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 --- PAGE BREAK --- DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) ADDITIONAL COUNTS OF CONVICTION Title & Section Nature of Offense Offense Ended Count 18 USC 2423.F TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 12/31/1997 4 18 USC 1591.F SEX TRAFFICKING OF AN INDIVIDUAL UNDER THE AGE OF EIGHTEEN 7/30/2004 6 --- PAGE BREAK --- DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) Judgment — Page 3 of 8 IMPRISONMENT The defendant is hereby committed to the custody of the Federal Bureau of Prisons to be imprisoned for a total term of: The Defendant is sentenced to a term of 240 Months. Count 3 a sentence of 60 Months. Count 4 a sentence of 120 Months. Count 6 a sentence of 240 Months. All Counts to run concurrently. Defendant was notified of her right to Appeal. The court makes the following recommendations to the Bureau of Prisons: Defendant to be considered for designation to FCI Danbury. Defendant to be considered for enrollment in FIT program. The defendant is remanded to the custody of the United States Marshal. The defendant shall surrender to the United States Marshal for this district: at a.m. p.m. on as notified by the United States Marshal. The defendant shall surrender for service of sentence at the institution designated by the Bureau of Prisons: before 2 p.m. on as notified by the United States Marshal. as notified by the Probation or Pretrial Services Office. RETURN I have executed this judgment as follows: Defendant delivered on to at , with a certified copy of this judgment. UNITED STATES MARSHAL By DEPUTY UNITED STATES MARSHAL DOJ-OGR-00020480 --- PAGE BREAK --- AO 245B (Rev. 09/19) Judgment in a Criminal Case Sheet 3 — Supervised Release DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) SUPERVISED RELEASE Upon release from imprisonment, you will be on supervised release for a term of: 3 Years on Counts 3 and 4. 5 Years on Count 6 to run concurrently. MANDATORY CONDITIONS 1. You must not commit another federal, state or local crime. 2. You must not unlawfully possess a controlled substance. 3. You must refrain from any unlawful use of a controlled substance. You must submit to one drug test within 15 days of release from imprisonment and at least two periodic drug tests thereafter, as determined by the court. The above drug testing condition is suspended, based on the court's determination that you pose a low risk of future substance abuse. (check if applicable) 4. You must make restitution in accordance with 18 U.S.C. §§ 3663 and 3663A or any other statute authorizing a sentence of restitution. (check if applicable) 5. You must cooperate in the collection of DNA as directed by the probation officer. (check if applicable) 6. You must comply with the requirements of the Sex Offender Registration and Notification Act (34 U.S.C. § 20901, et seq.) as directed by the probation officer, the Bureau of Prisons, or any state sex offender registration agency in the location where you reside, work, are a student, or were convicted of a qualifying offense. (check if applicable) 7. You must participate in an approved program for domestic violence. (check if applicable) You must comply with the standard conditions that have been adopted by this court as well as with any other conditions on the attached page. DOJ-OGR-00020481 --- PAGE BREAK --- AO 245B (Rev. 09/19) Judgment in a Criminal Case Sheet 3A — Supervised Release Judgment—Page 5 of 8 DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) STANDARD CONDITIONS OF SUPERVISION As part of your supervised release, you must comply with the following standard conditions of supervision. These conditions are imposed because they establish the basic expectations for your behavior while on supervision and identify the minimum tools needed by probation officers to keep informed, report to the court about, and bring about improvements in your conduct and condition. 1. You must report to the probation office in the federal judicial district where you are authorized to reside within 72 hours of your release from imprisonment, unless the probation officer instructs you to report to a different probation office or within a different time frame. 2. After initially reporting to the probation office, you will receive instructions from the court or the probation officer about how and when you must report to the probation officer, and you must report to the probation officer as instructed. 3. You must not knowingly leave the federal judicial district where you are authorized to reside without first getting permission from the court or the probation officer. 4. You must answer truthfully the questions asked by your probation officer. 5. You must live at a place approved by the probation officer. If you plan to change where you live or anything about your living arrangements (such as the people you live with), you must notify the probation officer at least 10 days before the change. If notifying the probation officer in advance is not possible due to unanticipated circumstances, you must notify the probation officer within 72 hours of becoming aware of a change or expected change. 