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METRO 
New Jeffrey Epstein accuser says he molested her at 13, told her to 
wear children's underwear 
By Emily Saul 
Jeffrey Epstein 
AP 
January 18, 2020 I 12:04am I Updated 
A woman claiming she was Jeffrey Epstein's "first-known victim" says she was sexually abused by the now-dead pedophile 
-
who called himself her "Godfather" -
when she was 13 years old. 
Jane Doe met Epstein and his friend, Ghislaine Maxwell, in the summer of 1994 at Michigan's lnterlochen Arts Camp, where 
she was in voice training, according to newly filed court papers suing Epstein's estate and Maxwell. 
The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all 
the while grooming her for abuse, the Manhattan federal court suit says. 
Epstein "started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of letting Doe pick out 
clothes she wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear," the suit says. 

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She was first allegedly abused in a pool house that same year when Epstein pulled her onto her his lap and began 
masturbating -
claiming this was what "professionals" did. 
The attacks escalated, the court papers claim. The financier would regularly sexually assault her and force her to perform 
sex acts in Palm Beach, New York City and his New Mexico ranch, always traveling to the locations on his private plane 
dubbed the "Lolita Express." 
At 16, Epstein put Doe up in one of his apartments in New York City -
near his own townhouse, where he would allegedly 
rape her the next year. 
5114159 
Feds finally start 
investigating Jeffrey 
Epstein's gal pal Ghislaine 
Maxwell 
"In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York, Epstein asked 17-year-old Doe if she had 
a boyfriend. Doe replied that she did not," the lawsuit reads. "Epstein responded that when she did have a boyfriend she 
would want the sex to be 'good' and that she should 'get it over with already,' meaning lose her virginity." 
"Despite Doe's resistance, Epstein then pushed Doe down onto her stomach and raped her. From that point forward for 
several years in New York, Epstein raped Doe on multiple occasions," the papers claim, noting Maxwell was often present 
when the abuse took place. 
The court papers also claim Epstein introduced her to President Trump when she was 14 years old, allegedly elbowing 
Trump and saying, "This is a good one, right?" 
"Trump smiled and nodded in agreement," the suit states. 
A spokesperson for the president did not immediately return a request for comment. 
Doe is suing Epstein's estate, alleging sexual assault, sexual battery, false imprisonment and other charges. Her complaint 
joins over a dozen filed by other women claiming they were trafficked and abused by the multi-millionaire. 
Epstein was found dead in his jail cell in August while awaiting trial ...

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NEWS 
Epstein, Maxwell wanted me to have surrogate baby: Virginia 
Roberts 
By Post Staff Report 
Virginia Roberts Giuffre 
William Farrington 
March 22, 2020 I 3:24pm 
Former teen "sex slave" Virginia Roberts Giuffre says she finally fled Jeffrey Epstein and Ghislaine Maxwell after three years, 
when they asked her, at age 19, to bear their surrogate baby. 
Epstein's former gal pal 
sues his estate 

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The latest creepy allegation by Giuffre, who has also accused Epstein of pimping her out to Prince Andrew when she was 
just 17, was revealed by her attorney, Bradley Edwards, in his new memoir, "Relentless Pursuit." 
"It was the final straw," Edwards writes in an excerpt published in the Daily Mail. 
"She knew she had to escape." 
FILED UNDER 
GHISLAINE MAXWELL, JEFFREY EPSTEIN, PRINCE ANDREW, VIRGINIA ROBERTS, 3/22/20 

March 28, 2020
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year-old-girl-naked-massage-victims-
lawyer-says.html
Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a
naked massage while Jeffrey Epstein watched,' lawyer who
dedicated his life to nailing Prince Andrew’s paedophile friend
claims in new book
Ghislaine Maxwell, 58, allegedly sexually assaulted 16-year-old Annie
Farmer
It reportedly happened at paedophile Epstein's 7,500-acre New Mexico
ranch 
A lawyer for more than 20 of Epstein's victims has made the allegation 
By Mark Hookham For The Mail On Sunday
Published: 18:03 EDT, 28 March 2020 | Updated: 15:59 EDT, 2 July 2020
e-mail
713 shares
Socialite Ghislaine Maxwell allegedly groped a teenage girl during a naked massage while
paedophile Jeffrey Epstein watched, a new book claims.
Maxwell, 58, allegedly sexually assaulted 16-year-old Annie Farmer at Epstein’s 7,500-acre
ranch in New Mexico, according to the book by Bradley Edwards, a lawyer for more than
20 of Epstein’s victims.
The book, from which we are summarising stories in The Mail on Sunday, details
Maxwell’s alleged role in recruiting and grooming underage girls for Epstein. According to
some accounts, she was even involved in some of the abuse herself.
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Ghislaine Maxwell, 58, attending to an Alzheimer's Association event in New York in 2010
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It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for
months, has never been charged with any wrongdoing. She has always maintained that
allegations against her are abhorrent and untrue.
The book also claims that:
Maxwell, Epstein’s ex-girlfriend, was at the wedding of former US President Bill
Clinton’s daughter Chelsea in July 2010, a year after Epstein was released from jail as
a convicted sex offender;
She loved to take nude photographs of girls and allegedly took many of the pictures
displayed on the walls of Epstein’s mansions.
According to one witness, she felt ‘indebted’ to Epstein for helping her following the
mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell;
Epstein ‘wasn’t beyond killing someone’ to keep his sex addiction alive, the witness
claimed.
Annie Farmer, now 40, helped keep Epstein behind bars last July after giving evidence
about her ordeal as a teenager during a bail hearing. The financier was found dead in his
cell the following month. Ms Farmer is now suing Epstein’s estate and Maxwell in the New
York district court for damages.
According to Ms Farmer’s testimony, detailed in the book, she was flown to the financier’s
vast Zorro Ranch after he offered to pay for her to attend a summer educational
programme in Thailand.
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Prince Andrew pictured with his arm around Virginia Roberts, who has accused the
Queen's 'favourite son' of having sex with her
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NEWS 
When will feds arrest Jeffrey Epstein 'fixer' Ghislaine Maxwell? 
By Ben Feuerherd 
Jeffrey Epstein and Ghislaine Maxwell 
Patrick McMullan via Getty Images 
May 28, 2020 I 4:17pm I Updated 
Nine months after Attorney General William Barr warned that Jeffrey Epstein's co-conspirators "should not rest easy," the 
pedophile's alleged madam, Ghislaine Maxwell, remains at large -
and is using a potential criminal investigation to thwart 
civil action against her. 
Maxwell is currently a co-defendant in several civil cases brought by alleged Epstein sex-trafficking victims. 
Among them is Annie Farmer, who claims in her suit against Maxwell and the proprietors of Epstein's estate that she was 
lured to his New Mexico ranch as a teenager and sexually abused by the pair. 
According to the suit, Maxwell allegedly forced Farmer to undress in view of Epstein after promising to give her a massage. 
"Maxwell touched intimate parts of Annie's body against her will for the sexual benefit of 
Maxwell and Epstein," the suit states. "Maxwell exposed Annie's breasts and groped her," it adds. 

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Through her attorney, Farmer has sought to depose Maxwell and have her respond to written questions related to the 
alleged sexual abuse. 
~ Ghislaine Maxwell 
Paul Bruinooge/Patrick McMullan via Getty Images 
But the former fixer has successfully dodged a grilling in the case, citing an ongoing criminal investigation into co-
conspirators of Epstein -
all while not admitting she herself is being probed by the feds. 
An investigation into Epstein's accomplices was alluded to by Barr days after the pedophile's suicide in a Lower Manhattan 
lockup, and has been mentioned repeatedly by the US Attorney's Office in New York, according to court filings. 
A spokesperson for the Southern District of New York declined to comment on the investigation. 
Maxwell's attorney cited the investigation in an effort to block her testimony in the Farmer case. 
1114119 
Ghislaine Maxwell wins 
questioning delay in sexual 
battery suit 
"The Southern District of New York has publicly and repeatedly announced its 'ongoing' criminal investigation into alleged 
Epstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May 13 letter to 
Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. 
"Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investigation could impair 
her Fifth Amendment privilege against self-incrimination," added her attorney, Laura Menninger. 
Farmer's attorney, David Boies, noted in his response that Maxwell has not publicly admitted she herself is the center of a 
federal investigation, but is nevertheless using it to shield herself. 
"Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators, 
the status of the investigation, or even disclosed whether she herself is a target of the Southern District's inv...

