s6 NY RA ANN UDG8.1 AN URT nua4.4 Tit-30 ll DNY YOR5.4 CIT4.9 udge4.5 us10 ng on YOUR5.3 T5 on on doc4.4 HANGE9.9 I ONT10 ON doe4.5 on doc4.5 nd Case Document Page1 of nd ho doc4.5 us10 nge4.5 ng phone4.4 num5.1 il s6 ps10 gi a upda4.5 bus10 ng ho doc4.4 um ng by ng ppe4.5 on on ng on on nd pr45 ny ope4.5 ur45 gna4.4 ns10 ng on know9.7 nd a s6 udge4.5 on TE s6 ng doc4.4 nd on know9.8 ppe4.5 ubm5.1 on know9.7 nd ppe4.5 ons10 on by ona4.5 on ons10 ns10 ons10 bs10 nqui20.3 ng Case Document Page2 of Case Document Filed Page of Case Document Page1 of Criminal Not ice of Appeal Form A NOTICE OF APPEAL United States istric Court District or New Yori Captioo United States Ghislaine Maxwell Docket No Alison Nathan DISlrld Court JIJ Sge Not i ce is hereby i ven that Ghislaine Maxwell appeals to the United States Court of Appeals for the Second Circuit from the judgmen other I Ordat DMy,no Defe Mo bon lof on Ba entered i th i action on epeclfy date This appeal conoerns Conviction only I_ Sentence only LJ Conviction Sentence I_ Other I Defendant found gu il ty by plea I I trial I NIA I Offense occurred after November Yes No I NIA Date of sentence __ NIA I Ba il Jail Dispos i tion Committed Not comm i tted I I NIAi Appellent is represented by counsel Yes I No I If yes provide the following i nformetion Defendants Counsel Christian Everdell Counsels Address Cohen Gresser LLP Third Avenue New Yor1 NY Coonse Phone Assistant Allomey Maurene Corney AUSA Address St Andrews Plaza New York NY AUSA Phone US-3 DC DN-8 DO-4 CUME-4 NT ELEC4 TR4 ON4 C4 A4 LLY4 F4 LED DO-4 DAT-4 FI-8 January S?AkA?I BZ?eh??1?Vf PG 4?Gd I?W ю?Ú I g?y?c y?dо p??ք jəID z?So_ c?L?W V??b j??mϴw w??D?Ӑx?z?q??Β aFY c?ݖ?!DT??A z?4?Ԩd?lw?b 2JO ܐnjv?5G?3 T??k kSʘ?Z?MW?٠ F-q _?Vi X?0?WD?F(H Ukj Wȫ p??R ҕ??ky i?2ddMx??ټ Óg NHw t?Mճ 6?䀍tc?vD?Gl?K?z??ԝ?b w??cl Rso?u A y?O ml А?d?nt t??ln N?i a?W vypwLC?x8J SO a5Gx?j Ԝ9e N?h 0D?C a K?-g?Uy ThqtQ Б??R ap ƙ?i R?c?F 8?Oܨ?M I?7JbCwT I W?ǃ??X tf A?t oe?ᅴ??C l?w Ud ixŁ oax nţh L?oʉ?p z?iyZ?n HƔZƌ ښx??B GGL?m Q?o??j pns 1R J?s2 cV?6 RB vU H?x?D e?r M2 va?t hi t,X??z a q?p?憫v 6?Bh"o i ȔԌX?q9?n t?P D?A ф??Aӕ m?H Pj ECF,INTAPP U.S District Court Southern District of New York Foley Square Case Document Page2 of CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS 1s COERCION OR ENTICEMENT OFA MINOT TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS COERCION OR ENTICEMENT OF MINOR TO ENGAGE IN ILLEGAL SEX ACTS 2s CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 3s COERCION OR ENTICEMENT OF MINOR FEMALE TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 4s FALSE DECLARATIONS BEFORE GRAND JURY/COURT PERJURY FALSE DECLARATIONS BEFORE GRAND JURY/COURT Highest Offense Level Opening Felony Terminated Counts Disposition None Case Document Page3 of Highest Offense Level Terminated None Complaints Disposition None Plaintiff USA represented by Alex Rossmiller U.S Attorneys Office Southern District of New York St Andrews Plaza New York NY Email alexander.rossmiller usdoj.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED Designation Assistant US Attorney Alison Gainfort Moe United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email alison.moe usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Maurene Ryan Comey United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email maurene.comey usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Andrew Rohrbach DOJ-USAO St Andrews Plaza New York NY Email Andrew.Rohrbach usdoj.gov ATTORNEY TO BE NOTICED Lara Elizabeth Pomerantz United States Attorneys Office One St Andrews Plaza New York NY Fax Email Lara.Pomerantz usdoj.gov ATTORNEY TO BE NOTICED Date Filed Docket Text Case Document Page4 of SEALED INDICTMENT as to Sealed Defendant count jm Main Document replaced on jm Entered Order to Unseal Indictment as to Sealed Defendant Signed by Magistrate Judge Katharine Parker on jm Entered INDICTMENT UNSEALED as to Ghislaine Maxwell jm Entered Case Designated ECF as to Ghislaine Maxwell jm Entered Case as to Ghislaine Maxwell ASSIGNED to Judge Alison Nathan jm Entered Attorney update in case as to Ghislaine Maxwell Attorney Alex Rossmiller,Maurene Ryan Comey,Alison Gainfort Moe for USA added jm Entered MOTION to detain defendant Document filed by USA as to Ghislaine Maxwell Moe Alison Entered Arrest of Ghislaine Maxwell in the United States District Court District of New Hampshire jm Entered Case Document Page5 of advance of the proceeding by subsequent order Given the high degree of public interest in this case a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse Pearl Street New York NY Due to social distancing requirements seating will be extremely limited when capacity is reached no additional persons will be admitted Per the S.D.N.Y COVID-19 Courthouse Entry Program anyone who appears at any S.D.N.Y courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse All visitors must also have their temperature taken when they arrive at the courthouse Please see the instructions attached Completing the questionnaire ahead of time will save time and effort upon entry Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below degrees will be allowed to enter the courthouse Face coverings that cover the nose and mouth must be worn at all times Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse There are no exceptions As discussed in the Courts previous order defense counsel shall if possible discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding See Dkt No If the Defendant consents and is able to sign the form either personally or in accordance with Standing Order of March by defense counsel defense counsel shall file the executed form at least hours prior to the proceeding In the event the Defendant consents but counsel is unable to obtain or affix the Defendants signature on the form the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendants signature to the form Pursuant to U.S.C the Government must make their best efforts to see that crime victims are notified of and accorded the rights provided to them in that section This includes the right to reasonable accurate and timely notice of any public court proceeding involving the crime or of any release of the accused and the right to be reasonably heard at any public proceeding in the district court involving release Id a The Court will inquire with the Government as to the extent of those efforts So that appropriate logistical arrangements can be made the Government shall inform the Court by email within hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial Finally the time between the Defendants arrest and July is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district See U.S.C And the Court further excludes time under the Speedy Trial Act from today through July Due to the logistical issues involved in conducting a remote proceeding the Court finds that the ends of justice served by this exclusion outweigh the best interest of the public and the defendant in a speedy trial U.S.C A The exclusion is also supported by the need for the parties to discuss a potential protective order which will facilitate the timely production of discovery in a manner protective of the rights of third parties See Dkt No SO ORDERED Signed by Judge Alison Nathan on jbo Entered Case Document Page6 of MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff Document filed by Ghislaine Maxwell Attachments Exhibit Declaration of Jeffrey Pagliuca Exhibit Certificate of Good Standing Text of Proposed Order Proposed Order Pagliuca Jeffrey Entered S1 SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell count 1s 2s 3s 4s jm Entered NOTICE REGARDING PRO HAC VICE MOTION Regarding Document No MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff The document has been reviewed and there are no deficiencies aea Entered ORDER as to Ghislaine Maxwell As discussed in its previous order the Court will hold an arraignment initial conference and bail hearing in this matter remotely as a video/teleconference on July at pm Members of the press and the public in the United States may access the live audio feed of the proceeding by calling and using access code and PIN Those outside of the United States may access the live audio feed by calling and using the same access code and PIN These phone lines can accommodate approximately callers on a first come first serve basis The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel alleged victims and any family members of the Defendant The United States Attorneys Office should email Chambers with information regarding any alleged victims who are entitled pursuant to U.S.C a to be heard at the bail hearing and who wish to be heard The Court will then provide information as to the logistics for their dial-in access As the Court described in a previous order members of the press and public may watch and listen to the live video feed in the Jury Assembly Room at the Daniel Patrick Moynihan Courthouse Pearl Street See Dkt No However in light of COVID-19 seating will be limited to approximately seats in order to enable appropriate social distancing and ensure public safety Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant Members of the credentialed in-house press corps may contact the District Executives Office about seating Otherwise all seating will be allocated on a first come first serve basis and in accordance with the S.D.N.Y COVID-19 Courthouse Entry Program and this Courts previous order of July See Dkt No If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health the Court may provide audio access by telephone only Any photographing recording or rebroadcasting of federal court proceedings is prohibited by law Violation of these prohibitions may result in fines or sanctions including removal of court issued media credentials restricted entry to future hearings denial of entry to future hearings or any other sanctions deemed necessary by the Court SO ORDERED Signed by Judge Alison Nathan on jbo Entered MEMORANDUM in Opposition by Ghislaine Maxwell re MOTION to detain defendant Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Mark Stewart Cohen appearing for Ghislaine Maxwell Appearance Type Retained Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Christian Everdell appearing for Ghislaine Maxwell Appearance Type Retained Everdell Christian Entered WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by Ghislaine Maxwell Everdell Christian Entered REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re MOTION to detain defendant Moe Alison Entered ORDER granting Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to Ghislaine Maxwell Signed by Judge Alison Nathan on kwi Case Document Page7 of Entered ORDER as to Ghislaine Maxwell For the reasons stated on the record at todays proceeding the Governments motion to detain the Defendant pending trial is hereby GRANTED Signed by Judge Alison Nathan on jw Entered Minute Entry for proceedings held before Judge Alison Nathan:Arraignment as to Ghislaine Maxwell Count held on Defendant Ghislaine Maxwell present by video conference with attorney Mark Cohen present by video conference AUSA Alison Moe Alex Rossmiller and Maurene Comey for the government present by video conference Pretrial Service Officer Lea Harmon present by telephone and Court Reporter Kristine Caraannante Defendant enters a plea of Not Guilty to the S1 indictment Trial set for July See Order Time is excluded under the Speedy Trial Act from today until July Bail is denied Defendant is remanded See Transcript jw Entered Minute Entry for proceedings held before Judge Alison Nathan Plea entered by Ghislaine Maxwell Count Not Guilty jw Entered Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re Arraignment Bail Hearing Conference jw Entered ORDER as to Ghislaine Maxwell Initial non-electronic discovery generally to include search warrant applications and subpoena returns is due by Friday August Completion of discovery to include electronic materials is due by Monday November Motions are due by Monday December Motion responses are due by Friday January Motion replies are due by Friday February Trial is set for Monday July Discovery due by Motions due by Signed by Judge Alison Nathan on jw Entered ORDER as to Ghislaine Maxwell The Court has received a significant number of letters and messages from non-parties that purport to be related to this case These submissions are either procedurally improper or irrelevant to the judicial function Therefore they will not be considered or docketed The Court will accord the same treatment to any similar correspondence it receives in the future SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page8 of Entered Case Document Page9 of this case These individuals still maintain a significant privacy interest that must be safeguarded The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also allows the Defense to reference the identities of individuals they believe may be relevant to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial Dkt No This proposal adequately balances the interests at stake And as the Governments letter notes see Dkt No at to the extent that the Defense needs an exception to the protective order for a specific investigative purpose they can make applications to the Court on a case-by-case basis Second restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation The Government labors under many restrictions including Rule of the Federal Rules of Criminal Procedure the Privacy Act of and other policies of the Department of