EFTA00030934.pdf
230 KB
Extraction Summary
10
People
2
Organizations
3
Locations
4
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / request for bill of particulars
File Size:
230 KB
Summary
This document is a legal letter dated December 28, 2020, from Ghislaine Maxwell's defense attorney, Christian Everdell, to the US Attorney's Office (SDNY). The letter formally requests a Bill of Particulars to clarify the allegations in the Superseding Indictment, specifically asking for the real names of Minor Victims 1-3, precise dates and locations of alleged grooming and sexual abuse, details regarding travel in 1996 (NM and FL/NY), and specifics concerning perjury allegations from 2016 depositions.
People (10)
| Name | Role | Context |
|---|---|---|
| Christian R. Everdell | Defense Attorney / Sender |
Partner at Cohen & Gresser LLP, representing Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Client of Cohen & Gresser, subject of the Superseding Indictment.
|
| Jeffrey Epstein | Co-conspirator (Deceased) |
Mentioned repeatedly as the person Maxwell allegedly groomed victims for and abused victims with.
|
| Minor Victim-1 | Alleged Victim |
Pseudonym for individual in indictment; defense requests full name, birthday, and details of interactions.
|
| Minor Victim-2 | Alleged Victim |
Pseudonym for individual in indictment; defense requests details regarding 1996 travel to NM.
|
| Minor Victim-3 | Alleged Victim |
Pseudonym for individual in indictment; defense requests details of introduction and abuse.
|
| Mark S. Cohen | Attorney |
CC'd on the letter.
|
| Jeff Pagliuca | Attorney |
CC'd on the letter.
|
| Laura Menninger | Attorney |
CC'd on the letter.
|
| Bobbi C. Sternheim | Attorney |
CC'd on the letter.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Law firm representing Ghislaine Maxwell.
|
|
| United States Attorney's Office, Southern District of New York |
Prosecuting authority receiving the request.
|
Timeline (4 events)
1994-1997
Time period of the charged conspiracies mentioned in Request 23.
Various
1996
Alleged travel of Minor Victim-2 across state lines to and from New Mexico.
New Mexico
Locations (3)
| Location | Context |
|---|---|
|
Location of Cohen & Gresser LLP and the US Attorney's Office.
|
|
|
Mentioned in Request 12 regarding Minor Victim-2's travel in 1996.
|
|
|
Mentioned in Request 26 regarding Minor Victim-1's travel to New York in 1996.
|
Relationships (3)
Letter discusses alleged conspiracies, grooming victims for Epstein, and joint participation in abuse.
Request asks for details on when Maxwell 'groomed', 'met', or 'involved' the victim in sexual acts.
Opening line: 'On behalf of our client, Ghislaine Maxwell...'
Key Quotes (4)
"The Superseding Indictment does not sufficiently inform Ms. Maxwell of the specific conduct of which she is accused."Source
EFTA00030934.pdf
Quote #1
"Please provide the full names and full birthdays of the individuals identified in the Superseding Indictment as Minor Victims-1-3"Source
EFTA00030934.pdf
Quote #2
"Please identify the dates when Minor Victim-2 allegedly traveled across state lines to and from New Mexico in 1996"Source
EFTA00030934.pdf
Quote #3
"Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New York in 1996"Source
EFTA00030934.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (6,451 characters)
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
December 28, 2020
BY EMAIL
[REDACTED]
[REDACTED]
[REDACTED]
United States Attorney’s Office
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
[REDACTED]
[REDACTED]
United States Attorney’s Office
Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
On behalf of our client, Ghislaine Maxwell, we hereby request that the government file a Bill of Particulars pursuant to Rule 7(f) of the Federal Rules of Criminal Procedure. Please let us know by January 4, 2021 whether it will be necessary to raise any aspect of this request with the Court.
We request clarification of the allegations specified below in order to permit Ms. Maxwell to prepare her defense and avoid unfair surprise at trial. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Superseding Indictment does not sufficiently inform Ms. Maxwell of the specific conduct of which she is accused. Accordingly, we request the following particulars regarding the indicated paragraphs of the Superseding Indictment:
1. Please provide the full names and full birthdays of the individuals identified in the Superseding Indictment as Minor Victims-1-3 (¶¶ 7, 11, 13, 17, 19).
2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-1 (¶ 7a).