6. You must allow the probation officer to visit you at any time at your home or elsewhere, and you must permit the probation officer to take any items prohibited by the conditions of your supervision that he or she observes in plain view. 7. You must work full time (at least 30 hours per week) at a lawful type of employment, unless the probation officer excuses you from doing so. If you do not have full-time employment you must try to find full-time employment, unless the probation officer excuses you from doing so. If you plan to change where you work or anything about your work (such as your position or your job responsibilities), you must notify the probation officer at least 10 days before the change. If notifying the probation officer at least 10 days in advance is not possible due to unanticipated circumstances, you must notify the probation officer within 72 hours of becoming aware of a change or expected change. 8. You must not communicate or interact with someone you know is engaged in criminal activity. If you know someone has been convicted of a felony, you must not knowingly communicate or interact with that person without first getting the permission of the probation officer. 9. If you are arrested or questioned by a law enforcement officer, you must notify the probation officer within 72 hours. 10. You must not own, possess, or have access to a firearm, ammunition, destructive device, or dangerous weapon (i.e., anything that was designed, or was modified for, the specific purpose of causing bodily injury or death to another person such as nunchakus or tasers). 11. You must not act or make any agreement with a law enforcement agency to act as a confidential human source or informant without first getting the permission of the court. 12. You must follow the instructions of the probation officer related to the conditions of supervision. U.S. Probation Office Use Only A U.S. probation officer has instructed me on the conditions specified by the court and has provided me with a written copy of this judgment containing these conditions. For further information regarding these conditions, see Overview of Probation and Supervised Release Conditions, available at: www.uscourts.gov. Defendant's Signature Date DOJ-OGR-00020482 --- PAGE BREAK --- DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) SPECIAL CONDITIONS OF SUPERVISION You shall submit your person, and any property, residence, vehicle, papers, computer, other electronic communication, data storage devices, cloud storage or media, and effects to a search by any United States Probation Officer, and if needed, with the assistance of any law enforcement. The search is to be conducted when there is reasonable suspicion concerning violation of a condition of supervision or unlawful conduct by the person being supervised. Failure to submit to a search may be grounds for revocation of release. You shall warn any other occupants that the premises may be subject to searches pursuant to this condition. Any search shall be conducted at a reasonable time and in a reasonable manner. You shall undergo a sex-offense-specific evaluation and participate in an outpatient sex offender treatment and/or outpatient mental health treatment program approved by the U.S. Probation Office. You shall abide by all rules, requirements, and conditions of the sex offender treatment program(s), including submission to polygraph testing and refraining from accessing websites, chatrooms, instant messaging, or social networking sites to the extent that the sex offender treatment and/or mental health treatment program determines that such access would be detrimental to your ongoing treatment. You will not view, access, possess, and/or download any pornography involving adults unless approved by the sex-offender specific treatment provider. You must waive your right of confidentiality in any records for mental health assessment and treatment imposed as a consequence of this judgment to allow the U.S. Probation Office to review the course of treatment and progress with the treatment provider. You must contribute to the cost of services rendered based on your ability to pay and the availability of third-party payments. The Court authorizes the release of available psychological and psychiatric evaluations and reports, including the presentence investigation report, to the sex offender treatment provider and/or mental health treatment provider. You must not have contact with the victim(s) in this case. This includes any physical, visual, written, or telephonic contact with such persons. Additionally, you must not directly cause or encourage anyone else to have such contact with the victim (s). You must not have deliberate contact with any child under 18 years of age, unless approved by the U.S. Probation Office. You must not loiter within 100 feet of places regularly frequented by children under the