Justice and the U.S Attorneys Office for the Southern District of New York all of which the Court expects the Government to scrupulously follow Furthermore the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession See Dkt No at And of course those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government Nothing in the Defenses papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial For the foregoing reasons the Court adopts the Governments proposed protective order which will be entered on the docket This resolves Dkt No SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page10 of parties shall propose redactions to the letter briefing on this issue Alternatively the parties shall provide support and argument for why the letter motions should be sealed in their entirety SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for USA Pomerantz Lara Entered SEALED DOCUMENT placed in vault mhe Entered Case Document Page11 of Case Document Page12 of Case Document Page13 of temporarily sealed while the Court resolves the redaction request SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page14 of Case Document Page15 of necessary steps to ensure that the Defendant continues to receive adequate access to her legal materials and her ability to communicate with defense counsel Signed by Judge Alison Nathan on ap Entered TRANSCRIPT of Proceedings as to Ghislaine Maxwell re Conference held on before Judge Alison Nathan Court Reporter/Transcriber Kristen Carannante Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction After that date it may be obtained through PACER Redaction Request due Redacted Transcript Deadline set for Release of Transcript Restriction set for McGuirk Kelly Entered NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell Notice is hereby given that an official transcript of a Conference proceeding held on has been filed by the court reporter/transcriber in the above-captioned matter The parties have seven calendar days to file with the court a Notice of Intent to Request Redaction of this transcript If no such Notice is filed the transcript may be made remotely electronically available to the public without redaction after calendar days McGuirk Kelly Entered ORDER as to Ghislaine Maxwell On December Defendant Ghislaine Maxwell filed her renewed application for bail under seal with proposed redactions in accordance with this Courts December Order see Dkt No The Government did not file any opposition to the Defendants proposed redactions After due consideration the Court will adopt the Defendants proposed redactions The Courts decision to adopt those redactions is guided by the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo F.3d 2d Amodeo II The proposed redactions satisfy this test The Court finds that Defendants letter motions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless in balancing competing considerations against the presumption of access the Court finds that the redactions are narrowly tailored to properly guard the privacy interests of the individuals referenced in the Defendants submission and in the corresponding exhibits The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits Signed by Judge Alison Nathan on ap Entered Case Document Page16 of those materials The Defendant did not file any opposition to the Governments proposed redactions The Court will adopt the Governments proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Governments submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless the proposed redactions are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d The Government is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December Signed by Judge Alison Nathan on ap Entered MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed Bail Motion Attachments Exhibit A Exhibit Comey Maurene Entered ORDER as to Ghislaine Maxwell On December the Defendant filed her reply to the Governments opposition to her renewed application for bail In accordance with this Courts December Order see Dkt No she filed these materials under seal and proposed narrowly tailored redactions on those materials The Government did not file any opposition to the Defendants proposed redactions The Court will adopt the Defendants proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Defendants submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S As with the redactions to her renewed motion for bail the proposed redactions here are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d S.D.N.Y See also Dkt No The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page17 of motion In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket the Court will permit the parties hours to propose any redactions to the Courts Opinion and Order and to justify those redactions by reference tothe Second Circuits decision in Lugosch Pyramid Co of Onondaga F.3d 2d Cir After determining which if any portions of the Opinion and Order should be redacted the Court will file the Opinion and Order on the public docket As a result the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pretrial detention continues to be warranted On or before December the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal This resolves Dkt No Signed by Judge Alison Nathan on jw Entered Case Document Page18 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were ransmitted to the U.S Court of Appeals nd Entered Case Document Page19 of I I A IJ LLJ NH 5!NQ7R6S T6 IJIJ V5 WXH U!C:Q IJJ_OH V65H 3!NQDZ IJIJ?!5C49 T6 QD7 C6 H,H IM;O G4DD C!Y6 6bQ4 Hc Case Document Filed Page of Case Document Page1 of DOCUMENT EU:Cf:RONICALLY FILED I C6 C8 C6 QYY C6 YYD T6 C6 C8 C6 RC5 VH C6 QT9 C6 C6 C8 C6 T8 C6 C6 R8 C8 TD C6 YY6 Q5 C4 C8 Q9 C6 C6 C6 C8 R6 C6 RC5 C6 A4 R8 C6 C6 C4 C8 C6 C6 Q9 C6 C8 C6 QD H,H IMROH C6 A6 C8 C6 C6 C6 C6 C8 C6 C6 H,H IM6 OH C6 C8 C6 QD TD C6 YY6 Q5 QD C6 C8 C6 A6 C8 TQ Q8 C8 C6 RC5 C8 T6 7H T6 T6 LJ?!IJIJ?!5 C6 Y8 QT 3R!G C6 C6 C6 Z!Y 3Z C6 Q9 C!Y C4 A6 V5 WX 7S T6 IU IJIJ Q7R6 Case Document Filed Page of Case Document Page2 of s6 RA ANN UDG8.1 AN URT Tit-30 ll DNY YOR5.4 CIT4.9 udge4.5 Case Document Page1 of CA02db Intake From NYSD_ECF_Pool nysd.uscourts.gov Sent Tuesday January AM To NYSD CourtMail Subject Case Document Page1 of Alison Gainfo-7.9rt Moe alison.moe usdoj.gov CaseV5.5i1ew.ECF usdoj.gov USAN-5.4YS.ECF Alex Rossmiller ale-4.3x2.3ander.rossmiller usdoj.gov CaseView.ECF usdoj.gov USDOJ.GO-4.4V Maurene Ryan Comey usdoj.gov CaseView.EC-7.1F1.2 usdoj.gov USDOJ.GO-4.4V Andrew Rohr-7.1bach 1.5usdoj.gov caseview.ecf-5.9 usdoj.gov usanys.ecf 6.9u1.5sdoj.gov cr AJN Notice has b-5.1een delivered by means to Case Document Page2 of ECF,INTAPP U.S District Court Southern District of New York Foley Square Case Document Page3 of CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS 1s COERCION OR ENTICEMENT OFA MINOT TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS COERCION OR ENTICEMENT OF MINOR TO ENGAGE IN ILLEGAL SEX ACTS 2s CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 3s COERCION OR ENTICEMENT OF MINOR FEMALE TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 4s FALSE DECLARATIONS BEFORE GRAND JURY/COURT PERJURY FALSE DECLARATIONS BEFORE GRAND JURY/COURT Highest Offense Level Opening Felony Terminated Counts Disposition None Case Document Page4 of Highest Offense Level Terminated None Complaints Disposition None Plaintiff USA represented by Alex Rossmiller U.S Attorneys Office Southern District of New York St Andrews Plaza New York NY Email alexander.rossmiller usdoj.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED Designation Assistant US Attorney Alison Gainfort Moe United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email alison.moe usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Maurene Ryan Comey United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email maurene.comey usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Andrew Rohrbach DOJ-USAO St Andrews Plaza New York NY Email Andrew.Rohrbach usdoj.gov ATTORNEY TO BE NOTICED Lara Elizabeth Pomerantz United States Attorneys Office One St Andrews Plaza New York NY Fax Email Lara.Pomerantz usdoj.gov ATTORNEY TO BE NOTICED Date Filed Docket Text Case Document Page5 of SEALED INDICTMENT as to Sealed Defendant count jm Main Document replaced on jm Entered Order to Unseal Indictment as to Sealed Defendant Signed by Magistrate Judge Katharine Parker on jm Entered INDICTMENT UNSEALED as to Ghislaine Maxwell jm Entered Case Designated ECF as to Ghislaine Maxwell jm Entered Case as to Ghislaine Maxwell ASSIGNED to Judge Alison Nathan jm Entered Attorney update in case as to Ghislaine Maxwell Attorney Alex Rossmiller,Maurene Ryan Comey,Alison Gainfort Moe for USA added jm Entered MOTION to detain defendant Document filed by USA as to Ghislaine Maxwell Moe Alison Entered Arrest of Ghislaine Maxwell in the United States District Court District of New Hampshire jm Entered Case Document Page6 of advance of the proceeding by subsequent order Given the high degree of public interest in this case a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse Pearl Street New York NY Due to social distancing requirements seating will be extremely limited when capacity is reached no additional persons will be admitted Per the S.D.N.Y COVID-19 Courthouse Entry Program anyone who appears at any S.D.N.Y courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse All visitors must also have their temperature taken when they arrive at the courthouse Please see the instructions attached Completing the questionnaire ahead of time will save time and effort upon entry Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below degrees will be allowed to enter the courthouse Face coverings that cover the nose and mouth must be worn at all times Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse There are no exceptions As discussed in the Courts previous order defense counsel shall if possible discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding See Dkt No If the Defendant consents and is able to sign the form either personally or in accordance with Standing Order of March by defense counsel defense counsel shall file the executed form at least hours prior to the proceeding In the event the Defendant consents but counsel is unable to obtain or affix the Defendants signature on the form the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendants signature to the form Pursuant to U.S.C the Government must make their best efforts to see that crime victims are notified of and accorded the rights provided to them in that section This includes the right to reasonable accurate and timely notice of any public court proceeding involving the crime or of any release of the accused and the right to be reasonably heard at any public proceeding in the district court involving release Id a The Court will inquire with the Government as to the extent of those efforts So that appropriate logistical arrangements can be made the Government shall inform the Court by email within hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial Finally the time between the Defendants arrest and July is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district See U.S.C And the Court further excludes time under the Speedy Trial Act from today through July Due to the logistical issues involved in conducting a remote proceeding the Court finds that the ends of justice served by this exclusion outweigh the best interest of the public and the defendant in a speedy trial U.S.C A The exclusion is also supported by the need for the parties to discuss a potential protective order which will facilitate the timely production of discovery in a manner protective of the rights of third parties See Dkt No SO ORDERED Signed by Judge Alison Nathan on jbo Entered Case Document Page7 of MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff Document filed by Ghislaine Maxwell Attachments Exhibit Declaration of Jeffrey Pagliuca Exhibit Certificate of Good Standing Text of Proposed Order Proposed Order Pagliuca Jeffrey Entered S1 SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell count 1s 2s 3s 4s jm Entered NOTICE REGARDING PRO HAC VICE MOTION Regarding Document No MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff The document has been reviewed and there are no deficiencies aea Entered ORDER as to Ghislaine Maxwell As discussed in its previous order the Court will hold an arraignment initial conference and bail hearing in this matter remotely as a video/teleconference on July at pm Members of the press and the public in the United States may access the live audio feed of the proceeding by calling and using access code and PIN Those outside of the United States may access the live audio feed by calling and using the same access code and PIN These phone lines can accommodate approximately callers on a first come first serve basis The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel alleged victims and any family members of the Defendant The United States Attorneys Office should email Chambers with information regarding any alleged victims who are entitled pursuant to U.S.C a to be heard at the bail hearing and who wish to be heard The Court will then provide information as to the logistics for their dial-in access As the Court described in a previous order members of the press and public may watch and listen to the live video feed in the Jury Assembly Room at the Daniel Patrick Moynihan Courthouse Pearl Street See Dkt No However in light