Ghislaine Maxwell SECOND SUPERSEDING INDICTMENT -FOURTH MINOR VICTIM -updated

Oh my - the update was NOT what I was expecting - it could be viewed as a slight mini-bombshell- but the USAO-SDNY is doing the right thing by informing & clarifying to the Court

USAO-SDNY letter to the Court

In a five page letter (ECF or via my public drive)¹ to the Court - from SDNY Prosecutors explaining the difference in SR 1 versus SR2 -mainly that prosecutors are disclosing a fourth minor victim and backing the conspiracy and sex trafficking to 2001:

“Whereas Count One of the S1 Indictment alleged that this conspiracy lasted through in or about 1997, Count One of the S2 Indictment alleges that the conspiracy continued through in or about 2004 and specifically identifies a fourth victim, Minor Victim-4, who was a victim of this conspiracy between approximately 2001 and 2004…Count Three of the S2 Indictment alleges that the conspiracy continued through in or about 2004 and specifically identifies a fourth victim, Minor Victim-4, who was a victim of this conspiracy between approximately 2001 and 2004.

Count Five is a NEW CHARGE- which alleges that Maxwell participated in a sex trafficking conspiracy between approximately 2001 and 2004, in violation of 18 U.S.C. § 371. The S2 Indictment specifically identifies Minor Victim-4 as a victim of this conspiracy.

Count Six is also a NEW CHARGE: which alleges that Maxwell participated in the sex trafficking of a minor, and aided and abetted the same, in violation of 18 U.S.C. §§ 1591 and 2. …specifically identifies Minor Victim-4 as the victim of this count.

Defendant Ghislaine Maxwell - SECOND SUPERSEDER

(S2) SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell (1) count(s) 1ss, 2ss, 3ss, 4ss, 5ss, 6ss, 7ss-8ss. ECF-SDNY or via my public drive

“…in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described herein, when providing testimony under oath in 2016”

FOURTH MINOR VICTIM

“…Minor Victim- 4 was recruited to provide Epstein with sexualized massages for which Minor Victim- 4 was paid by Epstein and/or one of his associates…MAXWELL, at the Palm Beach Residence beginning in or around 2001. MAXWELL met Minor Victim- 4 at Epstein' s Palm Beach Residence when Minor Victim- 4 was approximately 14 years old.”

Count Three - Overt Acts

“Between in or about 2001 and in or about 2002, when Minor Victim- 4 was under the age of 18, MAXWELL and Epstein invited Minor Victim-4 to travel from Florida to a place outside of Florida with Epstein”

Count Five:

The government alleges that on numerous occasions (from 2001 through 2004) that various Epstein' s employees, including at times MAXWELL, sent Minor Victim-4 gifts, including lingerie, from an address in Manhattan, New York to Minor Victim-4's residence in Florida. They also encouraged Minor Victim-4 to recruit other young females to provide sexualized massages to Epstein and then rewarded her with cash payments

“…2001 and in or about 2004, both Epstein and MAXWELL recruited Minor Victim- 4 to engage in sex acts with EPSTEIN at the Palm Beach Residence, after which Epstein and, at times, MAXWELL provided Minor Victim- 4 with hundreds of dollars in cash for each encounter. Minor Victim- 4 truthfully told both Epstein and MAXWELL her age…

Count Six

“…MAXWELL, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, MAXWELL recruited, enticed, harbored, transported, provided, and obtained…”

The letter to the Court - Prosecutors stated and (I can’t stress how important this is) the following - it pertains to not only witnesses but discovery production;

“Additionally, in order to ensure that the defense has adequate time to prepare for trial, the Government intends to begin its production to the defense of non-testifying witness statements by April 12, 2021, approximately three months in advance of trial…

…This production will include the statements of more than 250 witnesses related to the investigation of Jeffrey Epstein and his associates in the government’s possession whom the government does not currently expect to call to testify at trial. The government is continuing to review its files for witness statements and will produce any additional non-testifying witness statements that come to light on a rolling basis as promptly as possible in advance of trial.”