3. Please identify the dates when, and locations where, Ms. Maxwell allegedly “groomed” Minor Victim-1 “to engage in sexual acts with Epstein” (¶ 7a).
4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-1 (¶ 7a).
EFTA00030934
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5. Please identify the dates when, and locations where, Ms. Maxwell allegedly “was present for and involved in” Epstein’s sexual abuse of Minor Victim-1 (¶ 7a).
6. Please identify the dates when, and locations where, Minor Victim-1 participated in “group sexualized massages” of Epstein (¶ 7a).
7. Please describe with particularity the conduct that the government contends is a “group sexualized massage” and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7a).
8. Please describe with particularity how Ms. Maxwell allegedly “involved” Minor Victim-1 in these massages and how Ms. Maxwell allegedly participated in these massages (¶ 7a).
9. Please identify the dates when Minor Victim-1 allegedly traveled “across state lines for the purpose of sexual encounters with Epstein” (¶ 7a).
10. Please identify the dates when Ms. Maxwell allegedly enticed Minor Victim-1 “to travel across state lines for the purpose of sexual encounters with Epstein” and describe with particularity the actions that Ms. Maxwell allegedly took to entice Minor Victim-1 to travel (¶ 7a).
11. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-2 (¶ 7b).
12. Please identify the dates when Minor Victim-2 allegedly traveled across state lines to and from New Mexico in 1996 (¶ 7b).
13. Please identify the dates when Ms. Maxwell allegedly “groomed” Minor Victim-2 to engage in “acts of sexual abuse” with Epstein (¶ 7b).
14. Please describe with particularity what Ms. Maxwell allegedly did as part of the “unsolicited massage” of Minor Victim-2 and identify the criminal statute(s) the conduct allegedly violates (¶ 7b, 11c, 17c).
15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-3 (¶ 7c).
16. Please identify the dates when, and locations where, Ms. Maxwell allegedly introduced Minor Victim-3 to Epstein and the dates and locations of their subsequent “multiple interactions” (¶ 7c).
EFTA00030935
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17. Please identify the dates when, and locations where, Ms. Maxwell allegedly “groomed” Minor Victim-3 to engage in sex acts with Epstein (¶ 7c).
18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-3 (¶ 7c).
19. Please describe with particularity the “sex acts” that Minor Victim-3 allegedly engaged in with Epstein during massages and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7c).
20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or foreign commerce to engage in illegal sexual activity with Epstein (¶ 7c).
21. Please specify when the conspiracies charged in Count One and Count Three began and ended. (¶¶ 9, 15).
22. Please identify the “others” who allegedly participated in the conspiracies charged in Count One and Count Three with Epstein and Ms. Maxwell. (¶¶ 9-10, 15-16).
23. Please identify any individuals who were enticed to travel, or were transported, in interstate or foreign commerce to engage in illegal sexual activity with Epstein during the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-3 (¶ 10, 16).
24. Please identify the dates when, and the locations where, Ms. Maxwell participated in “group sexualized encounters” with Jeffrey Epstein and Minor Victim-1 (¶¶ 11a, 17a).
25. Please describe with particularity the conduct that the government believes constitutes a “group sexualized encounter” and identify the criminal statute(s) the conduct violates and the participants in those encounters (¶¶ 11a, 17a).
26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New York in 1996 (¶¶ 11b, 17b).
27. Please identify from whom Ms. Maxwell was allegedly trying to “conceal her crimes” when she allegedly lied under oath in depositions in 2016 (¶ 2).
28. Please identify “the specific events and acts of abuse” about which Ms. Maxwell allegedly “repeatedly provided false and perjurious statements” (¶ 8).
EFTA00030936
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29. As to each statement alleged to be perjurious in Counts Five and Six of the Superseding Indictment please specify why the Government contends the statement was material (¶¶ 21, 23).
Thank you in advance for your prompt response to these requests.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
[REDACTED]
[REDACTED]
[REDACTED]
Christian R. Everdell
COHEN & GRESSER LLP
[REDACTED]
[REDACTED]
[REDACTED]
cc: Mark S. Cohen, Esq.
Jeff Pagliuca, Esq.
Laura Menninger, Esq.
Bobbi C. Sternheim, Esq.
Jeff Pagliuca, Esq.
Laura Menninger, Esq.
Bobbi C. Sternheim, Esq.
EFTA00030937
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