE (DID NOT GIVE THE #) TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE "I AM RETURNING YOUR CALL" SIGNED GOVERNMENT EXHIBIT 3-N-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015516 --- PAGE BREAK --- IMPORTANT MESSAGE FOR JEFF DATE DOJ REDACTION TIME 11:75 A.M. P.M. M OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE SIGNED a 1184 IMPORTANT MESSAGE FOR Jeffery DATE 6/9/05 TIME 11:20 A.M. P.M. M Chishlaine OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Just that she has called. It's not important SIGNED a 1184 IMPORTANT MESSAGE FOR Jeffery DATE 6/9/05 TIME 1:30 A.M. P.M. M Cecilia OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Yes she called SIGNED AM a 1184 IMPORTANT MESSAGE FOR Jeffery DATE 2/9/05 TIME 12:25 A.M. P.M. M Darrien OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Just that he called. SIGNED GOVERNMENT EXHIBIT 3-S S2 20 Cr. 330 (AJN) DOJ-OGR-00015521 a 1184 --- PAGE BREAK --- IMPORTANT MESSAGE FOR Jeffrey DATE DOJ REDACTION TIME 3:40 A.M. P.M. OF PHONE/MOBILE 561 202 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE She has a female friend for you Please call back as soon as possible SIGNED IMPORTANT MESSAGE FOR Jeffrey DATE 1/24/85 TIME 1:10 A.M. OF PHONE/MOBILE 9336374 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE She called SIGNED IMPORTANT MESSAGE FOR Jeffrey DATE 1/24/85 TIME 6:15 A.M. P.M. OF PHONE/MOBILE 305580 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Just that she called SIGNED GOVERNMENT EXHIBIT 3-V-R S2 20 Cr. 330 (AJN) IMPORTANT MESSAGE FOR Jeffrey DATE 1/24/85 TIME 6:05 A.M. P.M. OF Cecilia PHONE/MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE DOJ REDACTION Cecilia will put it on sheet as well SIGNED DOJ-OGR-00015524 --- PAGE BREAK --- IMPORTANT MESSAGE FOR Jeffrey DATE 11/25/05 TIME 3:40 A.M. M George S OF PHONE/ MOBILE 8881274 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE It's regarding the letter you have received about investors in Mexico Number you should refer to is 310B SIGNED Mark Dec IMPORTANT MESSAGE FOR Jeffrey DATE 01/25/05 TIME 12:55 A.M. M Ghislane OF PHONE/ MOBILE her cell phone TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE Please call back SIGNED Eric to talk IMPORTANT MESSAGE DOJ REDACTION FOR DATE TIME A.M. P.M. M OF PHONE/ MOBILE TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE U 30 SIGNED IMPORTANT MESSAGE FOR Jeffrey DATE 11/25/05 TIME 12:45 A.M. M OF PHONE/ MOBILE 1561379 TELEPHONED PLEASE CALL CAME TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION MESSAGE called again about waiting today SIGNED GOVERNMENT EXHIBIT 3-W-R S2 20 Cr. 330 (AJN) DOJ-OGR-00015525 --- PAGE BREAK --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA - v. - GHISLAINE MAXWELL, Defendant. S2 20 CR 330 (AJN) STIPULATION IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. Government Exhibit 11 is a true and correct certified copy of a birth certificate reported to the New York Department of State. Government Exhibit 11 accurately reflects the date of birth of the person named on the certificate. 2. Government Exhibit 12 is a true and correct certified copy of a birth certificate reported to the Rhode Island Department of Health. Government Exhibit 12 accurately reflects the date of birth of the person named on the certificate. 3. Government Exhibit 13 is a true and correct certified copy of a birth certificate reported to the Missouri Department of Health and Senior Services. Government Exhibit 13 accurately reflects the date of birth of the person named on the certificate. GOVERNMENT EXHIBIT 1004 S2 20 Cr. 330 (AJN) DOJ-OGR-00015537 --- PAGE BREAK --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA - v. - GHISLAINE MAXWELL, Defendant. S2 20 CR 330 (AJN) STIPULATION IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. Government Exhibits 52A, 52D, 52E, 52F, 52G, and 52H are true and correct photocopies of six pages of Government Exhibit 52. GOVERNMENT EXHIBIT 1009 S2 20 Cr. 330 (AJN) DOJ-OGR-00015540 --- PAGE BREAK --- GOVERNMENT EXHIBIT 318 S2 20 Cr. 330 (AJN) DOJ-OGR-00015641 --- PAGE BREAK --- SOFTWARE[366023].dat.