of COVID-19 seating will be limited to approximately seats in order to enable appropriate social distancing and ensure public safety Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant Members of the credentialed in-house press corps may contact the District Executives Office about seating Otherwise all seating will be allocated on a first come first serve basis and in accordance with the S.D.N.Y COVID-19 Courthouse Entry Program and this Courts previous order of July See Dkt No If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health the Court may provide audio access by telephone only Any photographing recording or rebroadcasting of federal court proceedings is prohibited by law Violation of these prohibitions may result in fines or sanctions including removal of court issued media credentials restricted entry to future hearings denial of entry to future hearings or any other sanctions deemed necessary by the Court SO ORDERED Signed by Judge Alison Nathan on jbo Entered MEMORANDUM in Opposition by Ghislaine Maxwell re MOTION to detain defendant Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Mark Stewart Cohen appearing for Ghislaine Maxwell Appearance Type Retained Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Christian Everdell appearing for Ghislaine Maxwell Appearance Type Retained Everdell Christian Entered WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by Ghislaine Maxwell Everdell Christian Entered REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re MOTION to detain defendant Moe Alison Entered ORDER granting Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to Ghislaine Maxwell Signed by Judge Alison Nathan on kwi Case Document Page8 of Entered ORDER as to Ghislaine Maxwell For the reasons stated on the record at todays proceeding the Governments motion to detain the Defendant pending trial is hereby GRANTED Signed by Judge Alison Nathan on jw Entered Minute Entry for proceedings held before Judge Alison Nathan:Arraignment as to Ghislaine Maxwell Count held on Defendant Ghislaine Maxwell present by video conference with attorney Mark Cohen present by video conference AUSA Alison Moe Alex Rossmiller and Maurene Comey for the government present by video conference Pretrial Service Officer Lea Harmon present by telephone and Court Reporter Kristine Caraannante Defendant enters a plea of Not Guilty to the S1 indictment Trial set for July See Order Time is excluded under the Speedy Trial Act from today until July Bail is denied Defendant is remanded See Transcript jw Entered Minute Entry for proceedings held before Judge Alison Nathan Plea entered by Ghislaine Maxwell Count Not Guilty jw Entered Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re Arraignment Bail Hearing Conference jw Entered ORDER as to Ghislaine Maxwell Initial non-electronic discovery generally to include search warrant applications and subpoena returns is due by Friday August Completion of discovery to include electronic materials is due by Monday November Motions are due by Monday December Motion responses are due by Friday January Motion replies are due by Friday February Trial is set for Monday July Discovery due by Motions due by Signed by Judge Alison Nathan on jw Entered ORDER as to Ghislaine Maxwell The Court has received a significant number of letters and messages from non-parties that purport to be related to this case These submissions are either procedurally improper or irrelevant to the judicial function Therefore they will not be considered or docketed The Court will accord the same treatment to any similar correspondence it receives in the future SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page9 of Entered Case Document Page10 of this case These individuals still maintain a significant privacy interest that must be safeguarded The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also allows the Defense to reference the identities of individuals they believe may be relevant to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial Dkt No This proposal adequately balances the interests at stake And as the Governments letter notes see Dkt No at to the extent that the Defense needs an exception to the protective order for a specific investigative purpose they can make applications to the Court on a case-by-case basis Second restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation The Government labors under many restrictions including Rule of the Federal Rules of Criminal Procedure the Privacy Act of and other policies of the Department of Justice and the U.S Attorneys Office for the Southern District of New York all of which the Court expects the Government to scrupulously follow Furthermore the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession See Dkt No at And of course those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government Nothing in the Defenses papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial For the foregoing reasons the Court adopts the Governments proposed protective order which will be entered on the docket This resolves Dkt No SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page11 of parties shall propose redactions to the letter briefing on this issue Alternatively the parties shall provide support and argument for why the letter motions should be sealed in their entirety SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for USA Pomerantz Lara Entered SEALED DOCUMENT placed in vault mhe Entered Case Document Page12 of Case Document Page13 of Case Document Page14 of temporarily sealed while the Court resolves the redaction request SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page15 of Case Document Page16 of necessary steps to ensure that the Defendant continues to receive adequate access to her legal materials and her ability to communicate with defense counsel Signed by Judge Alison Nathan on ap Entered TRANSCRIPT of Proceedings as to Ghislaine Maxwell re Conference held on before Judge Alison Nathan Court Reporter/Transcriber Kristen Carannante Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction After that date it may be obtained through PACER Redaction Request due Redacted Transcript Deadline set for Release of Transcript Restriction set for McGuirk Kelly Entered NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell Notice is hereby given that an official transcript of a Conference proceeding held on has been filed by the court reporter/transcriber in the above-captioned matter The parties have seven calendar days to file with the court a Notice of Intent to Request Redaction of this transcript If no such Notice is filed the transcript may be made remotely electronically available to the public without redaction after calendar days McGuirk Kelly Entered ORDER as to Ghislaine Maxwell On December Defendant Ghislaine Maxwell filed her renewed application for bail under seal with proposed redactions in accordance with this Courts December Order see Dkt No The Government did not file any opposition to the Defendants proposed redactions After due consideration the Court will adopt the Defendants proposed redactions The Courts decision to adopt those redactions is guided by the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo F.3d 2d Amodeo II The proposed redactions satisfy this test The Court finds that Defendants letter motions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless in balancing competing considerations against the presumption of access the Court finds that the redactions are narrowly tailored to properly guard the privacy interests of the individuals referenced in the Defendants submission and in the corresponding exhibits The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits Signed by Judge Alison Nathan on ap Entered Case Document Page17 of those materials The Defendant did not file any opposition to the Governments proposed redactions The Court will adopt the Governments proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Governments submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless the proposed redactions are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d The Government is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December Signed by Judge Alison Nathan on ap Entered MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed Bail Motion Attachments Exhibit A Exhibit Comey Maurene Entered ORDER as to Ghislaine Maxwell On December the Defendant filed her reply to the Governments opposition to her renewed application for bail In accordance with this Courts December Order see Dkt No she filed these materials under seal and proposed narrowly tailored redactions on those materials The Government did not file any opposition to the Defendants proposed redactions The Court will adopt the Defendants proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Defendants submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S As with the redactions to her renewed motion for bail the proposed redactions here are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d S.D.N.Y See also Dkt No The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page18 of motion In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket the Court will permit the parties hours to propose any redactions to the Courts Opinion and Order and to justify those redactions by reference tothe Second Circuits decision in Lugosch Pyramid Co of Onondaga F.3d 2d Cir After determining which if any portions of the Opinion and Order should be redacted the Court will file the Opinion and Order on the public docket As a result the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pretrial detention continues to be warranted On or before December the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal This resolves Dkt No Signed by Judge Alison Nathan on jw Entered Case Document Page19 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were ransmitted to the U.S Court of Appeals nd Entered Case Document Page20 of I I CE APPEARAN-17.4 CE EL t6 Subs22.5 onal36.1 ouns16.2 on as foll20.4 i6 r6 r6 l6 il or t6 i6 t6 l6 r6 l6 i6 l6 l6 t6 i6 t6 l6 r6 l6 i6 t6 r6 l6 i6 i6 s6 r6 f6 I rtify newed I i6 t6 r6 f6 l6 r6 r6 i6 t6 Case Document Page1 of CE APPEARAN-17.4 CE EL t6 Subs22.5 onal36.1 ouns16.2 on as foll20.4 i6 r6 r6 l6 il or t6 i6 t6 l6 r6 l6 i6 l6 l6 t6 i6 t6 l6 r6 l6 i6 t6 r6 l6 i6 i6 s6 r6 f6 I rtify newed I i6 t6 r6 f6 l6 r6 r6 i6 t6 Case Document Page1 of ICE BSTITU-9 TE ITIONAL AMICU-14.2 NSEL Short-11.6 Title-11.3 __ Docke-12.1 No __ tit-11 Additional-11.2 or Amic-9.9 ontac-14.5 Inform-12.1 ation is as Firm Addre-12.8 ss leph-9.8 ax mail earance for sign-8.3 ation-11.6 Selec-13.8 ne Substitut-5.7 ounse-6.3 placin-13.4 ad ounse-11.8 firm Substitut-5.7 ounse-6.3 placin-13.4 ounse-6.3 firm Addition-6.5 al coun-12 sel ounse-11.7 with firm Amicus in supp-9.8 ort of sign-8.3 ation-11.6 TIFICAT-9.6 ION I rtify I am dmitt-9.8 ed to in his Court-9.4 if quire-12.4 by rim Rule a have-11 my mission OR I lied for dmission on ature-9.4 of Counse-13.6 or MAXWELL Bobbi Sternheim Esq Law fices of Bobbi Sternheim est 19th Street 4th Floor54.7 New ork bc sternheimlaw54.5 com ecf sternheimlaw54.5 com bcsternheim mac.com Appellant Ghislaine Maxwell Christian Everdell Esq Cohen Gresser54.7 LLP Bobbi Sternheim Esq Case Document Page1 of Case Document Page1 of ACKNOWLEDGMENT AND NOTICE OF APPEARANCE Short Title USA MAXWELL Docket No Lead Counsel of Record nam.e/firm or Pro Party na1ne _C_h_ri_st_ia_n_R_ _E_v_e_rd_e_ll _E_sq Cohen Gresser LLP Appearanc for party es ignation _A s6 NY UDG8.1 AN URT nua4.4 DNY YOR5.4 CIT4.9 udge4.5 re ns10 how9.8 __ __ ng __ ng ng on __ ng Case Document Page1 of __ __ __ nd doc4.5 no a A ec by bove4.4 doc4.5 ng il s6 nqui20.3 ng Case Document Page2 of UNI-4 CO2 URT9 O2 O2 HE11 CO2 ND CI-4 RC13 UI-4 CRI-4 M4 NA13 AL TR-9 S3 C5 R5 IP3 IN17 IO20 FO7 R4 TO BE CA27 N2 DO3 CKE12 N2 M6 B2 ER2 C2 O5 U2 N2 EL11 N2 C2 O5 U2 N2 EL11 D2 D2 C2 O5 U2 N2 EL11 PH2 QU-3 S9 am rd-4 s7 ri-5 p9 am not rd9 ri-5 n9 ra-4 n9 ri9 Re-6 s5 Da-6 co16 p3 av11 ai-1 ab13 At11 y6 pl-1 ed or17 der Ot-7 c7 ex24 pl13 na13 TR4 N4 S3 C4 IP16 OR-3 Pre-4 re-4 ra-4 n9 of Pre-4 ri-5 l9 ro9 e9 g9 D2 ri9 i9 D2 ri-5 D2 ri9 i9 D2 Se-4 n9 n9 D2 ri9 i9 D2 Po-4 ri9 ro-4 c7 d9 g9 D2 ri9 i9 D2 I her17 eby r6 i2 th11 I ma16 ke o9 ry9 rra-4 e9 e9 s7 l9 nam-3 th-2 co3 u3 re-4 rt-2 fo-2 pay11 ent of2 t2 he t5 f5 in c7 rd-4 n9 FR4 A3 of pay11 ent2 Fu1 n1 CJ-9 A Fo-2 Co-6 e7 Si8 Da-6 TO BE G3 D2 rd9 Es-7 m6 e9 Nu-6 m4 of2 age13 Es-7 m6 e9 p3 t5 dat2 C2 rt-2 R2 e9 rt-2 s7 Si-5 n9 Da-6 r2 U2 C2 r2 C2 r2 e9 a9 s9 U2 tt13 O5 fi11 c9 C2 e9 r2 te9 r2 C2 r2 te-4 Se-4 m9 e9 C2 r2 s9 C2 r2 Maxwell Christian Everdell Esq Cohen Gresser54.7 LLP Third venue New ork Case Document Page1 of 1E I I Case Document Page2 of s6 NY RA ANN UDG8.1 AN URT DNY YOR5.4 CIT4.9 udge4.5 us10 ng on RE5 A on on doc4.4 HANGE9.9 ONT9.9 ON doe4.5 on doc4.5 nd Case Document Page1 of nd ho doc4.5 us10 nge4.5 ng phone4.4 num5.1 il s6 ps10 gi a upda4.5 bus10 ng ho doc4.4 ng by ng ppe4.5 on on ng on on nd pr45 ny ope4.5 ur45 gna4.4 ns10 ng on know9.7 nd a s6 udge4.5 on TE titio-20.1 ng doc4.4 nd on know9.8 ppe4.5 ubm5.1 on know9.7 nd ppe4.5 ons10 s6 on by ona4.5 on ons10 ns10 ons10 bs10 nqui20.3 ng Case Document Page2 of ce al A AL rt __ ptio12 cket ct tice is he12 en hat appea13.3 ls he nite12 tat12 es eals th12 econd Cir17 cuit ju12 dgment15 __ fy in this actio12 on __ his ictio11.3 __ nce nly18 __ ictio11.3 nce ther16.3 __ ant ilty22 ple12 a ial __ ffe12 nse ccurr15.3 ed fte12 ov16 ember14 es __ __ te of nce A isposit14 ommitt13.3 ed co12 mmitte13.3 A ellan12 sel es If es ide the foll11.3 ing info12 rmat13.3 ion ant ounsel12.656 unsel unsel Assist13.667 ant tto12 SA14 2s SA14 2s hone re Case Document Filed Page of Case Document Page1 of SDC SONY LY IL I APPEAL,ECF,INTAPP U.S District Court Southern District of New York Foley Square Case Document Page2 of ATTORNEY TO BE NOTICED Pending Counts Disposition CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS 1s COERCION OR ENTICEMENT OFA MINOT TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS COERCION OR ENTICEMENT OF MINOR TO ENGAGE IN ILLEGAL SEX ACTS 2s CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 3s COERCION OR ENTICEMENT OF MINOR FEMALE TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 4s FALSE DECLARATIONS BEFORE GRAND JURY/COURT PERJURY FALSE DECLARATIONS BEFORE GRAND JURY/COURT Highest Offense Level Opening Felony Case Document Page3 of Terminated Counts Disposition None Highest Offense Level Terminated None Complaints Disposition None Plaintiff USA represented by Alex Rossmiller U.S Attorneys Office Southern District of New York St Andrews Plaza New York NY Email alexander.rossmiller usdoj.