age of 18, such as schoolyards, playgrounds, and arcades. You must not view and/or access any web profile of users under the age of 18. This includes, but is not limited to, social networking websites, community portals, chat rooms or other online environment (audio/visual/messaging), etc. which allows for real time interaction with other users, without prior approval from your probation officer. You must provide the probation officer with access to any requested financial information. You must not incur new credit charges or open additional lines of credit without the approval of the probation officer unless you are in compliance with the installment payment schedule. If you are sentenced to any period of supervision, it is recommended that you be supervised by the district of residence. --- PAGE BREAK --- DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) CRIMINAL MONETARY PENALTIES The defendant must pay the total criminal monetary penalties under the schedule of payments on Sheet 6. TOTALS Assessment Restitution Fine AVAA Assessment* JVTA Assessment** $ 300.00 $ $ 750,000.00 $ $ The determination of restitution is deferred until . An Amended Judgment in a Criminal Case (AO 245C) will be entered after such determination. The defendant must make restitution (including community restitution) to the following payees in the amount listed below. If the defendant makes a partial payment, each payee shall receive an approximately proportioned payment, unless specified otherwise in the priority order or percentage payment column below. However, pursuant to 18 U.S.C. § 3664(i), all nonfederal victims must be paid before the United States is paid. Name of Payee Total Loss*** Restitution Ordered Priority or Percentage TOTALS $ 0.00 $ 0.00 Restitution amount ordered pursuant to plea agreement $ The defendant must pay interest on restitution and a fine of more than $2,500, unless the restitution or fine is paid in full before the fifteenth day after the date of the judgment, pursuant to 18 U.S.C. § 3612(f). All of the payment options on Sheet 6 may be subject to penalties for delinquency and default, pursuant to 18 U.S.C. § 3612(g). The court determined that the defendant does not have the ability to pay interest and it is ordered that: the interest requirement is waived for the fine restitution. the interest requirement for the fine restitution is modified as follows: * Amy, Vicky, and Andy Child Pornography Victim Assistance Act of 2018, Pub. L. No. 115-299. ** Justice for Victims of Trafficking Act of 2015, Pub. L. No. 114-22. *** Findings for the total amount of losses are required under Chapters 109A, 110, 110A, and 113A of Title 18 for offenses committed on or after September 13, 1994, but before April 23, 1996. DOJ-OGR-00020484 --- PAGE BREAK --- DEFENDANT: GHISLAINE MAXWELL CASE NUMBER: S2 20 CR 330 (AJN) SCHEDULE OF PAYMENTS Having assessed the defendant's ability to pay, payment of the total criminal monetary penalties is due as follows: A Lump sum payment of $ 300.00 due immediately, balance due not later than , or in accordance with C, D, E, or F below; or B Payment to begin immediately (may be combined with C, D, or F below); or C Payment in equal (e.g., weekly, monthly, quarterly) installments of $ over a period of (e.g., months or years), to commence (e.g., 30 or 60 days) after the date of this judgment; or D Payment in equal (e.g., weekly, monthly, quarterly) installments of $ over a period of (e.g., months or years), to commence (e.g., 30 or 60 days) after release from imprisonment to a term of supervision; or E Payment during the term of supervised release will commence within 30 (e.g., 30 or 60 days) after release from imprisonment. The court will set the payment plan based on an assessment of the defendant's ability to pay at that time; or F Special instructions regarding the payment of criminal monetary penalties: Unless the court has expressly ordered otherwise, if this judgment imposes imprisonment, payment of criminal monetary penalties is due during the period of imprisonment. All criminal monetary penalties, except those payments made through the Federal Bureau of Prisons' Inmate Financial Responsibility Program, are made to the clerk of the court. The defendant shall receive credit for all payments previously made toward any criminal monetary penalties imposed. Joint and Several Case Number Defendant and Co-Defendant Names (including defendant number) Total Amount Joint and Several Amount Corresponding Payee, if appropriate The defendant shall pay the cost of prosecution. The defendant shall pay the following court cost(s): The defendant shall forfeit the defendant's interest in the following property to the United States: Payments shall be applied in the following order: (1) assessment, (2) restitution principal, (3) restitution interest, (4) AVAA assessment, (5) fine principal, (6) fine interest, (7) community restitution, (8) JVTA assessment, (9) penalties, and (10) costs, including cost of prosecution and court costs. DOJ-OGR-00020485