[AD].html Registry SOFTWARE Information Install Date 2/22/2001 20:46:35 +0000 Product Name Microsoft Windows 2000 Registered Organization gmax Registered Owner gmax CSDVersion Service Pack 1 Digital Product ID A4 00 00 00 03 00 00 00 35 31 38 37 33 2D 4F 45 4D 2D 30 30 34 35 30 32 33 2D 30 39 31 33 36 00 13 00 00 00 41 32 2D 30 30 30 30 31 00 00 00 00 00 00 00 E0 4A AB B5 09 36 00 29 98 BA 60 ED 4E F5 00 00 00 00 00 00 15 26 95 3A 0A B7 05 00 02 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 37 37 34 32 33 00 00 00 00 00 00 8A 01 00 00 0E 02 D1 07 00 01 00 02 18 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 AC 85 CC 15 GOVERNMENT EXHIBIT 419 S2 20 Cr. 330 (AJN) DOJ-OGR-00015674 --- PAGE BREAK --- LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 • Main 917-912-9698 • Cell 888-587-4737 • Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: _____ DATE FILED: 3/3/22 March 2, 2022 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: In response to a letter from Juror 50's counsel indicating the juror's intention to assert the Fifth Amendment privilege against self-incrimination at the upcoming hearing (Dkt. 624), the government has informed the Court that it is in the process of making an application for a grant of immunity for the juror. (Dkt. 625). Juror 50 has publicly stated that he "answered all questions honestly." Ms. Maxwell requests a proffer from Juror 50's counsel explaining the basis for his client's assertion of the Fifth Amendment and the government's willingness to provide immunity to Juror 50. Very truly yours, Bobbi C. Sternheim BOBBI C. STERNHEIM cc: Counsel of record No grounds are offered for entitlement to the requested proffer, and the Court is not aware of any basis for granting the request. DENIED. SO ORDERED. Alison J. Nathan 3/3/22 DOJ-OGR-00009621 --- PAGE BREAK --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNITED STATES OF AMERICA - V. - GHISLAINE MAXWELL, Defendant. X STIPULATION S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq. that: 1. The HM Land Registry is the governmental authority in the United Kingdom that maintains official public records relating to the ownership of land and property located in the United Kingdom. 2. Defense Exhibit MG-12 are documents relating to the property located at 69 Stanhope Mews East, London SQ7 5QT, United Kingdom that were retrieved from the HM Land Registry on March 26, 2021. 3. Defense Exhibit MG-1 are documents relating to the property located at 44 Kinnerton Street, London SW1X 8ES, United Kingdom that were retrieved from the HM Land Registry on December 13, 2021. 4. Pages 1-3 of Defense Exhibit MG-12 is a true and accurate copy of the HM Land Registry official public record dated January 21, 1994 confirming the registered ownership of S2 20 Cr. 330 (AJN) Defendant's Ex. A-5 DOJ-OGR-00015166 --- PAGE BREAK --- FIL A LA GRANDE SOEUR R & C DEFENDANT'S EXHIBIT AF-1-R S2 20 Cr. 330 (AJN) Property of DOJ REDACTION Not For Media Use DOJ REDACTION DOJ-OGR-00015178 --- PAGE BREAK --- IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO.: Plaintiff, vs. JEFFREY EPSTEIN, and SARAH KELLEN, Defendants. COMPLAINT Plaintiff, sues the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and alleges: 1. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00), exclusive of costs and interest. 2. At all times material hereto, the Plaintiff, was and is a resident of Palm Beach County, Florida. Plaintiff is a female who is presently twenty-one years old. 3. The Plaintiff is unsure of the residency of defendant JEFFREY ESPSTEIN, because he has residences in New York, Florida, New Mexico, and also outside of the continental United States. 4. The defendant, SARAH KELLEN, was a resident of Florida. DEFENDANT'S EXHIBIT C-4 S2 20 Cr. 330 (AJN) 1 DOJ-OGR-00015187 --- PAGE BREAK --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------- X UNITED STATES OF AMERICA - V. - STIPULATION GHISLAINE MAXWELL, S2 20 CR 330 (AJN) Defendant. --------------------------------------------------- X IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. If recalled as a witness, Dominique Hyppolite would testify as follows: 2. The Palm Beach County School maintains school records in the ordinary course of business. 3. The document marked Defense Exhibits DH-1, DH-2 and DH-3 are each a true and accurate copy of Palm Beach County School records for DOJ REDACTION 4. The document marked Defense Exhibit J-2 is a true and accurate copy of Palm Beach County School records for the witness identified as Jane. 5. IT IS FURTHER STIPULATED AND AGREED THAT Defense Exhibits DH-1, DH-2, DH-3 and J-2, and this stipulation, marked as Government Defense Exhibit DH-4, may be received in evidence at trial. DEFENDANT'S EXHIBIT DH-4 S2 20 Cr. 330 (AJN) 1 DOJ-OGR-00015210