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED Designation Assistant US Attorney Alison Gainfort Moe United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email alison.moe usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Maurene Ryan Comey United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email maurene.comey usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Andrew Rohrbach DOJ-USAO St Andrews Plaza New York NY Email Andrew.Rohrbach usdoj.gov ATTORNEY TO BE NOTICED Lara Elizabeth Pomerantz United States Attorneys Office One St Andrews Plaza New York NY Fax Email Lara.Pomerantz usdoj.gov ATTORNEY TO BE NOTICED Case Document Page4 of Date Filed Docket Text SEALED INDICTMENT as to Sealed Defendant count jm Main Document replaced on jm Entered Order to Unseal Indictment as to Sealed Defendant Signed by Magistrate Judge Katharine Parker on jm Entered INDICTMENT UNSEALED as to Ghislaine Maxwell jm Entered Case Designated ECF as to Ghislaine Maxwell jm Entered Case as to Ghislaine Maxwell ASSIGNED to Judge Alison Nathan jm Entered Attorney update in case as to Ghislaine Maxwell Attorney Alex Rossmiller,Maurene Ryan Comey,Alison Gainfort Moe for USA added jm Entered MOTION to detain defendant Document filed by USA as to Ghislaine Maxwell Moe Alison Entered Arrest of Ghislaine Maxwell in the United States District Court District of New Hampshire jm Entered Case Document Page5 of capacity of the internet platform system only one attorney per party may participate by video Co-counsel members of the press and the public may access the audio feed of the proceeding by calling a dial-in number which the Court will provide in advance of the proceeding by subsequent order Given the high degree of public interest in this case a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse Pearl Street New York NY Due to social distancing requirements seating will be extremely limited when capacity is reached no additional persons will be admitted Per the S.D.N.Y COVID-19 Courthouse Entry Program anyone who appears at any S.D.N.Y courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse All visitors must also have their temperature taken when they arrive at the courthouse Please see the instructions attached Completing the questionnaire ahead of time will save time and effort upon entry Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below degrees will be allowed to enter the courthouse Face coverings that cover the nose and mouth must be worn at all times Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse There are no exceptions As discussed in the Courts previous order defense counsel shall if possible discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding See Dkt No If the Defendant consents and is able to sign the form either personally or in accordance with Standing Order of March by defense counsel defense counsel shall file the executed form at least hours prior to the proceeding In the event the Defendant consents but counsel is unable to obtain or affix the Defendants signature on the form the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendants signature to the form Pursuant to U.S.C the Government must make their best efforts to see that crime victims are notified of and accorded the rights provided to them in that section This includes the right to reasonable accurate and timely notice of any public court proceeding involving the crime or of any release of the accused and the right to be reasonably heard at any public proceeding in the district court involving release Id a The Court will inquire with the Government as to the extent of those efforts So that appropriate logistical arrangements can be made the Government shall inform the Court by email within hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial Finally the time between the Defendants arrest and July is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district See U.S.C And the Court further excludes time under the Speedy Trial Act from today through July Due to the logistical issues involved in conducting a remote proceeding the Court finds that the ends of justice served by this exclusion outweigh the best interest of the public and the defendant in a speedy trial U.S.C A The exclusion is also supported by the need for the parties to discuss a potential protective order which will facilitate the timely production of discovery in a manner protective of the rights of third parties See Dkt No SO ORDERED Signed by Judge Alison Nathan on jbo Entered Case Document Page6 of MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff Document filed by Ghislaine Maxwell Attachments Exhibit Declaration of Jeffrey Pagliuca Exhibit Certificate of Good Standing Text of Proposed Order Proposed Order Pagliuca Jeffrey Entered S1 SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell count 1s 2s 3s 4s jm Entered NOTICE REGARDING PRO HAC VICE MOTION Regarding Document No MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff The document has been reviewed and there are no deficiencies aea Entered ORDER as to Ghislaine Maxwell As discussed in its previous order the Court will hold an arraignment initial conference and bail hearing in this matter remotely as a video/teleconference on July at pm Members of the press and the public in the United States may access the live audio feed of the proceeding by calling and using access code and PIN Those outside of the United States may access the live audio feed by calling and using the same access code and PIN These phone lines can accommodate approximately callers on a first come first serve basis The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel alleged victims and any family members of the Defendant The United States Attorneys Office should email Chambers with information regarding any alleged victims who are entitled pursuant to U.S.C a to be heard at the bail hearing and who wish to be heard The Court will then provide information as to the logistics for their dial-in access As the Court described in a previous order members of the press and public may watch and listen to the live video feed in the Jury Assembly Room at the Daniel Patrick Moynihan Courthouse Pearl Street See Dkt No However in light of COVID-19 seating will be limited to approximately seats in order to enable appropriate social distancing and ensure public safety Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant Members of the credentialed in-house press corps may contact the District Executives Office about seating Otherwise all seating will be allocated on a first come first serve basis and in accordance with the S.D.N.Y COVID-19 Courthouse Entry Program and this Courts previous order of July See Dkt No If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health the Court may provide audio access by telephone only Any photographing recording or rebroadcasting of federal court proceedings is prohibited by law Violation of these prohibitions may result in fines or sanctions including removal of court issued media credentials restricted entry to future hearings denial of entry to future hearings or any other sanctions deemed necessary by the Court SO ORDERED Signed by Judge Alison Nathan on jbo Entered MEMORANDUM in Opposition by Ghislaine Maxwell re MOTION to detain defendant Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Mark Stewart Cohen appearing for Ghislaine Maxwell Appearance Type Retained Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Christian Everdell appearing for Ghislaine Maxwell Appearance Type Retained Everdell Christian Entered WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by Ghislaine Maxwell Everdell Christian Entered REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re MOTION to detain defendant Moe Alison Entered Case Document Page7 of ORDER granting Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to Ghislaine Maxwell Signed by Judge Alison Nathan on kwi Entered ORDER as to Ghislaine Maxwell For the reasons stated on the record at todays proceeding the Governments motion to detain the Defendant pending trial is hereby GRANTED Signed by Judge Alison Nathan on jw Entered Minute Entry for proceedings held before Judge Alison Nathan:Arraignment as to Ghislaine Maxwell Count held on Defendant Ghislaine Maxwell present by video conference with attorney Mark Cohen present by video conference AUSA Alison Moe Alex Rossmiller and Maurene Comey for the government present by video conference Pretrial Service Officer Lea Harmon present by telephone and Court Reporter Kristine Caraannante Defendant enters a plea of Not Guilty to the S1 indictment Trial set for July See Order Time is excluded under the Speedy Trial Act from today until July Bail is denied Defendant is remanded See Transcript jw Entered Minute Entry for proceedings held before Judge Alison Nathan Plea entered by Ghislaine Maxwell Count Not Guilty jw Entered Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re Arraignment Bail Hearing Conference jw Entered ORDER as to Ghislaine Maxwell Initial non-electronic discovery generally to include search warrant applications and subpoena returns is due by Friday August Completion of discovery to include electronic materials is due by Monday November Motions are due by Monday December Motion responses are due by Friday January Motion replies are due by Friday February Trial is set for Monday July Discovery due by Motions due by Signed by Judge Alison Nathan on jw Entered ORDER as to Ghislaine Maxwell The Court has received a significant number of letters and messages from non-parties that purport to be related to this case These submissions are either procedurally improper or irrelevant to the judicial function Therefore they will not be considered or docketed The Court will accord the same treatment to any similar correspondence it receives in the future SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page8 of defense counsels letter filed July Document filed by USA Moe Alison Entered Case Document Page9 of statement might have occurred decades ago and have no relevance to the charges in this case These individuals still maintain a significant privacy interest that must be safeguarded The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also allows the Defense to reference the identities of individuals they believe may be relevant to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial Dkt No This proposal adequately balances the interests at stake And as the Governments letter notes see Dkt No at to the extent that the Defense needs an exception to the protective order for a specific investigative purpose they can make applications to the Court on a case-by-case basis Second restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation The Government labors under many restrictions including Rule of the Federal Rules of Criminal Procedure the Privacy Act of and other policies of the Department of Justice and the U.S Attorneys Office for the Southern District of New York all of which the Court expects the Government to scrupulously follow Furthermore the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession See Dkt No at And of course those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government Nothing in the Defenses papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial For the foregoing reasons the Court adopts the Governments proposed protective order which will be entered on the docket This resolves Dkt No SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page10 of at p.m The Defendants reply is due on Monday August at p.m The parties shall propose redactions to the letter briefing on this issue Alternatively the parties shall provide support and argument for why the letter motions should be sealed in their entirety SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for USA Pomerantz Lara Entered SEALED DOCUMENT placed in vault mhe Entered Case Document Page11 of Case Document Page12 of Case Document Page13 of temporarily sealed while the Court resolves the redaction request SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page14 of Case Document Page15 of necessary steps to ensure that the Defendant continues to receive adequate access to her legal materials and her ability to communicate with defense counsel Signed by Judge Alison Nathan on ap Entered