DOJ-OGR-00004270.pdf

--- Page 1 --- The extracted text is: **PRELIMINARY STATEMENT** Ghislaine Maxwell respectfully submits this Omnibus Memorandum in Support of her Supplemental Pretrial Motions Related to the S2 Superseding Indictment ("Motion"). For the reasons set forth below, Ms. Maxwell moves the Court to: 1. Dismiss Counts One, Three, Five and Six for breach of the Non-Prosecution Agreement; 2. Dismiss Counts Five and Six for violation of the Double Jeopardy Clause; 3. Dismiss Counts Five and Six as time-barred under the statute of limitations; 4. Dismiss Count Five and Either Count One or Count Three as multiplicitous; 5. Dismiss the S2 Indictment for pre-indictment delay; 6. Order a Bill of Particulars as to Counts Five and Six; 7. Order the government to produce Accuser-4's prior statements as Brady material. The S2 Superseding Indictment ("S2 Indictment") demonstrates just how far the government is willing to go to "get" Ms. Maxwell and disingenuously blame her for the crimes of Jeffrey Epstein. No longer content to charge a 25-year-old case based on purported conduct in the 1990s, the government now sweeps in the 2000s through the allegations of one person—Accuser-4. But Accuser-4 is not a new witness; she first levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three-year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And remarkably, although interviewed just a few years after she claims any misconduct occurred, Accuser-4 never implicated Ms. Maxwell. Instead, she reported **Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 5 of 32** **Accuser-4 is identified in the S2 Indictment as Minor Victim-4.**