From: "Pomerantz, Lara (USANYS)" To: Christian Everdell , "Comey, Maurene (USANYS)" , "Moe, Alison (USANYS)" , "Rohrbach, Andrew (USANYS)" Cc: Laura Menninger , Jeff Pagliuca , 'BOBBI C STERNHEIM' Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order Date: Wed, 30 Jun 2021 20:59:57 +0000 Attachments: 2021-06-30_GMjoint_letter re_redactions_to_suppression_opinion.docx Chris, We agree. Attached please find a draft joint letter to the Court conveying the parties' position. Please let us know if you have any proposed revisions to the letter. Best, Lara From: Christian Everdell Sent: Wednesday, lune 30, 2021 2:46 PM To: Carney, Maurene (USANYS) ; Moe, Alison (USANYS) ; Pomerantz, Lara (USANYS) ; Rohrbach, Andrew (USANYS) Cc: Laura Menninger , Jeff Pagliuca ipagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' Subject: FW: Activity in Case 1:20-cr-00330-A1N USA v. Maxwell Order All — We have no redactions to propose to the opinion or the other documents mentioned in the court's order. Will you be filing the joint letter? Regards, Chris From: NYSD ECF Pool@nysd.uscourts.gov [mailto:NYSD ECF Pool@nysd.uscourts.gcAd Sent: Wednesday, June 30, 2021 2:11 PM To: CourtMail@nysd.uscourts.gov Subject: Activity in Case 1:20-cr-00330-A]N USA v. Maxwell Order ### This is an automatic e-mail message generated by the CMIECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions. ### U.S. District Court ### Southern District of New York ### Notice of Electronic Filing The following transaction was entered on 6/30/2021 at 2:11 PM EDT and filed on 6/30/2021 Case Name: USA v. Maxwell Case Number: 1:20-er-00330-AJN Filer: Document Number:305 Docket Text: ORDER as to Ghislaine Maxwell: Pursuant to the Courts order of June 25, 2021 (Dkt. No. 303), any proposed redactions to the Court's opinion on Maxwell's motions to suppress evidence must be filed no later than today, June 30, 2021. Any proposed redactions to the other documents ordered unsealed in that order must be filed no later than July 2, 2021. The parties shall file a joint letter by each of these dates informing the Court if no redactions are sought. SO ORDERED. (Signed by Judge Alison J. Nathan on 6/30/2021) (InI) 1:20-cr-00330-AJN-1 Notice has been electronically mailed to: David Boies, II dboies@bsflIp.com, NYC_Managing_Clerk@bsfflp.com Jeffrey S. Pagliuca jpagliuca@hinflaw.com, nsimmons@hmflaw.com Laura A. Menninger Imenninger@hmflaw.com alundberg®hmflaw.com, hrogers@hmflaw.com nsimmons@hmflaw.com Bobbi C Stemheim bc®stemheimlaw.com, bcstemheim@mac.com, ecf@stemheimlaw.com Christian R. Everdell ceverdell@cohengresser.com, autodocket@cohengresser.com Mark Stewart Cohen mcohen@cohengresseccom, Mark-Cohen-1234@ecfpacerpro.com autodocket@cohengresser.com, managingclerksoffice@cterigressencom Sigrid S. McCawley smccawley@bsfllp.com, NYC_Managing_Clerk@ballp.com, achristie@bsfllp.com, lamberslex@bsfll com Sigrid-mccawley-4908@ecfpacerpro.com Lara Elizabeth Pomerantz Lara.Pomerantz@usdoj.gpy, CaseView.ECRThusdoj.gov, USANYS.ECF@USDOJ.GOV Alison Gainfort Moe alison.moe@usdoj.mv, CaseView.ECF®usdoj.gov, USANYS.ECF@USDOJ.GOV Alex Rossmiller alexanderrossmiller®usdoj.gov, CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV Maurene Ryan Comey maurene.comey@usdoj.gov, CaseView.ECF®usdoj.gpir, V Andrew Rohrbach Andrew.Rohrbach@usdoj.m, caseview.ecf@usdoj.gpi, usanys.ecfOusdoj.gpi ### 1:20-cr-00330-AJN-1 Notice has been delivered by other means to: The following document(s) are associated with this transaction: Document description:Main Document Original filenamem/a Electronic document Stamp: [STAMP dcecfStamp_11: 1008691343 [Date=6/30/2021] [FileNumber=26121187- 0] [3c5a70929198acf931c1f73c5a2a597c98feed5c5d0403d4c6fl f89b4baad04043 ea20ed7c38e46a961e8fadb631a8a67a274479c460bebe5b89e28cce654c1]] EFTA00029537 The Government expects Minor Victim-3 to testify, in substance and in part, that she met the defendant when she was approximately 17 years old. Within a few weeks of meeting the defendant, at the defendant's invitation, Minor Victim-3 went to the defendant's townhouse in London for tea. The defendant expressed an interest in Minor Victim-3, talked with Minor Victim-3 about Minor Victim-3's life and interests, and told Minor Victim-3 about her boyfriend Jeffrey Epstein, who she wanted Minor Victim-3 to meet. Shortly after, the defendant invited Minor Victim-3 to her home. During that first visit, the defendant introduced Minor Victim-3 to Epstein and encouraged her to give Epstein a foot massage. Epstein instructed Minor Victim-3 to massage his shoulders. Minor Victim-3 left the townhouse after she was excused. Shortly thereafter, the defendant invited Minor Victim-3 to her home again and encouraged Minor Victim-3 to provide Epstein with a massage. The defendant showed Minor Victim-3 to a room in which a massage table was set up. Epstein was in the room. Epstein removed his robe and was naked. The defendant handed Minor Victim-3 oil and closed the door. After the massage, the defendant was outside the room and asked if Minor Victim-3 had fun and whether Epstein liked the massage. The defendant subsequently told Minor Victim-3 that Epstein was impressed with her and asked her to come back to her townhouse. The defendant encouraged Minor Victim-3 to provide a massage to Epstein. The defendant thanked Minor Victim-3, indicating that if it wasn't Minor Victim-3 or someone else, it would all fall to her (the defendant). The defendant again showed Minor Victim-3 to a room with a massage table where Epstein was naked. Both massages involved at least one sex act with Minor Victim-3. Following those two encounters, the defendant and Epstein invited Minor Victim-3 to travel with them to Florida, the U.S. Virgin Islands, and New York. Minor Victim-3 eventually accepted these invitations, but she does not recall whether she was 17 or 18 when she took her first trip at Epstein and the defendant's invitation. Minor Victim-3 traveled to visit the defendant and Epstein in New York, Palm Beach, and Little Saint James. When Minor Victim-3 met the defendant and Epstein in these locations, she provided additional massages to Epstein, during which he engaged in sex acts with Minor Victim-3. Over the course of their interactions, the defendant made multiple statements to Minor Victim-3 reflecting the defendant's awareness that Epstein engaged in sex acts with Minor Victim-3. On at least one occasion, the defendant asked Minor Victim-3 if she knew any other young females to bring to Epstein and made comments to Minor Victim-3 about Epstein's significant sexual needs. On one occasion in Palm Beach, the defendant provided Minor Victim-3 with a schoolgirl uniform and told Minor Victim-3, in substance and in part, that she should bring Epstein his tea in the uniform. After Minor Victim-3 brought Epstein tea that had been provided by the defendant, Epstein raped Minor Victim-3.