TRANSCRIPT of Proceedings as to Ghislaine Maxwell re Conference held on before Judge Alison Nathan Court Reporter/Transcriber Kristen Carannante Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction After that date it may be obtained through PACER Redaction Request due Redacted Transcript Deadline set for Release of Transcript Restriction set for McGuirk Kelly Entered NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell Notice is hereby given that an official transcript of a Conference proceeding held on has been filed by the court reporter/transcriber in the above-captioned matter The parties have seven calendar days to file with the court a Notice of Intent to Request Redaction of this transcript If no such Notice is filed the transcript may be made remotely electronically available to the public without redaction after calendar days McGuirk Kelly Entered ORDER as to Ghislaine Maxwell On December Defendant Ghislaine Maxwell filed her renewed application for bail under seal with proposed redactions in accordance with this Courts December Order see Dkt No The Government did not file any opposition to the Defendants proposed redactions After due consideration the Court will adopt the Defendants proposed redactions The Courts decision to adopt those redactions is guided by the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo F.3d 2d Amodeo II The proposed redactions satisfy this test The Court finds that Defendants letter motions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless in balancing competing considerations against the presumption of access the Court finds that the redactions are narrowly tailored to properly guard the privacy interests of the individuals referenced in the Defendants submission and in the corresponding exhibits The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits Signed by Judge Alison Nathan on ap Entered Case Document Page16 of those materials The Defendant did not file any opposition to the Governments proposed redactions The Court will adopt the Governments proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Governments submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless the proposed redactions are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d The Government is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December Signed by Judge Alison Nathan on ap Entered MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed Bail Motion Attachments Exhibit A Exhibit Comey Maurene Entered ORDER as to Ghislaine Maxwell On December the Defendant filed her reply to the Governments opposition to her renewed application for bail In accordance with this Courts December Order see Dkt No she filed these materials under seal and proposed narrowly tailored redactions on those materials The Government did not file any opposition to the Defendants proposed redactions The Court will adopt the Defendants proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Defendants submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S As with the redactions to her renewed motion for bail the proposed redactions here are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d S.D.N.Y See also Dkt No The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page17 of motion In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket the Court will permit the parties hours to propose any redactions to the Courts Opinion and Order and to justify those redactions by reference tothe Second Circuits decision in Lugosch Pyramid Co of Onondaga F.3d 2d Cir After determining which if any portions of the Opinion and Order should be redacted the Court will file the Opinion and Order on the public docket As a result the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pretrial detention continues to be warranted On or before December the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal This resolves Dkt No Signed by Judge Alison Nathan on jw Entered Case Document Page18 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were transmitted to the U.S Court of Appeals nd Entered Case Document Page19 of Cohen Mark Entered ORDER as to Ghislaine Maxwell On January the Defendant filed twelve pre-trial motions Because there is a request to redact sensitive or confidential information several of the motions have been filed under temporary seal The Government may respond to the Defendants proposed redactions within two days of this Order Signed by Judge Alison Nathan on ap Entered Case Document Page20 of MOTION to Suppress Under the Fourth Amendment Martindell and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six Document filed by Ghislaine Maxwell Pagliuca Jeffrey Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Suppress Under the Fourth Amendment Martindell and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six Pagliuca Jeffrey Entered MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution Agreement Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution Agreement Attachments Exhibit A Exhibit Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Cohen Mark Entered MOTION to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred Cohen Mark Entered MOTION to Strike Surplusage from Superseding Indictment Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Strike Surplusage from Superseding Indictment Cohen Mark Entered MOTION for Bill of Particulars and Pretrial Disclosures Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION for Bill of Particulars and Pretrial Disclosures Attachments Exhibit A Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Cohen Mark Entered AFFIDAVIT of Bobbi Sternheim in Support as to Ghislaine Maxwell re MOTION for Bill of Particulars and Pretrial Disclosures Cohen Mark Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered Case Document Page21 of THIRD MOTION for Bond Document filed by Ghislaine Maxwell Sternheim Bobbi Entered ORDER as to Ghislaine Maxwell On February Defendant Ghislaine Maxwell filed a third motion for release on bail Dkt No The Governments response is due March and the Defendants reply is due March SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered Case Document Page22 of ORDER as to Ghislaine Maxwell Defendant Ghislaine Maxwells third motion for release on bail Dkt No is DENIED The parties are ORDERED to meet and confer and propose and justify any redactions to the Defendants reply brief by March If they conclude that redactions are unnecessary the Defendant is ORDERED to docket the unredacted version of the brief by March Signed by Judge Alison Nathan on See ORDER set forth ap Modified on ap Entered Case Document Page23 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were transmitted to the U.S Court of Appeals tp Entered SEALED DOCUMENT placed in vault dn Entered SEALED DOCUMENT placed in vault dn Entered SEALED DOCUMENT placed in vault dn Entered Case Document Page24 of s6 RA ANN UDG8.1 AN URT Tit-30 ll DNY YOR5.4 CIT4.9 udge4.5 Case Document Page1 of From NYSD_ECF_Pool nysd.uscourts.gov To NYSD CourtMail Subject Activity in Case USA Maxwell Appeal Record Sent to USCA Electronic File Date Wednesday March AM This is an automatic e-mail message generated by the CM/ECF system Plea se DO NOT RESPOND to this e-mail because the mail box is unattended NOTE TO PUBLIC ACCESS USERS Judicial Conference of the United Stat es policy permits attorneys of record and parties in a case including pro se litigants to receive one free electronic copy of all documents filed electronically if receipt is required by law or directed by the filer PACER access fees apply to all other us ers To avoid later charges download a copy of each document during this first viewing How ever if the referenced document is a transcript the free copy and page limit do not apply U.S District Court Southern District of New York Notice of Electronic Filing The following transaction was entered on at AM EDT and iled on Case Name USA Maxwell Case Number Filer Document Number No document attached Docket Text Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appe al were transmitted to the U.S Court of Appeals tp Notice has been electronically mailed to Jeffrey Pagliuca jpagliuca hmflaw.com nsimmons hmflaw.com Laura A Menninger lmenninger hmflaw.com alundberg hmflaw.com hrogers hmflaw.com nsimmons hmflaw.com Bobbi Sternheim bc sternheimlaw.com bcsternheim mac.com ecf sternheimlaw.com Christian Everdell ceverdell cohengresser.com autodocket cohengresser.com Mark Stewart Cohen mcohen cohengresser.com Mark-Cohen-1234 ecf.pacerpro.com autodocket cohengresser.com managingclerksoffice cohengresser.com Lara Elizabeth Pomerantz Lara.Pomerantz usdoj.gov CaseView.ECF usdoj.gov USANYS.ECF USDOJ.GOV Case Document Page1 of Alison Gainfort Moe alison.moe usdoj.gov CaseView.ECF usdoj.gov USANYS.ECF USDOJ.GOV Alex Rossmiller alexander.rossmiller usdoj.gov CaseView.ECF usdoj.gov USANYS.ECF USDOJ.GOV Maurene Ryan Comey maurene.comey usdoj.gov CaseView.ECF usdoj.gov USANYS.ECF USDOJ.GOV Andrew Rohrbach Andrew.Rohrbach usdoj.gov caseview.ecf usdoj.gov usanys.ecf usdoj.gov Notice has been delivered by other means to Case Document Page2 of APPEAL,ECF,INTAPP U.S District Court Southern District of New York Foley Square Case Document Page3 of ATTORNEY TO BE NOTICED Pending Counts Disposition CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS 1s COERCION OR ENTICEMENT OFA MINOT TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS COERCION OR ENTICEMENT OF MINOR TO ENGAGE IN ILLEGAL SEX ACTS 2s CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 3s COERCION OR ENTICEMENT OF MINOR FEMALE TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 4s FALSE DECLARATIONS BEFORE GRAND JURY/COURT PERJURY FALSE DECLARATIONS BEFORE GRAND JURY/COURT Highest Offense Level Opening Felony Case Document Page4 of Terminated Counts Disposition None Highest Offense Level Terminated None Complaints Disposition None Plaintiff USA represented by Alex Rossmiller U.S Attorneys Office Southern District of New York St Andrews Plaza New York NY Email alexander.rossmiller usdoj.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED Designation Assistant US Attorney Alison Gainfort Moe United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email alison.moe usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Maurene Ryan Comey United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email maurene.comey usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Andrew Rohrbach DOJ-USAO St Andrews Plaza New York NY Email Andrew.Rohrbach usdoj.gov ATTORNEY TO BE NOTICED Lara Elizabeth Pomerantz United States Attorneys Office One St Andrews Plaza New York NY Fax Email Lara.Pomerantz usdoj.gov ATTORNEY TO BE NOTICED Case Document Page5 of Date Filed Docket Text SEALED INDICTMENT as to Sealed Defendant count jm Main Document replaced on jm Entered Order to Unseal Indictment as to Sealed Defendant Signed by Magistrate Judge Katharine Parker on jm Entered INDICTMENT UNSEALED as to Ghislaine Maxwell jm Entered Case Designated ECF as to Ghislaine Maxwell jm Entered Case as to Ghislaine Maxwell ASSIGNED to Judge Alison Nathan jm Entered Attorney update in case as to Ghislaine Maxwell Attorney Alex Rossmiller,Maurene Ryan Comey,Alison Gainfort Moe for USA added jm Entered MOTION to detain defendant Document filed by USA as to Ghislaine Maxwell Moe Alison Entered Arrest of Ghislaine Maxwell in the United States District Court District of New Hampshire jm Entered Case Document Page6 of capacity of the internet platform system only one attorney per party may participate by video Co-counsel members of the press and the public may access the audio feed of the proceeding by calling a dial-in number which the Court will provide in advance of the proceeding by subsequent order Given the high degree of public interest in this case a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse Pearl Street New York NY Due to social distancing requirements seating will be extremely limited when capacity is reached no additional persons will be admitted Per the S.D.N.Y COVID-19 Courthouse Entry Program anyone who appears at any S.D.N.Y courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse All visitors must also have their temperature taken when they arrive at the courthouse Please see the instructions attached Completing the questionnaire ahead of time will save time and effort upon entry Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below degrees will be allowed to enter the courthouse Face coverings that cover the nose and mouth must be worn at all times Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse There are no exceptions As discussed in the Courts previous order defense counsel shall if possible discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding See Dkt No If the Defendant consents and is able to sign the form either personally or in accordance with Standing Order of March by defense counsel defense counsel shall file the executed form at least hours prior to the proceeding In the event the Defendant consents but counsel is unable to obtain or affix the Defendants signature on the form the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendants signature to the form Pursuant to U.S.C the Government must make their best efforts to see that crime victims are notified of and accorded the rights provided to them in that section This includes the right to reasonable accurate and timely notice of any public court proceeding involving the crime or of any release of the accused and the right to be reasonably