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"When Plaintiff's counsel asked Maxwell's counsel for information about the criminal investigation during their meet and 
confer, Maxwell's counsel refused to provide any details," he added. 
Freeman agreed Maxwell could potentially incriminate herself by giving a deposition and ordered that she not be required 
to sit for one as part of the suit. 
-
ADVERTISEMENT -
[): 
the $570 single speed 
tokyoblke 
Maxwell, who is apparently in hiding, has not given testimony or a public statement since Epstein's arrest and suicide. 
Attorneys for Farmer and Maxwell did not immediately respond. 
FILED UNDER 
GHISLAINE MAXWELi. JEFFREY EPSTEIN, LAWSUITS, SEX TRAFFICKING, WILLIAM BARR, 5/28/20 

June 3, 2020
Ghislaine Maxwell felt no guilt in procuring girls for
Jeffrey Epstein, claims friend
dailymail.co.uk/femail/article-8384165/Ghislaine-Maxwell-felt-no-guilt-procuring-girls-Jeffrey-Epstein-claims-
friend.html
US_based Christina Oxenberg, 57, has spoken out in new documentary
Claims Ghislaine Maxwell felt 'no guilt' in procuring girls for Jeffrey Epstein
Maria farmer reveals she 'feared for her life' at the hands of Epstein and
Maxwell 
Who Killed Jeffrey Epstein? premieres at 11pm Saturday 6th June on Quest
Red and dplay
e-mail
592 shares
Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey Epstein to satisfy his
'incredible sex drive,' Prince Andrew's distant cousin has claimed - adding that 'if anything,
she was proud.'
In Quest Red's new true crime documentary special Who Killed Jeffrey Epstein? it is
alleged that socialite Ghislaine Maxwell - Epstein's former partner - procured girls for
Epstein to 'satisfy his insatiable sex drive.'  
Socialite writer Christina Oxenberg, 57, from the US, who is a friend of Maxwell, notes that
Maxwell felt no guilt in procuring girls for his pleasure. 
'She says he has an incredible sex drive, he has to have three orgasms a day, so I help him
out by bringing in the females,' explains Christina. 'She felt no compunction about telling
me this, if anything she was proud.'
Christina is the daughter of a Serbian princess and sister of the Hollywood actress,
Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex
cult run by its leader, Keith Raniere, after an 18 month battle.
India was among the women he recruited under the guise of offering them self-help
courses. Her actress mother pulled her out of it in 2018 after fighting relentlessly in the
press to expose Raniere and his practices. 
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Christina Oxenberg claims that Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey
Epstein to satisfy his 'incredible sex drive' in Quest Red's new true crime documentary
special Who Killed Jeffrey Epstein?
Jeffrey Epstein and Ghislaine Maxwell attend de Grisogono Sponsors The 2005 Wall
Street Concert Series Benefitting Wall Street Rising on March 15, 2005 in New York
2/12
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Prince Andrew and Virginia Roberts, aged 17 at Ghislaine Maxwell's townhouse in London,
Britain on March 13, 2001
The documentary dives headfirst into the Epstein story, examining the mysterious
circumstances surrounding the financier's death, aiming to answer one vital question: Did
Epstein take his own life, or was it something much more sinister?
On 10th August 2019, disgraced American financier Jeffrey Epstein was found dead in his
New York prison cell as he awaited his trial on sex trafficking charges. 
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It was a dramatic end to one of the world's most mysterious billionaires, with the coroner
officially ruling the cause of death as suicide. 
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But it wasn't long before the circumstances surrounding Epstein's death were
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lbe Wasbington Jlost 
Democracy Dies in Darkness 
Ghislaine Maxwell, longtime associate of Jeffrey 
Epstein, charged in sex abuse case 
By Shayna Jacobs and Devlin Barrett 
July 2, 2020 at 3:14 p.m. MDT 
NEW YORK- Ghislaine Maxwell, a longtime confidante of sex offender Jeffrey 
Epstein, was arrested Thursday in New Hampshire on charges she recruited and 
groomed underage girls for abuse by her then-boyfriend, officials said. 
Support our journalism. Subscribe today. ➔ 
A grand jury indictment unsealed Thursday charged Maxwell, daughter of the late 
media tycoon Robert Maxwell, with perjury and conspiring to entice minors to 
travel to engage in sex acts. 
Maxwell has been under investigation for months as a possible accomplice to 
Epstein's history of sexual abuse of underage girls. Epstein, who committed suicide 
while in federal custody last summer, dated Maxwell for years, and the indictment 
charges she played a key role in grooming girls for him to abuse. 
AD 

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Beginning in at least 1994, the indictment alleges, Maxwell "enticed and groomed 
multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of 
means and methods." 
Acting U.S. Attorney Audrey Strauss called the sex abuse described in the Maxwell 
case "the prequel" to the charges they lodged last year against Epstein covering 
alleged acts of abuse in the early 2000s. 
"Maxwell played a critical role in helping Epstein to identify, befriend, and groom 
minor victims for abuse," said Strauss, who oversees the federal prosecutor's office 
in the Southern District of New York. "In some cases, Maxwell participated in the 
abuse herself." 
A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages 
seeking comment. 
David Boies, who along with Sigrid Mccawley represents a dozen of Epstein's 
accusers, said their clients were elated by the development. "It's just an enormous 
step," he said. 
AD 

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Boies said he thinks Maxwell will be under "tremendous pressure to cooperate" as 
she looks for ways to shave time off what may be a significant prison sentence. 
Maxwell could potentially help prosecutors shed light on Epstein's dealings with 
other wealthy and influential people who may have had encounters with underage 
victims, he said, adding, "There were a lot of people with a lot of public stature ... 
who were involved with Epstein." 
"The pain [Maxwell] has caused will never go away but today is a step toward 
healing," Mccawley added in a statement, praising prosecutors on the case for their 
"unrelenting courage." 
U.S. Magistrate Judge Andrea Johnstone ordered Maxwell to remain in custody at a 
brief hearing via videoconference in federal court in New Hampshire, where 
another of her attorneys, Lawrence Vogelman, did not seek an immediate bail 
hearing because her lawyers plan to make those arguments after she is transferred 
to New York. 
AD 

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In a court filing, prosecutors said Maxwell should stay behind bars pending trial 
because she might flee given her "extensive international ties," noting she has 
citizenship in two countries and three passports in her name. Maxwell, 58, faces the 
possibility of 35 years in prison if convicted and has "absolutely no reason to stay in 
the United States," prosecutors argued in the filing. 
Prosecutors also said the Epstein investigation is not over and asked any victims or 
witnesses to Epstein's abuse of minors to contact the FBI. 
William Sweeney, head of the FBI' s New York office, called Maxwell "one of the 
villains" of the Epstein saga and said that agents kept close tabs on her after she 
"slithered away to a gorgeous property in New Hampshire." 
AD 
The indictment charged that Maxwell "would try to normalize sexual abuse for a 
minor victim by, among other things, discussing sexual topics, undressing in front 

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of the victim, being present when a minor victim was undressed, and/ or being 
present for sex acts involving the minor victim and Epstein." 
One of the victims was 14 years old when Epstein and Maxwell began grooming her 
for sex acts with Epstein, according to the indictment. 
The victims were groomed or abused at a number of Epstein's luxurious homes, 
including his sprawling Upper East Side townhouse in Manhattan, an estate in 
Palm Beach, Fla., a ranch in Santa Fe, N.M., and Maxwell's home in London, 
according to the charges. 
"Minor Victim-2," according to the indictment, was under 18 when she was flown to 
New Mexico at Epstein's invitation. "In New Mexico, Maxwell began her efforts to 
groom Minor Victim-2 for abuse by Epstein by, among other things, providing an 
unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless," 
the indictment charged. 
Maxwell is also accused of grooming and befriending a third victim, whom she met 
in London between 1994 and 1995. She allegedly encouraged that victim to give 
Epstein massages "knowing that Epstein would engage in sex acts with Minor 
Victim-3 during those massages." 
The indictment also accuses Maxwell of lying in a deposition in 2016 when asked 
about these activities by a lawyer for one of Epstein's alleged victims, when she 
denied any knowledge of him engaging in sex acts with minors. When asked if 
Epstein had a scheme to recruit underage girls for sexual massages, Maxwell 
replied, "I don't know what you're talking about," the indictment says. 

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AD 
Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and 
others in the deposition because the truth "was almost unspeakable - Maxwell 
enticed minor girls, got them to trust her, then delivered them into the trap that she 
and Epstein had set for them. She pretended to be a woman they could trust, all the 
while she was setting them up to be sexually abused by Epstein." 
Maxwell's arrest was first reported Thursday by NBC News. 
Epstein, 66, was a registered sex offender who was arrested last year on federal sex 
trafficking charges for alleged abuses of underage girls in New York and Florida. 
His suicide in a Manhattan federal detention center led to charges against two of his 
guards who were accused of failing to check on him in his cell in the hours before he 
was found hanging from a bedsheet. 
Epstein's ability to avoid a lengthy prison sentence has raised questions about 
whether the wealthy, politically connected sex offender - with ties to both 
President Trump and former president Bill Clinton - was able to manipulate state 
and federal officials to go easy on him. 
Years before his 2019 arrest, Epstein had resolved similar allegations with a plea 
deal involving state charges in Florida that allowed him to spend a little more than a 
year in jail and leave daily for work - an arrangement widely criticized as too 
lenient. As part of that deal, prosecutors agreed not to pursue cases against 
Epstein's associates who might have recruited girls for him. 