March 29, 2021 Order

Maxwell has filed some twelve Pretrial motions - the Court just provided this Order via ECF or via my public drive

the Government’s letter responding to its March 18, 2021 order regarding redactions to its omnibus memorandum of law in opposition to the Defendant’s twelve pretrial motions. Dkt. No. 170.

…By April 1, 2021, the parties must meet and confer and either submit to the Court justification for those redactions…”

Update 2nd letter from USAO-SDNY;

I am going to give you a few words of caution;

• Firstly: anyone on Twitter that doesn’t provide you links to the Court filings - you should be skeptical

• Secondly: before you react to the Government’s second letter to the Court, take a deep breath and understand that context and content are not mutually exclusive. It is understandable that a second or third sweep might elucidate more facts, that doesn’t mean the “government was duplicitous or hiding info”

• Thirdly: try to tune out the conspiratorial tweets because that nonsense is click bait and typically the person tweeting that nonsense is full of ___

The Government just filed a second letter - document no 150, via ECF or via my ² -previously Defendant Maxwell had directly and indirectly accused the USAO-SDNY of possible Prosecutorial misconduct, those allegations have previously been found as unfounded. This evening the USAO-SDNY made the following (some might argue stunning disclosure) but I’d argue this happens more than most people know.

“…defense counsel brought to the Government’s attention information suggesting that the Federal Bureau of Investigation (“FBI”) New York Office may have participated in certain aspects of the Florida Investigation between 2005 and 2010. In response, the Government has re-reviewed portions of its files, including portions of the file of the FBI’s Palm Beach Resident Agency (the “FBI Florida Office”), for documentation indicating that the FBI New York Office interacted with the FBI Florida Office or with the United States Attorney’s Office for the Southern District of New York…”

THIS IS IMPORTANT

In tonight’s letter the USAO-SDNY disclosed that YES after conducting a “re-review”—at the “direction of the FBI Florida Office”

agents assigned to the FBI New York Office assisted the FBI Florida Office by contacting and interviewing or attempting to interview, at the direction of the FBI Florida Office, four witnesses in the New York area between approximately 2007 and 2008 during the Florida Investigation.

After conducting a “re-review” and importantly “at the direction of the Florida FBI office” -and this is very important -there was no separate New York FBI Investigation - again it was the FBI Florida’s office requesting assistance from a sister district

agents assigned to the FBI New York Office assisted the FBI Florida Office by contacting and interviewing or attempting to interview, at the direction of the FBI Florida Office, four witnesses in the New York area between approximately 2007 and 2008 during the Florida Investigation.

But this fact nugget buried on page 2 is equally important:

“…it appears from the FBI Florida Office’s file that the FBI Florida Office contacted numerous other FBI offices, including offices in New Mexico, Australia, and Colombia, to seek similar assistance.”

Again out of an abundance of caution - the USAO-SDNY made this disclosure to the Court and provided the records to the defense as part of the rolling discovery³…

Again don’t freak out and don’t get sucked in to click-bait Twitter because those who are doing that are messing with you and they generally speaking do not have a clue about the things they are tweeting about. As always my goal has always been to provide you the facts and access to public documents. Drops Mic

1. Second Superseding Indictment via ECF - https://ecf.nysd.uscourts.gov/doc1/127028805425 or via my public drive

2. The recent Maxwell Filings are uploaded to a public folder, found on my public drive

3. Fed Crim Rules of Procedure - Rule 16. Discovery and Inspection - Rule 16. Discovery and Inspection - last visited March 29, 2021

(a) Government's Disclosure.

(1) Information Subject to Disclosure.

(A) Defendant's Oral Statement. Upon a defendant's request, the government must disclose to the defendant the substance of any relevant oral statement made by the defendant, before or after arrest, in response to interrogation by a person the defendant knew was a government agent if the government intends to use the statement at trial.