EFTA00030934.pdf

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pdf

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data-set-8

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Extracted text

COHEN & GRESSER LLP 
December 28, 2020 
BY EMAIL. 
United States Attorney's Office 
Southern District of New York 
1 St. Andrew's Plaza 
New York, NY 10007 
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 
Dear Counsel: 
800 Third Pianos 
New York, NY 10022 
♦1 212 957 7600 phono 
www colsmipossoo corn 
On behalf of our client, Ghislaine Maxwell, we hereby request that the government file a 
Bill of Particulars pursuant to Rule 7(f) of the Federal Rules of Criminal Procedure. Please let us 
know by January 4, 2021 whether it will be necessary to raise any aspect of this request with the 
Court. 
We request clarification of the allegations specified below in order to permit Ms. Maxwell 
to prepare her defense and avoid unfair surprise at trial. See United States v. Bortnovsky, 820 F.2d 
572, 574 (2d Cir. 1987). The Superseding Indictment does not sufficiently inform Ms. Maxwell of 
the specific conduct of which she is accused. Accordingly, we request the following particulars 
regarding the indicated paragraphs of the Superseding Indictment: 
I. Please provide the full names and full birthdays of the individuals identified in the 
Superseding Indictment as Minor Victims-1-3 
7, II, 13, 17, 19). 
2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or 
interacted with Minor Victim-1 
7a). 
3. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed" 
Minor Victim-1 "to engage in sexual acts with Epstein" (¶ 7a). 
4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually 
abused Minor Victim-1 
7a). 
EFTA00030934


December 28, 2020 
Page 2 
5. Please identify the dates when, and locations where, Ms. Maxwell allegedly "was 
present for and involved in" Epstein's sexual abuse of Minor Victim-1 (¶ 7a). 
6. Please identify the dates when, and locations where, Minor Victim-1 participated in 
"group sexualized massages" of Epstein (1 7a). 
7. Please describe with particulari…

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