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AD 
Gloria Allred, a lawyer representing more than a dozen of Epstein's alleged victims, 
said her clients hope Maxwell "will be accountable if the evidence presented in 
court proves beyond a reasonable doubt that she had a role in assisting and 
recruiting young girls to be sex trafficked and sexually victimized by Jeffrey 
Epstein." 
The investigation into Epstein's conduct continued after his jailhouse death and has 
ensnared Britain's Prince Andrew, another old friend of the late financier. 
Federal prosecutors complained earlier this year that Andrew has provided "zero 
cooperation" to authorities. 
One of Epstein's accusers, Virginia Roberts Giuffre, claims she was paid by Epstein 
for sexual encounters with the prince when she was 17. The prince has denied any 
wrongdoing. 
On Thursday, Strauss made clear prosecutors still want to talk to him. 
"We would welcome Prince Andrew coming in to talk to us," she said. "We would 
like to have the benefit of his statement." 
Epstein's alleged victims continue to pursue lawsuits against his estate, which is 
valued at hundreds of millions of dollars. 

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METRO 
Ghislaine Maxwell leaves luxe life behind for tiny jail cell in Brooklyn 
By Vincent Barone 
July 7, 2020 I 8:47pm I Updated 
Stephen Yang 
From beef bourguignon to beef jerky: Ghislaine Maxwell has traded in her palatial New Hampshire cabin for stripped-down 
confinement at Brooklyn's Metropolitan Detention Center. 
The Oxford-educated British socialite had been lying low in a million-dollar New Hampshire hideaway featuring a cathedral 
ceiling, a massive floor-to-ceiling stone fireplace and a gourmet kitchen, according to the home's listing. 
Jeffrey Epstein's alleged right-hand woman cooked stews for herself in a kitchen with two ovens, a six-burner stove and a 
luxury refrigerator. 
Maxwell, 58, on Monday was transferred to the city's largest federal jail, where she is expected to be kept in a 10-foot-by-12-
foot cell. 
The notorious facility is in the midst of a lawsuit that has sounded the alarm over its potential to foster a dangerous 
coronavirus outbreak. It's the same facility where officers last month pepper-sprayed inmate Jamel Floyd to death. 

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In January 2019, inmates went freezing for weeks when an electrical fire knocked out power in the building, an environment 
described as a "humanitarian crisis." 
The interior of the Metropolitan Detention Center 
DOJ 
Maxwell will be given a T-shirt and other basic clothing at the MDC along with a thin mattress, pillow and blanket. She may 
be allowed to have an approved religious medallion or book, such as the Bible -
but cannot have any other personal 
possessions. 
After schmoozing among the global elite, Maxwell has apparently had a difficult time socializing with her fellow inmates. One 
inmate at a New Hampshire jail where she was briefly held reportedly called her a "snooty b-h." 
Injuring a high-profile inmate like Maxwell "would be a badge of honor," former MDC warden Cameron Lindsay said. 
"You go from living a life like Maxwell to all of a sudden being in a situation where you're being strip-searched and having 
people look into your body cavities," Lindsay added. 
FILED UNDER 
BROOKLYN, GHISLAINE MAXWELi. JAIi. JEFFREY EPSTEIN, 7 /7 /20 

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VIDEO 
LIVE 
SHOWS 
2020 ELECTIONS 
CORONA VIRUS 
For Ghislaine Maxwell, Epstein's alleged 
recruiter, a private battle has become a 
public reckoning 
She has been charged with conspiring with the infamous sex offender. 
By James Hill and Pete Madden 
July 10, 2020, 2:06 AM • 11 min read 
Ghislaine Maxwell behind bars as new details emerge 
Jeffrey Epstein's ex-girlfriend Ghislaine Maxwell is accused of facilitating Epstein's sex crimes by helping him 
"recruit, groom and ultimately abuse" three unnamed teens between 1994 and 1997. 
Ghislaine Maxwell, a British socialite and longtime companion of disgraced 
financier Jeffrey Epstein, is facing a reckoning for her alleged role in 
facilitating Epstein's sexual abuse of young women. 
Federal prosecutors say Maxwell played a "key role" in a multi-state sex 
trafficking scheme, in which she not only allegedly "befriended" and later 
"enticed and groomed multiple minor girls to engage in sex acts with 
Epstein, through a variety of means and methods," but was also, at times, 
"present for and involved" in the abuse herself. 
Maxwell is scheduled to appear before a federal judge in New York on 
Tuesday, where she is expected to publicly address those allegations for the 
first time. But court filings make clear that Tuesday's hearing is only the 
latest chapter in long-running legal battles waged mostly out of public 
view. 
Maxwell has been named as a defendant in five lawsuits from alleged 
Epstein victims, and in at least three others, alleged victims identify her as 
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8 Jeffrey Epstein and Ghislaine Maxwell attend de Grisogono Sponsors The 2005 Wall Street Concert Series 
Benefitting Wall Street Rising, with a Performance by Rod Stewart at Cipriani Wall Street on. .. more 
Patrick Mcmullan/Patrick McMullan via Getty Image, FILE 
But in lawsuits several of Epstein's alleged victims tell an entirely different 
story, one that often places Maxwell in a role that was central to their abuse. 
One anonymous victim, identified only as Jane Doe, alleged that Epstein 
and Maxwell "attempted to groom and mentor" her when she was just 13 
years old. 
"They took her to movies, went shopping with her and lounged around 
Epstein's estate with her," Doe alleged in her complaint. "Epstein and 
Maxwell then started to make sexual references when they were with her." 
Ultimately, according to Doe's complaint, Maxwell "regularly facilitated 
Epstein's abuse of Doe and was frequently present when it occurred." 
+ MORE: Ghislaine Maxwell given paper clothes at correctional center to avoid 
suicide attempt: Sources 
Virginia Giuffre, Annie Farmer and another anonymous alleged victim 
identified only as Doe 1000, have alleged that Maxwell not only recruited 
girls for Epstein but, in their cases, even participated in their abuse. Giuffre 
alleged Epstein and Maxwell sexually abused her between 2000 and 2002 
and claims that she was directed to have sex with some of their prominent 
friends; Farmer alleged that Maxwell "groped her" and "touched intimate 
parts of [her] body against her will for the sexual benefit of Maxwell and 
Epstein"; Doe alleged "Epstein and Maxwell proceeded to sexually assault 
Jane Doe simultaneously and by forcible compulsion" and that Maxwell 
"forcibly penetrated Jane Doe with a sex toy." 
Maxwell has, in court filings, strenuously denied any such misconduct. 
"She absolutely denies that she participated in this or any other sexual 
abuse or traf...

Case 1:15-cv-07433-LAP     Document 1078-5     Filed 07/29/20     Page 38 of 161
8 Jeffrey Epstein and Ghislaine Maxwell attend an event in New York City, June 13, 1995. 
Patrick McMullan via Getty Images, FILE 
Following Epstein's arrest last July and his death in prison a month later, 
Maxwell's whereabouts became the subject of intense scrutiny. She sold her 
former residences in New York and London and shuttered her non-profit 
ocean conservation organization. Various press reports placed her in 
Massachusetts, California, France and Israel, and attorneys for several of 
Epstein's alleged victims struggled to locate her in order to serve their 
lawsuits. She was ultimately arrested by the FBI in Bradford, New 
Hampshire, where prosecutors say she was living at a 156-acre property, 
nicknamed "Tucked Away." 
Prosecutors are now arguing that Maxwell poses an "extreme" flight risk, 
citing her "three passports, large sums of money, extensive international 
connections." 
Maxwell is a citizen of the United States, United Kingdom and France, 
prosecutors said, and she has traveled abroad frequently within the last 
three years. Prosecutors also believe she possesses "significant sums of 
money," citing a government investigation that identified "more than 15 
different bank accounts held by or associated with the defendant from 2016 
to the present, and during that same period, the total balances of those 
accounts have ranged from a total of hundreds of thousands of dollars to 
more than $20 million." 
+ MORE: 'Truth and Lies: Jeffrey Epstein' Podcast 
As with Epstein, however, prosecutors have found the full extent of 
Maxwell's wealth difficult to determine. 