heard at any public proceeding in the district court involving release Id a The Court will inquire with the Government as to the extent of those efforts So that appropriate logistical arrangements can be made the Government shall inform the Court by email within hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial Finally the time between the Defendants arrest and July is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district See U.S.C And the Court further excludes time under the Speedy Trial Act from today through July Due to the logistical issues involved in conducting a remote proceeding the Court finds that the ends of justice served by this exclusion outweigh the best interest of the public and the defendant in a speedy trial U.S.C A The exclusion is also supported by the need for the parties to discuss a potential protective order which will facilitate the timely production of discovery in a manner protective of the rights of third parties See Dkt No SO ORDERED Signed by Judge Alison Nathan on jbo Entered Case Document Page7 of MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff Document filed by Ghislaine Maxwell Attachments Exhibit Declaration of Jeffrey Pagliuca Exhibit Certificate of Good Standing Text of Proposed Order Proposed Order Pagliuca Jeffrey Entered S1 SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell count 1s 2s 3s 4s jm Entered NOTICE REGARDING PRO HAC VICE MOTION Regarding Document No MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff The document has been reviewed and there are no deficiencies aea Entered ORDER as to Ghislaine Maxwell As discussed in its previous order the Court will hold an arraignment initial conference and bail hearing in this matter remotely as a video/teleconference on July at pm Members of the press and the public in the United States may access the live audio feed of the proceeding by calling and using access code and PIN Those outside of the United States may access the live audio feed by calling and using the same access code and PIN These phone lines can accommodate approximately callers on a first come first serve basis The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel alleged victims and any family members of the Defendant The United States Attorneys Office should email Chambers with information regarding any alleged victims who are entitled pursuant to U.S.C a to be heard at the bail hearing and who wish to be heard The Court will then provide information as to the logistics for their dial-in access As the Court described in a previous order members of the press and public may watch and listen to the live video feed in the Jury Assembly Room at the Daniel Patrick Moynihan Courthouse Pearl Street See Dkt No However in light of COVID-19 seating will be limited to approximately seats in order to enable appropriate social distancing and ensure public safety Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant Members of the credentialed in-house press corps may contact the District Executives Office about seating Otherwise all seating will be allocated on a first come first serve basis and in accordance with the S.D.N.Y COVID-19 Courthouse Entry Program and this Courts previous order of July See Dkt No If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health the Court may provide audio access by telephone only Any photographing recording or rebroadcasting of federal court proceedings is prohibited by law Violation of these prohibitions may result in fines or sanctions including removal of court issued media credentials restricted entry to future hearings denial of entry to future hearings or any other sanctions deemed necessary by the Court SO ORDERED Signed by Judge Alison Nathan on jbo Entered MEMORANDUM in Opposition by Ghislaine Maxwell re MOTION to detain defendant Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Mark Stewart Cohen appearing for Ghislaine Maxwell Appearance Type Retained Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Christian Everdell appearing for Ghislaine Maxwell Appearance Type Retained Everdell Christian Entered WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by Ghislaine Maxwell Everdell Christian Entered REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re MOTION to detain defendant Moe Alison Entered Case Document Page8 of ORDER granting Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to Ghislaine Maxwell Signed by Judge Alison Nathan on kwi Entered ORDER as to Ghislaine Maxwell For the reasons stated on the record at todays proceeding the Governments motion to detain the Defendant pending trial is hereby GRANTED Signed by Judge Alison Nathan on jw Entered Minute Entry for proceedings held before Judge Alison Nathan:Arraignment as to Ghislaine Maxwell Count held on Defendant Ghislaine Maxwell present by video conference with attorney Mark Cohen present by video conference AUSA Alison Moe Alex Rossmiller and Maurene Comey for the government present by video conference Pretrial Service Officer Lea Harmon present by telephone and Court Reporter Kristine Caraannante Defendant enters a plea of Not Guilty to the S1 indictment Trial set for July See Order Time is excluded under the Speedy Trial Act from today until July Bail is denied Defendant is remanded See Transcript jw Entered Minute Entry for proceedings held before Judge Alison Nathan Plea entered by Ghislaine Maxwell Count Not Guilty jw Entered Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re Arraignment Bail Hearing Conference jw Entered ORDER as to Ghislaine Maxwell Initial non-electronic discovery generally to include search warrant applications and subpoena returns is due by Friday August Completion of discovery to include electronic materials is due by Monday November Motions are due by Monday December Motion responses are due by Friday January Motion replies are due by Friday February Trial is set for Monday July Discovery due by Motions due by Signed by Judge Alison Nathan on jw Entered ORDER as to Ghislaine Maxwell The Court has received a significant number of letters and messages from non-parties that purport to be related to this case These submissions are either procedurally improper or irrelevant to the judicial function Therefore they will not be considered or docketed The Court will accord the same treatment to any similar correspondence it receives in the future SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page9 of defense counsels letter filed July Document filed by USA Moe Alison Entered Case Document Page10 of statement might have occurred decades ago and have no relevance to the charges in this case These individuals still maintain a significant privacy interest that must be safeguarded The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also allows the Defense to reference the identities of individuals they believe may be relevant to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial Dkt No This proposal adequately balances the interests at stake And as the Governments letter notes see Dkt No at to the extent that the Defense needs an exception to the protective order for a specific investigative purpose they can make applications to the Court on a case-by-case basis Second restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation The Government labors under many restrictions including Rule of the Federal Rules of Criminal Procedure the Privacy Act of and other policies of the Department of Justice and the U.S Attorneys Office for the Southern District of New York all of which the Court expects the Government to scrupulously follow Furthermore the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession See Dkt No at And of course those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government Nothing in the Defenses papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial For the foregoing reasons the Court adopts the Governments proposed protective order which will be entered on the docket This resolves Dkt No SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page11 of at p.m The Defendants reply is due on Monday August at p.m The parties shall propose redactions to the letter briefing on this issue Alternatively the parties shall provide support and argument for why the letter motions should be sealed in their entirety SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for USA Pomerantz Lara Entered SEALED DOCUMENT placed in vault mhe Entered Case Document Page12 of Case Document Page13 of Case Document Page14 of temporarily sealed while the Court resolves the redaction request SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page15 of Case Document Page16 of necessary steps to ensure that the Defendant continues to receive adequate access to her legal materials and her ability to communicate with defense counsel Signed by Judge Alison Nathan on ap Entered TRANSCRIPT of Proceedings as to Ghislaine Maxwell re Conference held on before Judge Alison Nathan Court Reporter/Transcriber Kristen Carannante Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction After that date it may be obtained through PACER Redaction Request due Redacted Transcript Deadline set for Release of Transcript Restriction set for McGuirk Kelly Entered NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell Notice is hereby given that an official transcript of a Conference proceeding held on has been filed by the court reporter/transcriber in the above-captioned matter The parties have seven calendar days to file with the court a Notice of Intent to Request Redaction of this transcript If no such Notice is filed the transcript may be made remotely electronically available to the public without redaction after calendar days McGuirk Kelly Entered ORDER as to Ghislaine Maxwell On December Defendant Ghislaine Maxwell filed her renewed application for bail under seal with proposed redactions in accordance with this Courts December Order see Dkt No The Government did not file any opposition to the Defendants proposed redactions After due consideration the Court will adopt the Defendants proposed redactions The Courts decision to adopt those redactions is guided by the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo F.3d 2d Amodeo II The proposed redactions satisfy this test The Court finds that Defendants letter motions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless in balancing competing considerations against the presumption of access the Court finds that the redactions are narrowly tailored to properly guard the privacy interests of the individuals referenced in the Defendants submission and in the corresponding exhibits The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits Signed by Judge Alison Nathan on ap Entered Case Document Page17 of those materials The Defendant did not file any opposition to the Governments proposed redactions The Court will adopt the Governments proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Governments submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless the proposed redactions are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d The Government is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December Signed by Judge Alison Nathan on ap Entered MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed Bail Motion Attachments Exhibit A Exhibit Comey Maurene Entered ORDER as to Ghislaine Maxwell On December the Defendant filed her reply to the Governments opposition to her renewed application for bail In accordance with this Courts December Order see Dkt No she filed these materials under seal and proposed narrowly tailored redactions on those materials The Government did not file any opposition to the Defendants proposed redactions The Court will adopt the Defendants proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Defendants submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S As with the redactions to her renewed motion for bail the proposed redactions here are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d S.D.N.Y See also Dkt No The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page18 of motion In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket the Court will permit the parties hours to propose any redactions to the Courts Opinion and Order and to justify those redactions by reference tothe Second Circuits decision in Lugosch Pyramid Co of Onondaga F.3d 2d Cir After determining which if any portions of the Opinion and Order should be redacted the Court will file the Opinion and Order on the public docket As a result the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pretrial detention continues to be warranted On or before December the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal This resolves Dkt No Signed by Judge Alison Nathan on jw Entered Case Document Page19 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were transmitted to the U.S Court of Appeals nd Entered Case Document Page20 of Cohen Mark Entered ORDER as to Ghislaine Maxwell On January the Defendant filed twelve pre-trial motions Because there is a request to redact sensitive or confidential information several of the motions have been filed under temporary seal The Government may respond to the Defendants proposed redactions within two days of this Order Signed by Judge Alison Nathan on ap Entered Case Document Page21 of MOTION to Suppress Under the Fourth Amendment Martindell and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six Document filed by Ghislaine Maxwell Pagliuca