Case 1:15-cv-07433-LAP     Document 1078-5     Filed 07/29/20     Page 39 of 161
one of Epstein's primary "recruiters," claims that Maxwell, through her 
attorneys, has repeatedly denied. 
"Maxwell had no involvement in or knowledge of Epstein's alleged 
misconduct," one lawyer for Maxwell wrote earlier this year in her own 
lawsuit against the Epstein estate. 
+ MORE: As feds continue to seek interview with Prince Andrew, Attorney 
General William Barr says Jeffrey Epstein probe marches on 
In court filings related to that lawsuit, in which she claimed that Epstein 
had "promised that he would indemnify, defend, and advance any expenses 
incurred by reason of my prior employment relationship with him and his 
affiliated businesses," Maxwell contended that she had "incurred 
substantial expenses defending myself against false accusations and 
investigations." She claimed to owe more than $318,000 to a criminal 
defense firm, more than $101,000 to a civil litigation firm, and more than 
$194,000 in security and relocation costs. The estate, according to court 
records, declined to reimburse the costs. 
According to Joshua Schiller of Boies, Schiller, Flexner, LLP, a firm that 
represents three Epstein's alleged victims who have filed civil suits against 
her, Maxwell has been at the forefront of the fight with Epstein's alleged 
victims long before her recent arrest. 
"[Maxwell] has been using this Court as a sword and a shield for many 
years," Schiller wrote in a filing earlier this year, "and she, Jeffrey Epstein, 
and their other co-conspirators have attempted to thwart their victims from 
obtaining justice for decades." 
8 Ghislaine Maxwell at Spring Studios in New Yark City, Oct. 18, 2016. 
Patrick McMullan via Getty Images, File 
Maxwell, 58, is the Oxford-educated daughter of Robert Maxwell, the larger 
than life publishing baron whose rags-to-riches story captivated England. 
She lived an extravagant life among the British elite until her father's 
business ...

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"The defendant's financial resources appear to be substantial," prosecutors 
wrote, "and her numerous accounts and substantial money movements 
render her total financial picture opaque and indeterminate, even upon a 
review of bank records available to the Government." 
Brad Edwards, an attorney who represents several of Epstein's alleged 
victims, believes that there is still much more to learn about Maxwell. 
"I think that's the tip of the iceberg," Edwards told ABC News. "And I would 
expect the same thing that happened after Jeffrey Epstein was arrested. 
There's going to be a flood of calls and more information coming in." 
But her role in Epstein's story, he said, is already clear. 
"Ghislaine Maxwell created Jeffrey Epstein," Edwards told ABC News. "She 
helped to create the monster that we later understood him to be." 
0 Comments (89) J 
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In a letter to a Florida state prosecutor related to Epstein's 2008 guilty plea, 
Epstein's attorneys describe his relationship with Maxwell as one of two 
"long-term intimate relationships" Epstein had in adulthood. They met 
through mutual friends in 1991, his attorneys said, and parted "amicably" in 
2000 because "the demands of his work ... precluded a good married life 
with children." The same letter contains what purports to be a quote from 
Maxwell, in which she describes Epstein as a "thoughtful, kind, generous, 
loving man." 
Maxwell has asserted in court filings that she entered Epstein's employ in 
1999, where she remained, despite the end of their romantic relationship, 
until at least 2006. 
Maxwell's only sworn testimony on the nature of her work for Epstein can 
be found in excerpts -- unsealed by a federal court last year -- of two 2016 
depositions related to a defamation lawsuit filed by Virginia Giuffre, one of 
Epstein's alleged victims, who has accused Maxwell of recruiting her into 
Epstein's alleged child trafficking scheme, an accusation Maxwell denied. 
0 
Truth and Lies: Jeffre 
More than a decade ago, mysterious f 
According to Maxwell's testimony, she was responsible for the staffing and 
management of Epstein's various properties. 
"There were six homes," Maxwell said. "I hired assistants, I hired architects, 
I hired decorators, I hired cooks, I hired cleaners, I hired gardeners, I hired 
pool people, I hired pilots, I hired all sorts of people." 
"A very small part ofmy job," she added, "was from time to time to find 
adult professional massage therapists for Jeffrey." 
She denied, under oath, that she had ever hired underage girls to work for 
Epstein, assertions that are now the subject of perjury charges. 
"As far as I'm concerned, everyone who came to his house was an adult, 
professional person," Maxwell said. "I am not aware of teenagers who 
worked...

July 11, 2020
'I'm no Cruella de Vil': Ghislaine Maxwell insists she is
not an 'evil villain'
dailymail.co.uk/news/article-8513675/Im-no-Cruella-Vil-Ghislaine-Maxwell-insists-not-evil-villain.html
Maxwell says she is not the 'cartoon caricature of a villain’ she is portrayed
as
The 58-year-old is scheduled to appear before a judge in New York on
Tuesday
She will be charged with procuring girls as young as 14 for Jeffrey Epstein
e-mail
635 shares
Defiant Ghislaine Maxwell has rounded on her accusers, insisting that her portrayal as a
‘cartoon caricature of a villain’ is utterly false.
Friends say that the 58-year-old socialite, who is scheduled to appear before a judge in
New York on Tuesday to be formally charged with procuring girls as young as 14 for Jeffrey
Epstein – the serial paedophile and her former boyfriend – ‘is no Cruella de Vil’.
Referring to the glamorous but evil character from the Disney film One Hundred And One
Dalmatians, one friend told The Mail on Sunday: ‘This cartoon caricature of a villain she is
being painted as is utterly untrue and false. 
'This is a real human being with real feelings.’
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Ghislaine Maxwell, 58, has rounded on her accusers, insisting that her portrayal as a
‘cartoon caricature of a villain’ is utterly false
Breaking a year-long silence since Epstein’s death, sources close to Maxwell have gone on
the offensive to put her side of the story. 
After a year during which she was neither seen nor heard, her allies now reveal how she
intends to salvage her liberty and reputation against claims that she supplied depraved
Epstein with young girls.
Maxwell’s allies have told The Mail on Sunday that she:
Is not the person who introduced billionaire Epstein to Prince Andrew;
Fears dying of Covid-19 while in prison;
Insists she and Epstein had not met in person for 15 years;
Weeps over friends who have lost jobs because of their association with her;
Has not had a haircut in a year and is being moved ‘from cell-to-cell’ for her own
safety.
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Maxwell is scheduled to appear before a
judge in New York on Tuesday to be
formally charged with procuring girls as
young as 14 for Jeffrey Epstein – the serial
paedophile and her former boyfriend
The daughter of the late newspaper tycoon
Robert Maxwell will make global headlines
on Tuesday when she appears in court via
remote link from her New York jail cell. 
She will be formally charged with sex
offences between 1994 and 1997 and will
plead not guilty to them all. Her lawyers will
argue for her release from the high-security
Metropolitan Detention Center in Brooklyn
on £4 million bail, arguing that her life is in
danger from coronavirus and ‘multiple and
credible’ death threats.
Maxwell, who is a long-time friend of Prince Andrew and who saw him most recently in
2019, was arrested at her £800,000 New Hampshire hideaway on July 2.
Prosecutor Audrey Strauss condemned her as ‘playing a critical role in finding and
grooming victims’, while scores of Epstein’s victims claim that she acted as his ‘madam’,
often driving from his £20 million mansion in Palm Beach, Florida, to nearby trailer parks
to ‘procure’ vulnerable young girls for the paedophile.
But last night a source close to Maxwell hit back, saying: ‘Ghislaine is no Cruella de Vil. She
is being portrayed as this evil character and a cartoon-like villain but she is nothing like
that. She is a real person and is determined to prove her innocence despite the fact that she
has been characterised as some sort of monster.’
Maxwell insists that her romance with Epstein ended in 2001 and that she did not see him
in person after 2005 when she was photographed with him at a party.
At the time, she was dating billionaire Gateway computer founder Ted Waitt.
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A source close to Maxwell hit back, saying: ‘Ghislaine is no Cruella de Vil'. Pictured: The
character played by Glenn Close in the 1996 film 101 Dalmatians
‘The reality is that Ghislaine’s relationship with Epstein ended in 2001,’ says the friend.
‘Starting in late 2002, early 2003, she was dating Ted and she loved him deeply. Epstein
kept trying to woo her back but she wasn’t interested.’
However, the friend adds, Maxwell continued to work for the twisted tycoon. ‘She hired
Epstein’s pool guys, the IT guys.
‘She managed his household. They weren’t that close. It was a professional relationship.’
When Epstein negotiated an infamous plea deal, pleading guilty to two child sex
prostitution charges in 2008 and serving just 13 months in prison – most on day release –
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July 12, 2020
Four more women accused of supplying young girls for
Epstein to abuse
dailymail.co.uk/news/article-8513823/Four-women-accused-supplying-young-girls-Epstein-abuse.html
Epstein's other 'recruiters': Four more women accused of
supplying young girls for him to abuse face probe as it's revealed
Ghislaine Maxwell moved house 36 times in a year before she was
caught
Sara Kellen, Adriana Ross, Lesley Groff  and Nadia Marcinkova are
under investigation for their role in Epstein's sex-trafficking ring,
according to reports 
The four women are accused of helping to procure and groom the girls 
In one case a previous victim went on to help groom other young women 
Ms Kellen, dubbed Maxwell's 'lieutenant', 'flew on the lolita express
almost as many times as the disgraced couple' 
Reports suggest that Ms Maxwell moved 36 times before her arrest last
week 
By Ryan Fahey For Mailonline
Published: 20:46 EDT, 11 July 2020 | Updated: 09:08 EDT, 12 July 2020
e-mail
21k shares
Four more women accused of supplying young girls for billionaire paedophile Jeffrey
Epstein to abuse are facing investigation as it's revealed Ghislaine Maxwell moved house
36 times in a year before she was caught by the FBI. 
Sara Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova are being investigated for
their alleged role in Epstein's sex-trafficking ring, according to a report in the Sunday
Telegraph. 
Ms Kellen, dubbed Ghislaine Maxwell's 'lieutenant' by Epstein's victims, is said to have
flown on the paedophile's 'lolita express' almost as many times as the disgraced couple. 
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Ms Kellen, who is said to have taken a leading role in the sex ring, and the other three
women, have previously been accused of recruiting and grooming underage girls for
Epstein to sleep with. 
One was also said to have been involved in a sexual relationship with the financier. 
2/11
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Sarah Kellen worked as an assistant for Jefferey Epstein and was named in his 2008 plea
agreement as 'potential co-conspirators'
Nada Marcinkova who now goes by Nadia, was allegedly one of Epstein's victims according
to interviews with victims back in 2005, before she began procuring girls for the
paedophile herself 
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ilttiift-1H,M 

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Ghislaine Maxwell breaks down in
tears as she is DENIED bail and must
stay locked up until her July 2021 trial
as judge rules Epstein's 'madam' has
shown 'sophistication in hiding her
finances AND herself and poses
significant flight risk'

Ghislaine Maxwell cried as she was denied bail on Tuesday, with a judge ruling she
must stay locked up until her trial in July of 2021

The British socialite, 58, pleaded not guilty to the sex trafficking charges brought
against her

She hung her head as she learned her fate, wearing a prison-issued brown top and
with her normally short hair now long and swept back into a bun

Judge Alison Nathan ruled Maxwell was a significant flight risk, citing her
'substantial international' ties and 'extraordinary financial resources'

Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey
Epstein to abuse between 1994 and 1997

She had offered a $5 million bond co-signed by two of her sisters and backed up
by more than $3.75 million in property in the UK

Prosecutors fought for no bail, presenting evidence that she is 'skilled at living in
hiding', citing her three passports and claimed she is worth more than $10M

They said Maxwell refused to open the front door to the FBI and tried to flee to
another room when they raided her $1 million home on July 2

A victim also argued she was a flight risk and wrote: 'Without Ghislaine, Jeffrey
couldn't have done what he did. She is a predator and a monster'
By CHEYENNE ROUNDTREE FOR DAILYMAIL.COM and DANIEL BATES FOR DAILYMAIL.COM
PUBLISHED: 13:21 EDT, 14 July 2020 | UPDATED: 17:20 EDT, 14 July 2020
Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay
locked up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not
guilty to the sex trafficking charges brought against her.
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The 58-year-old wiped tears away and hung her head as she learned her fate, wearing a
prison-issued brown top and with her normally short hair now long and swept back into a
bun, appearing via video link.
U.S. District Judge Alison Nathan denied Maxwell's proposal of a $5 million bond co-
signed by two of her sisters and backed up by more than $3.75 million in property in the
UK.
Maxwell's legal team had argued she would be confined to a 'luxury hotel' in the New
York area, surrender all her travel documents and be subject to GPS monitoring.
But Judge Nathan ruled the British socialite was a significant flight risk, citing her
'substantial international' ties and 'extraordinary financial resources', setting an anticipated
trial date for July 12, 2021.
Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994
and 1997, a period when she was his girlfriend.
She faces up to 35 years in prison if found guilty of the charges, as
prosecutors successfully argued that along with her three passports, connections to
some of the world's most powerful people and her own fortune of more than $10 million -
Maxwell had every incentive to try and flee.
Maxwell will now return to the fortress-like Metropolitan Detention Center in Brooklyn
where she has been given paper clothes to ensure she doesn't kill herself.
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+18
Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay locked
up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not guilty to the
sex trafficking charges brought against her
+18
But Judge Nathan ruled the British socialite was a significant flight risk, citing her 'substantial
international' ties and 'extraordinary financial resources', setting an anticipated trial date for
July 12, 2021
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+18
Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994 and
1997, a period when she was his girlfriend. She faces up to 35 years in prison if found guilty of
the charges, as prosecutors successfully argued that along with her three passports,
connections to some of the world's most powerful people and her own fortune of more than
$10 million - Maxwell had every incentive to try and flee
+18
Maxwell is currently in custody in the Metropolitan Detention Center in Brooklyn (pictured)
where she is wearing paper clothes to ensure she doesn't kill herself
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Maxwell is being closely watched as the Department of Justice wants to ensure she does
not kill herself like Epstein, who hanged himself last August while awaiting trial on sex
trafficking charges.
During the two hour and 20 minute hearing at Manhattan’s Federal Court, Maxwell
appeared via video from the Metropolitan Detention Center in Brooklyn.
The small room she was in had white walls, a white bed, a window with frosted glass and
a door at the back.
She was wearing a dark brown prison issued top and her dark hair was far longer than in
the past - she reportedly has not had a haircut in a year - and was swept behind her head
in a bun.
At the start of the hearing, Maxwell rested her elbows on a table in front of the camera
and put her head on her hands.
She appeared nervous and pensive and kept looking from side to side, as she leaned into
the camera.
Maxwell briefly spoke and only to confirm she could hear the judge and to enter her
plea by saying: ‘Not guilty, your honor’.
Her demeanor changed when prosecutor Alison Moe began outlining the allegations
against her, sitting back in her chair and bowing her head when Moe accused her of
‘sexual abuse of minors’.
With every allegation, Maxwell either scratched her face or moved her hair, but was
emotionless as victim impact statements were read aloud.
It wasn’t until Judge Nathan started reading her decision that Maxwell finally broke down.
She began moving uneasily in her chair as the judge said the evidence against her was
‘strong’.
When Judge Nathan said a ‘combination of factors’ showed she had the ‘motive and
opportunity’ to flee before her trial, Maxwell wiped a tear away.
The second tear fell as the judge said Maxwell was ‘sophisticated at hiding her financial
resources’.
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+18
During the two hour and 20 minute hearing at Manhattan’s Federal Court, Maxwell appeared via
video from the Metropolitan Detention Center in Brooklyn. She was wearing a dark brown
prison issue top and her dark hair was far longer than in the past - she reportedly has not had a
haircut in a year - and was swept behind her head in a bun
+18
It wasn’t until Judge Nathan began reading her decision that Maxwell finally broke down. She
began moving uneasily in her chair as the judge said the evidence against her was ‘strong’.
When Judge Nathan said a ‘combination of factors’ showed she had the ‘motive and
opportunity’ to flee before her trial, Maxwell wiped a tear away
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For the rest of the decision, Maxwell rested her head in her hands as she had done at the
start of the hearing.
Maxwell sat though prosecutors detailing how she was 'skilled at living in hiding' and as
two victims argued she was a flight risk, with one writing: 'Without Ghislaine, Jeffrey
couldn't have done what he did. She is a predator and a monster.'
Prosecutors argued against Maxwell being granted bail, citing that due to holding both
French and British passports, she has the ability to 'live beyond the reach of extradition
indefinitely'.
Prosecutor Moe argued: 'She is good at living under an assumed identity. There really
can be no question that she can live in hiding.'
She revealed when Maxwell bought her $1 million home in Bradford, New Hampshire last
December, she toured the property with a real estate agent using an alias.
Moe said: 'The real estate agent told the FBI agent the buyers for the house introduced
themselves as Scott and Janet Marshall. Both had British accents.
'Scott Marshall told her he was retired from the British military and was currently working
on a book. Janet Marshall described herself as a journalist.'
Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea,
living at a home owned by her tech CEO lover Scott Borgerson. It is unclear if the man
who toured the New Hampshire home with Maxwell was Borgerson.
Moe also read out a victim impact statement from a woman identified as Jane Doe, who
also made the case that Maxwell was a flight risk.
The victim said she knew Maxwell for 10 years and the socialite intended to 'deliver' her
to Epstein, all the while knowing the 'heinous dehumanization that awaited me'.
The woman claimed Maxwell 'was in charge' and 'egged' Epstein on.
She described Maxwell as 'sociopathic' and said she would 'have done anything to get
what she wanted - to satisfy Jeffrey Epstein'.
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+18
Victim Annie Farmer (pictured) also spoke at the hearing, detailing how she met Maxwell when
she was 16 years old. Farmer has previously gone on record with her claims against Maxwell
+18
Prosecutor Allison Moe said when Maxwell bought her $1 million Bradford, New Hampshire
home (pictured), she toured the home back in November of 2019 using the alias of Janet
Marshall and claimed to the real estate agent that she worked as a journalist
The victim added that 'if [Maxwell] is out, I need to be protected', citing a phone call she
received in the middle of the night threatening her two-year-old child.
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Annie Farmer also spoke at the hearing, detailing how she met Maxwell when she was 16
years old. Farmer has previously gone on record with her claims against Maxwell.
She said Maxwell 'has never shown any remorse [and] tormented her survivors... She has
associates across the globe, some of great means.'
Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she
has community ties and is 'part of a very large and close family'.
He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media
spin', leading prosecutor Moe to later shoot back: 'These are the facts. It is not dirt, it is
not spin, it is evidence to the court.'
Cohen claimed Maxwell had received numerous threats and denied she had refused to
open her front door to the FBI when they raided her home on July 2.
He claimed her front door was unlocked, the windows were open and she had
'surrendered' to the agents.
Addressing reports that Maxwell had wrapped her mobile phone in tin foil, which
prosecutors called a 'seemingly misguided effort to evade detection' by law enforcement,
Cohen claimed her phone had been hacked and she had to preserve the phone as
evidence.
MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A.
Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she
is at increased risk of catching the coronavirus whilst in prison. They claim that the restrictions
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on access to her lawyers caused by the pandemic would mean it was impossible for her to get
a fair trial
+18
Also on the case is (l-r) Alex Rossmiller, Alison Moe and Maurene Comey, James Comey's
daughter
+18
Pictured: Acting United States Attorney for the Southern District of New York Audrey Strauss
speaks during a news conference to announce charges against Ghislaine Maxwell
Case 1:15-cv-07433-LAP     Document 1078-5     Filed 07/29/20     Page 76 of 161