Jeffrey Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Suppress Under the Fourth Amendment Martindell and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six Pagliuca Jeffrey Entered MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution Agreement Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution Agreement Attachments Exhibit A Exhibit Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Cohen Mark Entered MOTION to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred Cohen Mark Entered MOTION to Strike Surplusage from Superseding Indictment Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Strike Surplusage from Superseding Indictment Cohen Mark Entered MOTION for Bill of Particulars and Pretrial Disclosures Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION for Bill of Particulars and Pretrial Disclosures Attachments Exhibit A Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Cohen Mark Entered AFFIDAVIT of Bobbi Sternheim in Support as to Ghislaine Maxwell re MOTION for Bill of Particulars and Pretrial Disclosures Cohen Mark Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered Case Document Page22 of THIRD MOTION for Bond Document filed by Ghislaine Maxwell Sternheim Bobbi Entered ORDER as to Ghislaine Maxwell On February Defendant Ghislaine Maxwell filed a third motion for release on bail Dkt No The Governments response is due March and the Defendants reply is due March SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered Case Document Page23 of ORDER as to Ghislaine Maxwell Defendant Ghislaine Maxwells third motion for release on bail Dkt No is DENIED The parties are ORDERED to meet and confer and propose and justify any redactions to the Defendants reply brief by March If they conclude that redactions are unnecessary the Defendant is ORDERED to docket the unredacted version of the brief by March Signed by Judge Alison Nathan on See ORDER set forth ap Modified on ap Entered Case Document Page24 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were transmitted to the U.S Court of Appeals tp Entered SEALED DOCUMENT placed in vault dn Entered SEALED DOCUMENT placed in vault dn Entered SEALED DOCUMENT placed in vault dn Entered Case Document Page25 of ce al A AL rt __ ptio12 cket ct tice is he12 en hat appea13.3 ls he nite12 tat12 es eals th12 econd Cir17 cuit ju12 dgment15 __ fy in this actio12 on __ his ictio11.3 __ nce nly18 __ ictio11.3 nce ther16.3 __ ant ilty22 ple12 a ial __ ffe12 nse ccurr15.3 ed fte12 ov16 ember14 es __ __ te of nce A isposit14 ommitt13.3 ed co12 mmitte13.3 A ellan12 sel es If es ide the foll11.3 ing info12 rmat13.3 ion ant ounsel12.656 unsel unsel Assist13.667 ant tto12 SA14 2s SA14 2s hone re Case Document Filed Page of Case Document Page1 of SDC SONY LY IL I APPEAL,ECF,INTAPP U.S District Court Southern District of New York Foley Square Case Document Page2 of ATTORNEY TO BE NOTICED Pending Counts Disposition CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS 1s COERCION OR ENTICEMENT OFA MINOT TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS COERCION OR ENTICEMENT OF MINOR TO ENGAGE IN ILLEGAL SEX ACTS 2s CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 3s COERCION OR ENTICEMENT OF MINOR FEMALE TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY 4s FALSE DECLARATIONS BEFORE GRAND JURY/COURT PERJURY FALSE DECLARATIONS BEFORE GRAND JURY/COURT Highest Offense Level Opening Felony Case Document Page3 of Terminated Counts Disposition None Highest Offense Level Terminated None Complaints Disposition None Plaintiff USA represented by Alex Rossmiller U.S Attorneys Office Southern District of New York St Andrews Plaza New York NY Email alexander.rossmiller usdoj.gov LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED Designation Assistant US Attorney Alison Gainfort Moe United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email alison.moe usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Maurene Ryan Comey United States Attorneys Office SDNY One Saint Andrews Plaza New York NY Email maurene.comey usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation Assistant US Attorney Andrew Rohrbach DOJ-USAO St Andrews Plaza New York NY Email Andrew.Rohrbach usdoj.gov ATTORNEY TO BE NOTICED Lara Elizabeth Pomerantz United States Attorneys Office One St Andrews Plaza New York NY Fax Email Lara.Pomerantz usdoj.gov ATTORNEY TO BE NOTICED Case Document Page4 of Date Filed Docket Text SEALED INDICTMENT as to Sealed Defendant count jm Main Document replaced on jm Entered Order to Unseal Indictment as to Sealed Defendant Signed by Magistrate Judge Katharine Parker on jm Entered INDICTMENT UNSEALED as to Ghislaine Maxwell jm Entered Case Designated ECF as to Ghislaine Maxwell jm Entered Case as to Ghislaine Maxwell ASSIGNED to Judge Alison Nathan jm Entered Attorney update in case as to Ghislaine Maxwell Attorney Alex Rossmiller,Maurene Ryan Comey,Alison Gainfort Moe for USA added jm Entered MOTION to detain defendant Document filed by USA as to Ghislaine Maxwell Moe Alison Entered Arrest of Ghislaine Maxwell in the United States District Court District of New Hampshire jm Entered Case Document Page5 of capacity of the internet platform system only one attorney per party may participate by video Co-counsel members of the press and the public may access the audio feed of the proceeding by calling a dial-in number which the Court will provide in advance of the proceeding by subsequent order Given the high degree of public interest in this case a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse Pearl Street New York NY Due to social distancing requirements seating will be extremely limited when capacity is reached no additional persons will be admitted Per the S.D.N.Y COVID-19 Courthouse Entry Program anyone who appears at any S.D.N.Y courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse All visitors must also have their temperature taken when they arrive at the courthouse Please see the instructions attached Completing the questionnaire ahead of time will save time and effort upon entry Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below degrees will be allowed to enter the courthouse Face coverings that cover the nose and mouth must be worn at all times Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse There are no exceptions As discussed in the Courts previous order defense counsel shall if possible discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding See Dkt No If the Defendant consents and is able to sign the form either personally or in accordance with Standing Order of March by defense counsel defense counsel shall file the executed form at least hours prior to the proceeding In the event the Defendant consents but counsel is unable to obtain or affix the Defendants signature on the form the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendants signature to the form Pursuant to U.S.C the Government must make their best efforts to see that crime victims are notified of and accorded the rights provided to them in that section This includes the right to reasonable accurate and timely notice of any public court proceeding involving the crime or of any release of the accused and the right to be reasonably heard at any public proceeding in the district court involving release Id a The Court will inquire with the Government as to the extent of those efforts So that appropriate logistical arrangements can be made the Government shall inform the Court by email within hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial Finally the time between the Defendants arrest and July is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district See U.S.C And the Court further excludes time under the Speedy Trial Act from today through July Due to the logistical issues involved in conducting a remote proceeding the Court finds that the ends of justice served by this exclusion outweigh the best interest of the public and the defendant in a speedy trial U.S.C A The exclusion is also supported by the need for the parties to discuss a potential protective order which will facilitate the timely production of discovery in a manner protective of the rights of third parties See Dkt No SO ORDERED Signed by Judge Alison Nathan on jbo Entered Case Document Page6 of MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff Document filed by Ghislaine Maxwell Attachments Exhibit Declaration of Jeffrey Pagliuca Exhibit Certificate of Good Standing Text of Proposed Order Proposed Order Pagliuca Jeffrey Entered S1 SUPERSEDING INDICTMENT FILED as to Ghislaine Maxwell count 1s 2s 3s 4s jm Entered NOTICE REGARDING PRO HAC VICE MOTION Regarding Document No MOTION for Jeffrey Pagliuca to Appear Pro Hac Vice Filing fee receipt number Motion and supporting papers to be reviewed by Clerks Office staff The document has been reviewed and there are no deficiencies aea Entered ORDER as to Ghislaine Maxwell As discussed in its previous order the Court will hold an arraignment initial conference and bail hearing in this matter remotely as a video/teleconference on July at pm Members of the press and the public in the United States may access the live audio feed of the proceeding by calling and using access code and PIN Those outside of the United States may access the live audio feed by calling and using the same access code and PIN These phone lines can accommodate approximately callers on a first come first serve basis The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel alleged victims and any family members of the Defendant The United States Attorneys Office should email Chambers with information regarding any alleged victims who are entitled pursuant to U.S.C a to be heard at the bail hearing and who wish to be heard The Court will then provide information as to the logistics for their dial-in access As the Court described in a previous order members of the press and public may watch and listen to the live video feed in the Jury Assembly Room at the Daniel Patrick Moynihan Courthouse Pearl Street See Dkt No However in light of COVID-19 seating will be limited to approximately seats in order to enable appropriate social distancing and ensure public safety Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant Members of the credentialed in-house press corps may contact the District Executives Office about seating Otherwise all seating will be allocated on a first come first serve basis and in accordance with the S.D.N.Y COVID-19 Courthouse Entry Program and this Courts previous order of July See Dkt No If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health the Court may provide audio access by telephone only Any photographing recording or rebroadcasting of federal court proceedings is prohibited by law Violation of these prohibitions may result in fines or sanctions including removal of court issued media credentials restricted entry to future hearings denial of entry to future hearings or any other sanctions deemed necessary by the Court SO ORDERED Signed by Judge Alison Nathan on jbo Entered MEMORANDUM in Opposition by Ghislaine Maxwell re MOTION to detain defendant Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Mark Stewart Cohen appearing for Ghislaine Maxwell Appearance Type Retained Cohen Mark Entered NOTICE OF ATTORNEY APPEARANCE Christian Everdell appearing for Ghislaine Maxwell Appearance Type Retained Everdell Christian Entered WAIVER of Personal Appearance at Arraignment and Entry of Plea of Not Guilty by Ghislaine Maxwell Everdell Christian Entered REPLY MEMORANDUM OF LAW in Support by USA as to Ghislaine Maxwell re MOTION to detain defendant Moe Alison Entered Case Document Page7 of ORDER granting Motion for Jeffrey Pagliuca to Appear Pro Hac Vice as to Ghislaine Maxwell Signed by Judge Alison Nathan on kwi Entered ORDER as to Ghislaine Maxwell For the reasons stated on the record at todays proceeding the Governments motion to detain the Defendant pending trial is hereby GRANTED Signed by Judge Alison Nathan on jw Entered Minute Entry for proceedings held before Judge Alison Nathan:Arraignment as to Ghislaine Maxwell Count held on Defendant Ghislaine Maxwell present by video conference with attorney Mark Cohen present by video conference AUSA Alison Moe Alex Rossmiller and Maurene Comey for the government present by video conference Pretrial Service Officer Lea Harmon present by telephone and Court Reporter Kristine Caraannante Defendant enters a plea of Not Guilty to the S1 indictment Trial set for July See Order Time is excluded under the Speedy Trial Act from today until July Bail is denied Defendant is remanded See Transcript jw Entered Minute Entry for proceedings held before Judge Alison Nathan Plea entered by Ghislaine Maxwell Count Not Guilty jw Entered Waiver of Right to be Present at Criminal Proceeding as to Ghislaine Maxwell re Arraignment Bail Hearing Conference jw Entered ORDER as to Ghislaine Maxwell Initial non-electronic discovery generally to include search warrant applications and subpoena returns is due by Friday August Completion of discovery to include electronic materials is due by Monday November Motions are due by Monday December Motion responses are due by Friday January Motion replies are due by Friday February Trial is set for Monday July Discovery due by Motions due by Signed by Judge Alison Nathan on jw Entered ORDER as to Ghislaine Maxwell The Court has received a significant number of letters and messages from non-parties that purport to be related to this case These submissions are either procedurally