Cohen went above the issue of Maxwell being a flight risk to complain that the charges
against her are from 25 years ago, calling the indictment 'an effort to dance around' the
controversial non-prosecution sweetheart deal Epstein and his associates received in
Florida in 2007.
With her bail now denied, Maxwell will return to the Metropolitan Detention Center in
Brooklyn.
Journalists had started lining up outside the federal court in downtown Manhattan at 6am
to get a seat inside the courtroom.
They were allowed in at 11.45am and had to stand 6ft apart while they waited to ensure
social distancing.
The hearing took place in the jury assembly room which normally has space for hundreds
of people but had a dramatically reduced capacity of just 60 due to the coronavirus.
A dial-in phone line allowed 1,000 more people to listen in - the capacity was increased
from 500 due to world-wide interest.
Inside the room there were two projector screens, which showed the proceedings live.
All parties, including the judge, appeared remotely and no one was physically in court.
Maxwell’s lawyer was visible at all times in a box on the screen. Maxwell had her own
box, the judge had one and the prosecutors had another.
Maxwell’s mugshot has not been released by the federal authorities and the hearing
offered the first chance to see her in at least a year.
Maxwell's whereabouts had largely been unknown since Epstein's arrest last July.
Although DailyMail.com tracked her down to the New England coast last summer, she
vanished again, later popping up in a photo at an In-N-Out in Los Angeles.
The FBI managed to finally trace her down in the quiet and rural town of Bradford, New
Hampshire earlier this month, where she had been living since December.
Case 1:15-cv-07433-LAP     Document 1078-5     Filed 07/29/20     Page 77 of 161

+18
Maxwell’s mugshot has not been released by the federal authorities and the hearing offered the
first chance to see her in at least a year. Maxwell's whereabouts had largely been unknown
since Epstein's arrest last July. Although DailyMail.com tracked her down to the New England
Case 1:15-cv-07433-LAP     Document 1078-5     Filed 07/29/20     Page 78 of 161
. 
erpnse 
Women: lnsp1rat1or 

coast last summer, she vanished again, later popping up in a photo at an In-N-Out in Los
Angeles
+18
Maxwell was romantically involved with Jeffrey Epstein from around 1992, but then became his
'right-hand woman', managing his property empire and, it is alleged, his trafficking of minors
Officials said her conduct during the 8.30am raid at the property called 'Tuckedaway' was
'troubling'.
They wrote that when the FBI arrived they were confronted by a locked gate which they
forced their way through.
The filing said: 'As the agents approached the front door to the main house, they
announced themselves as FBI agents and directed the defendant to open the door.
'Through a window, the agents saw the defendant ignore the direction to open the door
and, instead, try to flee to another room in the house, quickly shutting a door behind her.
Agents were ultimately forced to breach the door in order to enter the house to arrest the
defendant, who was found in an interior room in the house.
'Moreover, as the agents conducted a security sweep of the house, they also noticed a
cell phone wrapped in tin foil on top of a desk, a seemingly misguided effort to evade
detection, not by the press or public, which of course would have no ability to trace her
phone or intercept her communications, but by law enforcement'.
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After Maxwell, the daughter of late newspaper tycoon Robert Maxwell, was arrested the
FBI spoke to a security guard who worked on the property who said that her brother had
hired him from a company staffed with former British military soldiers.
The filing states: 'The guard informed the FBI that the defendant had not left the property
during his time working there, and that instead, the guard was sent to make purchases for
the property using the credit card. As these facts make plain, there should be no question
that the defendant is skilled at living in hiding'.
In their filings to the court Maxwell's lawyers had argued that she is at increased risk of
catching the coronavirus whilst in prison. So far there have only been five cases and no
deaths at the prison.
They claim that the restrictions on access to her lawyers caused by the pandemic would
mean it was impossible for her to get a fair trial.
The prosecutors said that in fact the prison had made substantial efforts to accommodate
her and keep her safe.
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Case 1:2o~cr-00330~AJN Documem 22 FHed 07/13/20 Page 2 of 1'9 
U ITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
-----·------------------·------------------·- --------------x 
U ITED ST ATES OF AMERICA 
-v.-
GHISLAINE MAXWELL, 
Defendant. 
----·-·---------------------·-·-------------------·---------------x 
20 Cr. 330 (AJ ) 
THE GOVERNMENT'S REPLY MEMORANDUM 
IN FURTHER SUPPORT OF DETENTIO 
The Government respectfully submits this reply memorandum in fmtber support of its 
motion for detention, dated July 2, 2020 (the ••Detention Memorandum'') (Dkt. 4), and in response 
lO the defendant's 1nemornndum in opposition (tile '"Opposition Memorandum") (Dkt. .18). 
The charges against Ghislaine Maxwell arise from her essential role i.n sexual -exploitation 
that caused deep and lasting hann to vulnerable victims. At the heart of this case are brave women 
who are victims of seri.ous crimes that demand justice. The defendant's motion whoUy foils to 
appreciate the driving force behind this case: the defendant's victims were sexually abused as 
minors as a direct result of Ghis]aine Maxwell's actions, and they have carried the trauma from 
these events for their entire adult lives. They deserve to see her brought to justice at a trial .. 
There will be no trial for the victims if the defendant is afforded the opportunity to flee the 
jurisdi.ction, and there is every reason to think that i.s exactly what she wil l do if sue is released. 
Fm the reasons detailed in tbe Detention Memorandum, and as farther discussed below, the 
defendant poses a dear risk of flight, and no conditions of b.til could reasonably assure her 
continued appearance in this case. Among other concerns: (l) she is a citizen of a country that 
does not extradite its own citizens· (2) she appears to have access to considerable wealth 

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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 3 of 19 
domesticaUy and abroad; (3) her finances are completely opaque, as her memorandam pointedly 
declines to provide the Court with infonnation about her financial resources; and (4) she appears 
to be skilled at living in hiding_ These are glaring red tlags, even before the Court considers the 
gravity of the charges in th is case and the serious penalties the defendant faces if convicted at trial_ 
Instead of attempting to address the risks of releasing a defendant with apparent access to 
extraordinary financial resources, who has the ability to live beyond. the reach of extradition in 
France, and who has already demonstrated a willingness and ability to liv,e in hiding, the defendant 
instead pmposes a bail package that amounts to little n1ore than an unsecured bond. Among other 
things, the proposed bai] package contemplates the defendant pledging as the sole security a 
properly that is beyond the territmy and judicial reach of tl1e United States, and whi.ch therefore is 
of no value as coUateraL She proposes six unidentified co-signers, an unknown number of whom 
even reside jn the United States, and none of whose assets are identified_ The Court and the 
Government have no infonm1tion whatsoever regarding whether these co-signers would be ahle to 
able to pay the proposed $5 million bond should the defendant flee - or i.f, of equa] concern, the 
co-signers are themse]ves so wealthy that it would be no financial burden whatsoever to do so_ 
The defendant does not identify what residence she proposes to live at in the Southern District of 
ew York, nor does she identify any meaningful ties to the area. And most iu.1portantly, the 
defenda:nt s memorandum provides the Conn with no information whatsoever about her own 
finances or her aocess to the wealth of others, declining to provide the Court the very infommtion 
that ...

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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Pa:g.e 4 of 19 
Finally, the Government recognizes that the COVJD-]9 pandemic is - and should be - a 
relevant factor for the Court and the parties in this case. However, the Bureau of Prisons (''BOP'') 
is taking very significant steps to address that concern, and the defendant has offered no reason 
why she should he treated any differently from the many defendants who are currently detained at 
the Metropolitan Detention Center ("MDC") pending trial, induding defendants who have medical 
conditions that place them at heightened ri.sk Inmates at the MDC are able to ass.ist .in their own 
defense, especiaUy long before trial, through established policies and procedures applicable to 
every pretrial detainee. This defendant should not be granted the spec ia] treatment she requests. 
The defendant faces a pr.esumption of detention. she has significant assets and foreign ties, 
she has demonstrated her ability to evade detection, and the victims of the defendant's crimes seek 
ber detention. Because there is no set of conditi.ons short of incarceration that can reasonably 
assure the defendant's appearance, the Government urges the Court to detain her. 
ARGUMENT 
Each of the relevant factors to be considered as to flight risk- the nature and circumstances 
of the offense, the strength of the evidence, and the history and characteristics of the defendant -
weigh strong]y in favor of detention, and the defendant's proposed package would do absolutely 
nothing to m higate those risks. 
L 
The Defendant's Victims Seek DetentioH 
As the Comt is aware, pursuant to the Crime Victims' Ri.ghts Act ("CVRA''}, a crim.e 
victim has the right to be reasonably heard at ce1ta:in public proceedings in the district court, 
including proceedings involving release. rn U.S. C. § 3 771 ( a)( 4 ). 
Consistent with that 
requirement, the Government has been in c...

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their client opposes hail for the defendant, and ha:s asked the Government to convey that view to 
the Court. The Government also ex.pe,cts that one or more victims will exercise their right to be 
heard at the July 14, 2020 hearing i.n this matter, and will urge the Court not to grant b.aiL More 
generaUy, as noted above, the Government is de,eply concerned that if the defendant is bailed, th.e 
victims will be denied justice in this case. That outoo1ne is unacceptable to both the victims and 
the Government. 
H. 
The_:G_ove£!llllenfs_,Ca,~ I~Strong 
The defendant's moti.on ar1,n1es .in a condusory fashion, that the Govermnenfs case must 
be weak because the conduct charged occurred in the l 990s. That argument, which ignores the 
many specific al.legations in the Indictment, could not be more wrong. As the superseding 
indictment (the "lndictmenf') makes plain multiple victims have provided detailed, credible 
evidence of the defendant's crin1inai conduct And while that conduct did take place a number of 
years ago, it is unsurprising that the vi.ctims have been unab1e to forget the defendanfs predatory 
conduct after all this tim.e, as traumatic chi]dhood experiences often I.eave indelible marks. The 
recollections of the victims bea:r striking l"esemblances that con-obornte each other and provide 
compelling proof of the defendant's active participati.011 in a d.faturbing scheme to groom and 
sexually abuse minor girls. In addition to compelling victim accounts as the Government has 
explained, the victims' accounts are conobornted by documentairy evidence and other witnesses. 
]n pa.rticular, the victims' accoants are suppo1ied by conte1nporaneous documents and 
records, such as fljght records diary entries,. and. business records. The powerful testimony of 
these victims who had strikingly similar experiences with Ma...

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evidence and witness testimony, wiH condusivdy establish dmt the defendant groomed the victims 
for sexual abuse by Jeffrey Epstein. 1 
The defendant's motion alludies to defenses in this case,. all of which are legal or procedural 
in nature, and none of which pass muster, let alone counsel in favor of bail. To begin with, the 
notion that the defendant is protected from prosecution by the Non-Prosecntion Agreement 
r• PA'') between Jeffrey Epstein and the U.S _ Attorney's Office in the Southern District of Florida 
(''SDFL") is absmd. That agreement affords her no protection in this District, for at ]east three 
reasons. First, the defendant was not a party to that agreement nor named in it as a third-party 
beneficiary, and the defendant offers no basis to think she would have standing to claim any rights 
under the PA. Tellingly, the defendant cites no authority for the proposition that an agreement 
she was not a party to and that does not even identify her by name could possibly be invoked to 
bar her prosecution. Second, and equally important, the ·. PA does not hind the Southern Distr.ict 
ofNewYork, which was not a party to the agreement See UniledS/ales v. A,mab;; 771 F.2d 670, 
672 (2d Cir. l 985) (per curiam) ("A plea agreement binds only the office of the Uni.ted States 
Attorney for the district in which the plea is entered unless it affirmatively appears that the 
agreement contemplates a broader restriction.''))' United Slates v. Prisco, 391 F. App'x 920, 921 
(2d Cir. 2010). This ml.e applies even when the text of the agreement refers to the signing party 
as the "Government.'' A m1abi, 771 f .2d at 672. 
Thi rd, and perlmps most important, even assuming the NP A could be read to protect this 
defendant and hind this Office, which are both legally unsound propositions, the Indictment 
1 Addiitionally~ and b...

+18
New York prosecutors said in a filing Monday this was evidence that Maxwell was 'skilled at
living in hiding' and should be denied bail
+18
Her bail request (pictured) was filed in the US District Court in Manhattan and claims she was
not 'hiding' from authorities, is not a flight risk and is at risk of contracting COVID-19 if she
continues to be held in the Brooklyn jail
The case against her is 'strong' and multiple victims have provided 'detailed, credible
evidence of the defendant's criminal conduct' - with more women coming forward in the
past week.
The victims have made clear they want Maxwell remanded in custody and say they were
'directly abused as a result of Ghislaine Maxwell's actions'.
The document states: 'While that conduct did take place a number of years ago, it is
unsurprising that the victims have been unable to forget the defendant's predatory
conduct after all this time, as traumatic childhood experiences often leave indelible marks.
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Pt· ipo. '!d Bail 
·n 'flioits. In ligt t f tJ 
• \ 
prop 
th • oU wino• b ·1 
comlitions_ whiah are comfr lent. v.i.t:h tl se th · t ourls in this , ircuit ha e imposed in amtlogous 
le aU o wh m have stron tics to 
. Maxw ll, and secured b nra.l property in lb 
nitoo 
of 
I docum nts wilh no De'\ 
·mmediai 

'The recollections of the victims bear striking resemblances that corroborate each other
and provide compelling proof of the defendant's active participation in a disturbing
scheme to groom and sexually abuse minor girls'.
The prosecutors said that it was 'curious' that Maxwell claimed to have access to millions
of dollars had not offered 'a single dime' as collateral for her bond.
They claimed that Maxwell's finances were 'completely opaque' and she had not even
indicated which properties she would use for her bond.
Some of the co-signers are 'themselves so wealthy that it would be no financial burden
whatsoever' if they lost their $5 million by Maxwell skipping bail, the document states.
Epstein's victims have long demanded Maxwell's arrest and lawyers for them say that a
slew of new accusers have come forward since she was apprehended.
Prosecutors will likely be looking to do a plea deal with Maxwell to lighten some of the six
charges against her, two of which are perjury for allegedly lying during depositions.
They will be questioning her about powerful men in Epstein's orbit including Bill Clinton
with whom she flew on Epstein's private jet, called the 'Lolita Express', on a tour of Africa
in 2002.
Maxwell was also good friends with Prince Andrew and one of Epstein's victims, Virginia
Roberts, claims she was loaned out to the Duke three times for sex when she was 17.
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July 15, 2020
Ghislaine Maxwell's attack-the-victim strategy may
backfire
bnnbloomberg.ca/ghislaine-maxwell-may-play-the-victim-card-in-trial-defense-1.1465631
Ghislaine Maxwell Photographer: Laura Cavanaugh/Getty Images , Photographer: Laura
Cavanaugh/Getty Images
The bail hearing for Ghislaine Maxwell ended with a judge ruling that she must spend the
next year behind bars awaiting trial on sex-trafficking charges tied to her former boyfriend
Jeffrey Epstein. But it also offered hints at her defense strategy.
During the two-hour video-conference hearing Tuesday, Maxwell’s lawyers questioned the
credibility of her accusers as well as the strength of the government’s case.
While the arguments were designed to win bail, they’ll likely be the same ones used at the
58-year-old’s trial, which is scheduled to start next July. The federal charges stem from
events that are more than two decades old, Maxwell’s lawyer, Mark Cohen, said, noting
that the government doesn’t have “tapes or video” or other such evidence to support the
allegations.
“Absolutely, the defense is telegraphing where they’re going,” said David Weinstein, a
former federal prosecutor who listened in on Maxwell’s hearing. “While the defense isn’t
putting all of their cards on the table, they showed they’re going to argue that she was as
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d 