improper or irrelevant to the judicial function Therefore they will not be considered or docketed The Court will accord the same treatment to any similar correspondence it receives in the future SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page8 of defense counsels letter filed July Document filed by USA Moe Alison Entered Case Document Page9 of statement might have occurred decades ago and have no relevance to the charges in this case These individuals still maintain a significant privacy interest that must be safeguarded The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also allows the Defense to reference the identities of individuals they believe may be relevant to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial Dkt No This proposal adequately balances the interests at stake And as the Governments letter notes see Dkt No at to the extent that the Defense needs an exception to the protective order for a specific investigative purpose they can make applications to the Court on a case-by-case basis Second restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation The Government labors under many restrictions including Rule of the Federal Rules of Criminal Procedure the Privacy Act of and other policies of the Department of Justice and the U.S Attorneys Office for the Southern District of New York all of which the Court expects the Government to scrupulously follow Furthermore the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession See Dkt No at And of course those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government Nothing in the Defenses papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial For the foregoing reasons the Court adopts the Governments proposed protective order which will be entered on the docket This resolves Dkt No SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page10 of at p.m The Defendants reply is due on Monday August at p.m The parties shall propose redactions to the letter briefing on this issue Alternatively the parties shall provide support and argument for why the letter motions should be sealed in their entirety SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for USA Pomerantz Lara Entered SEALED DOCUMENT placed in vault mhe Entered Case Document Page11 of Case Document Page12 of Case Document Page13 of temporarily sealed while the Court resolves the redaction request SO ORDERED Signed by Judge Alison Nathan on bw Entered Case Document Page14 of Case Document Page15 of necessary steps to ensure that the Defendant continues to receive adequate access to her legal materials and her ability to communicate with defense counsel Signed by Judge Alison Nathan on ap Entered TRANSCRIPT of Proceedings as to Ghislaine Maxwell re Conference held on before Judge Alison Nathan Court Reporter/Transcriber Kristen Carannante Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction After that date it may be obtained through PACER Redaction Request due Redacted Transcript Deadline set for Release of Transcript Restriction set for McGuirk Kelly Entered NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Ghislaine Maxwell Notice is hereby given that an official transcript of a Conference proceeding held on has been filed by the court reporter/transcriber in the above-captioned matter The parties have seven calendar days to file with the court a Notice of Intent to Request Redaction of this transcript If no such Notice is filed the transcript may be made remotely electronically available to the public without redaction after calendar days McGuirk Kelly Entered ORDER as to Ghislaine Maxwell On December Defendant Ghislaine Maxwell filed her renewed application for bail under seal with proposed redactions in accordance with this Courts December Order see Dkt No The Government did not file any opposition to the Defendants proposed redactions After due consideration the Court will adopt the Defendants proposed redactions The Courts decision to adopt those redactions is guided by the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo F.3d 2d Amodeo II The proposed redactions satisfy this test The Court finds that Defendants letter motions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless in balancing competing considerations against the presumption of access the Court finds that the redactions are narrowly tailored to properly guard the privacy interests of the individuals referenced in the Defendants submission and in the corresponding exhibits The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits Signed by Judge Alison Nathan on ap Entered Case Document Page16 of those materials The Defendant did not file any opposition to the Governments proposed redactions The Court will adopt the Governments proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Governments submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S Nevertheless the proposed redactions are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d The Government is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December Signed by Judge Alison Nathan on ap Entered MEMORANDUM OF LAW in Opposition by USA as to Ghislaine Maxwell Renewed Bail Motion Attachments Exhibit A Exhibit Comey Maurene Entered ORDER as to Ghislaine Maxwell On December the Defendant filed her reply to the Governments opposition to her renewed application for bail In accordance with this Courts December Order see Dkt No she filed these materials under seal and proposed narrowly tailored redactions on those materials The Government did not file any opposition to the Defendants proposed redactions The Court will adopt the Defendants proposed redactions after applying the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Under this test the Court must i determine whether the documents in question are judicial documents ii assess the weight of the common law presumption of access to the materials and i balance competing considerations against the presumption of access Id at Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure Id at quoting United States Amodeo Amodeo II F.3d 2d Cir The proposed redactions satisfy this test The Court finds that the Defendants submissions are relevant to the performance of the judicial function and useful in the judicial process thereby qualifying as a judicial document for purposes of the first element of the Lugosch test United States Amodeo Amodeo I F.3d 2d Cir And the Court also finds that the common law presumption of access attaches Id at see also Nixon Warner Commcns Inc U.S As with the redactions to her renewed motion for bail the proposed redactions here are narrowly tailored to serve substantial interests including most importantly third parties personal privacy interests See Under Seal Under Seal Supp 3d S.D.N.Y See also Dkt No The Defendant is hereby ORDERED to docket the redacted documents and corresponding exhibits by no later than December SO ORDERED Signed by Judge Alison Nathan on lnl Entered Case Document Page17 of motion In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket the Court will permit the parties hours to propose any redactions to the Courts Opinion and Order and to justify those redactions by reference tothe Second Circuits decision in Lugosch Pyramid Co of Onondaga F.3d 2d Cir After determining which if any portions of the Opinion and Order should be redacted the Court will file the Opinion and Order on the public docket As a result the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pretrial detention continues to be warranted On or before December the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal This resolves Dkt No Signed by Judge Alison Nathan on jw Entered Case Document Page18 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were transmitted to the U.S Court of Appeals nd Entered Case Document Page19 of Cohen Mark Entered ORDER as to Ghislaine Maxwell On January the Defendant filed twelve pre-trial motions Because there is a request to redact sensitive or confidential information several of the motions have been filed under temporary seal The Government may respond to the Defendants proposed redactions within two days of this Order Signed by Judge Alison Nathan on ap Entered Case Document Page20 of MOTION to Suppress Under the Fourth Amendment Martindell and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six Document filed by Ghislaine Maxwell Pagliuca Jeffrey Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Suppress Under the Fourth Amendment Martindell and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six Pagliuca Jeffrey Entered MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution Agreement Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Dismiss the Superseding Indictment for Breach of Non-Prosecution Agreement Attachments Exhibit A Exhibit Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Sealed Cohen Mark Entered MOTION to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred Cohen Mark Entered MOTION to Strike Surplusage from Superseding Indictment Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION to Strike Surplusage from Superseding Indictment Cohen Mark Entered MOTION for Bill of Particulars and Pretrial Disclosures Document filed by Ghislaine Maxwell Cohen Mark Entered MEMORANDUM in Support by Ghislaine Maxwell re MOTION for Bill of Particulars and Pretrial Disclosures Attachments Exhibit A Exhibit Sealed Exhibit Sealed Exhibit Sealed Exhibit Cohen Mark Entered AFFIDAVIT of Bobbi Sternheim in Support as to Ghislaine Maxwell re MOTION for Bill of Particulars and Pretrial Disclosures Cohen Mark Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered SEALED DOCUMENT placed in vault jri Entered Case Document Page21 of THIRD MOTION for Bond Document filed by Ghislaine Maxwell Sternheim Bobbi Entered ORDER as to Ghislaine Maxwell On February Defendant Ghislaine Maxwell filed a third motion for release on bail Dkt No The Governments response is due March and the Defendants reply is due March SO ORDERED Responses due by Replies due by Signed by Judge Alison Nathan on lnl Entered Case Document Page22 of ORDER as to Ghislaine Maxwell Defendant Ghislaine Maxwells third motion for release on bail Dkt No is DENIED The parties are ORDERED to meet and confer and propose and justify any redactions to the Defendants reply brief by March If they conclude that redactions are unnecessary the Defendant is ORDERED to docket the unredacted version of the brief by March Signed by Judge Alison Nathan on See ORDER set forth ap Modified on ap Entered Case Document Page23 of Appeal Record Sent to USCA Electronic File Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re Notice of Appeal were transmitted to the U.S Court of Appeals tp Entered SEALED DOCUMENT placed in vault dn Entered SEALED DOCUMENT placed in vault dn Entered SEALED DOCUMENT placed in vault dn Entered Case Document Page24 of CE APPEARAN-17.4 CE EL t6 Subs22.5 onal36.1 ouns16.2 on as foll20.4 i6 r6 r6 l6 il or t6 i6 t6 l6 r6 l6 i6 l6 l6 t6 i6 t6 l6 r6 l6 i6 t6 r6 l6 i6 i6 s6 r6 f6 I rtify newed I i6 t6 r6 f6 l6 r6 r6 i6 t6 United-276.6 States-274.7 Maxwell Maurene-276.3 Comey United-276.4 States-274.6 Attorneys-273.4 Office-274.1 Southern-275.6 District-275 York Andrews-276 Plaza maurene.comey usdoj.gov United-276.4 States-274.6 America/Appellee Attorneys-274.5 Office-275.1 Southern-275.8 District-277.5 York November-277.3 s/Maurene-275 Come Maurene-277.6 Comey Case Document Page1 of CE APPEARAN-17.4 CE EL t6 Subs22.5 onal36.1 ouns16.2 on as foll20.4 i6 r6 r6 l6 il or t6 i6 t6 l6 r6 l6 i6 l6 l6 t6 i6 t6 l6 r6 l6 i6 t6 r6 l6 i6 i6 s6 r6 f6 I rtify newed I i6 t6 r6 f6 l6 r6 r6 i6 t6 Case Document Page1 of s6 NY UDG8.1 AN URT DNY YOR5.4 DNY YOR5.4 CIT4.9 udge4.5 re ns10 how9.8 __ Case Document Page1 of __ ng ng ng on __ ng __ ng __ i s6 a nd doc4.5 no ubm5.1 doc4.5 nd ill-30 by bove4.4 doc4.5 ng lt nqui20.3 ng Case Document Page2 of s6 NY RA ANN UDG8.1 AN URT DNY YOR5.4 DNY YOR5.4 CIT4.9 udge4.5 re ns10 how9.8 __ Case Document Page1 of __ ng __ ng us10 ng on __ ng __ ng __ __ nd doc4.5 s6 s6 no ubm5.1 doc4.5 nd ill-30 by bove4.4 doc4.5 ng lt nqui20.3 ng Case Document Page2 of Case Document Page1 of NOTICE OF APPEARANCE FOR SUBSTITUTE ADDITIONAL OR AMICUS COUNSEL Short Title United States of America Maxwell Substitute Additional or Amicus Counsels Contact Information is as follows Name David Oscar Markus Firm Markus/Moss PLLC Address NW Third Street PH Miami Florida Docket No Telephone Fax E-mail dmarkus markuslaw.com Appearance for Ghislaine Maxwell party designation Select One counsel replacing lead counsel name firm counsel replacing other counsel __ name/firm Additional counsel co-counsel with Christian Everdell/Cohen Gresser LLP name firm JAmicus in support of party designation CERTIFICATION I certify that Ir am admitted to practice in this Court and if required by Interim Local Rule a have renewed my admission on OR Di applied for admission on Si natm ofC unse Type or Print Name David Oscar Markus Vj.QW?O?Ƽ3c t??q?a?SIp0 عG p?NʣO??tGƎ??6 oI??h W?k??c?x??c??iIp L?4?Mw _B Qn Pa s?oѸ m??jaj wM 7v?g l?j 1m t??Yj p?M?ŻyGo i?5z?i?k V?ng w2?Yc Cq f/Љ ͼi?o J.swr??R I R?;S?d eE/Jf?n?x??Kǻq?N?cJ5i V??v?N 5n kr?i??p hD S?S oʶ?y??ga I?S qԦ O0 θ?2ne p?c?K F?ʨ?Iq鿜?ߔ?W B;J y?fz??c 8_ MR O?r0?ga S?QIF S?VrM??,?ŷ??SKp q??a QU?7?t?f Vu S?F z?t??f tr έY?k cu O?i?f כq?3 DxN?k I?mN_ 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Motion for Release on Bail Doc NW Third Street Ph Miami Florida Ghislaine Maxwell Maurene Comey Alison Moe Lara Pomerantz Alison Nathan