much a victim of Epstein -- much in the same way as these girls were -- and that she didn’t
know what was going on behind closed doors.”
Cohen briefly took aim at Annie Farmer, one of Maxwell’s accusers. He said she has sued
Maxwell and is seeking a payout from a fund set up for Epstein’s victims, Cohen said.
Established in May, Epstein’s victims can be compensated by the financier’s estate, valued
at more than US$600 million.
That’s a dangerous tactic that might backfire at trial, said David Boies, who represents
Farmer and several other women who say they were sexually abused by Epstein and
Maxwell.
It’s “a tone-deaf argument” that cost Maxwell her credibility, said Boies, who listened to the
hearing remotely.
“To mount a ‘blame the victim’ defense, particularly in today’s world and trying to blame
these girls for what happened is so contrary to the evidence, is so contrary to people’s
normal sense of morality,” Boies said. “I think that’s just going to enrage a jury if she goes
to trial -- which I would not do if I were representing her.”
Boies said he was confident Farmer would stand up to cross-examination if there’s a trial.
Farmer, who addressed the court by telephone, urged the judge not to grant Maxwell bail,
calling her a “sexual predator who groomed and abused me.” Maxwell “lied under oath and
tormented her survivors,” Farmer said.
Boies said that Farmer was a 16-year-old who “wanted to go to college” when she met
Maxwell.
“Maxwell and Epstein tell Annie and her mother ‘we’re having a group of high school
students to this ranch to help them get into college,”’ Boies said. “But when Annie gets
there, there are no high school students, all these claims are fraudulent and she’s in this
isolated place in New Mexico.”
Remote Hearing
Because of the pandemic, Maxwell’s hearing was held remotely with press and the public
permitted to hear arguments over the phone. About 60 members of the press were allowed
to watch the proceeding on monitors in a jury room in the...

Along with Farmer’s remarks, Assistant U.S. Attorney Alison Moe read from a letter
written by another of Maxwell’s alleged victims, who asked to be identified only as Jane
Doe. It’s possible that the woman may testify at the trial as well.
“Without Ghislaine Maxwell, Jeffrey Epstein could not have done what he did; she egged
him on,” the woman said in the letter. She called Maxwell “a monster.”
The judge scheduled the trial for July 12. The defense must file its pretrial motions by Dec.
21.
--With assistance from Bob Van Voris.
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July 16, 2020
Ghislaine Maxwell's neighbours tried to make her leave
town
dailymail.co.uk/news/article-8525759/Neighbors-Ghislaine-Maxwell-lover-tried-ostracize-couple-make-leave-
town.html
Ghislaine Maxwell had been living with her tech CEO lover Scott Borgerson
at his home in Manchester-by-the-Sea outside of Boston until last December 
In February 2019 neighbors learned the quiet, well-dressed woman in their
midst had been accused of procuring young girls for pedophile Jeffrey Epstein
'They were absolutely appalled to learn who they were allowing to have the
run of their property,' one resident exclusively told DailyMail.com
Neighbors tried to harass and 'ostracize' Maxwell into leaving, and make her
and Borgerson 'feel they weren't welcome on Sharksmouth or in Manchester'
It led to a court case where Borgerson successfully fought the neighbors'
decision to stop them from using paths and a beach near the home that were
part of a 40-acre estate with other homes
A judge only made his ruling on March 11 this year, three months after
Maxwell had left Sharksmouth for good, moving to her hideaway in Bradford,
NH
Borgerson is believed to have met Maxwell six years ago through speaking
engagements connected to ocean preservation
They were both pictured speaking at the Arctic Circle Assembly in Reykjavik,
Iceland, in 2014 
Ghislaine Maxwell's neighbors were so disgusted when they discovered an accused sex
trafficker was living among them that they tried to harass her into leaving, DailyMail.com
has learned exclusively.
It led to a court case where Maxwell's 14-years-younger lover Scott Borgerson successfully
fought the neighbors' decision to prevent them from using paths and a beach near their
Massachusetts oceanfront property, part of the 40-acre estate shared by other owners.
But the decision was not handed down until after Maxwell, 58, had already left for her new
life of seclusion in neighboring New Hampshire.
The small-town dispute involving the woman who was among th...

But in February 2019 neighbors learned the quiet, well-dressed woman in their midst had
been accused of procuring young girls for pedophile Jeffrey Epstein — and they decided to
act.
'They were absolutely appalled to learn who they were allowing to have the run of their
property,' one resident told DailyMail.com.
'The second they learned she was involved with Epstein they decided to try to limit how
much they could use their land.'
Ghislaine Maxwell and Scott Borgerson's
neighbors were so disgusted when they
discovered an accused sex trafficker was
living among them that they tried to harass
her into leaving. Borgerson is believed to
have met Maxwell six years ago through
speaking engagements connected to ocean
preservation, a subject on which they share
a passion. They were both pictured speaking
at the Arctic Circle Assembly in Reykjavik,
Iceland, in 2014 (left and right)
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It led to a court case where Maxwell's lover Scott Borgerson successfully fought the
neighbors' decision to prevent them from using paths and a beach near their
Massachusetts oceanfront property. Borgerson, 44, bought the Phippin House (pictured), a
7-bedroom property, for $2.4M in June 2016, using a limited liability company called
Tidewood
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July 17, 2020
Jeffrey Epstein's victim Maria Farmer claims it was the
British socialite who always set the trap
dailymail.co.uk/news/article-8535303/Jeffrey-Epsteins-victim-Maria-Farmer-claims-British-socialite-set-trap.html
'Ghislaine Maxwell was the mastermind': Jeffrey Epstein's victim
Maria Farmer who was the first to blow the whistle on him claims it
was the British socialite who always set the trap
By Tom Leonard for the Daily Mail
Published: 17:25 EDT, 17 July 2020 | Updated: 17:25 EDT, 17 July 2020
e-mail
337 shares
For talented young artist Maria Farmer, it was the night she’d been working towards for
months — her graduation show at the prestigious New York Academy of Art.
Maria, then 25, was ecstatic, having sold all three of her exhibited paintings for five-figure
sums.
Then a senior staff member appeared at her shoulder, took her arm and pointed out two
people she’d never seen before.
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• 
• 
• 
• 

Annie Farmer outside New York court on
July 15, 2019
‘This couple here are going to buy your art . .
. they’re very important benefactors of the
academy,’ she was told.
It was Jeffrey Epstein and Ghislaine
Maxwell, and they got the painting they
wanted — a semi-naked man observing a
sleeping girl, inspired by Edgar Degas’s The
Rape — for $6,000, half the price Maria had
been offered earlier.
Fast-forward 25 years and this week Maria’s
younger sister gave an emotional statement
to a Manhattan court about why Maxwell
should not be granted bail.
Speaking via an audio feed from her home
in Texas, psychotherapist Annie Farmer,
one of three women whose claims are the
basis for the criminal case against the
British socialite, said Maxwell was a ‘sexual
predator’ who had ‘never shown any
remorse for her heinous crimes or the
devastating, lasting effects her actions
caused’.
Maria, who says she feels guilty for
unwittingly bringing her then teenage sister
into the orbit of Maxwell and Epstein, was the first person to report the pair’s alleged
sexual abuse of underage girls in 1996. But her attempts to get the police and FBI to
investigate the attack on Annie, then 16, were ignored, leaving Epstein free to pursue his
depravity.
The sisters’ story is shocking and their determination to get justice remarkable. Now, at
last, their voices are being heard. Annie’s testimony was a key factor in the judge’s decision
to deny Maxwell bail and keep her in a New York jail cell before her trial next year — which
is as it should be, Maria told the Mail yesterday.
For her, Epstein — who was found dead in his remand jail cell last year — isn’t the worst
villain in this scandal.
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‘That woman was much more sinister than Epstein, and to me, much more dangerous,’ she
says. ‘She was definitely the mastermind. She was in charge.’
Maria worked for Epstein, a financial guru, for a year, during which time she says she saw
first hand Maxwell’s astonishing charm and her terrifying viciousness.
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NEWS 
Ghislaine Maxwell was 'a sexual predator,' alleged victim says in new 
testimony 
By Isabel Vincent 
July 18, 2020 I 6:32pm 
Ghislaine Maxwell 
Patrick McMullan via Getty Images 
Ghislaine Maxwell had to find three girls a day to be sexually abused by her longtime associate, convicted pedophile Jeffrey 
Epstein, according to blockbuster new testimony by an alleged victim who has waived her anonymity in the case. 
"She was a sexual predator who abused me and countless other children and young women," Annie Farmer told a federal 
judge who denied Maxwell, 58, bail Tuesday and ordered her to spend a year awaiting trial at the Brooklyn Detention 
Center, where she has been held since shortly after her July 2 arrest in New Hampshire. 
Farmer, now 41, is believed to be one of three victims -
all of them minors at the time of the alleged abuse between 1994 
and 1997 -
in the case against Maxwell. She is is charged with helping Epstein sexually abuse girls as young as 14. If 
convicted, Maxwell faces up to 35 years in prison. 
Maxwell has denied any wrongdoing. 

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Although prosecutors have not revealed all of Farmer's evidence, details of her abuse, which began when she was 16 and 
flown to Epstein's ranch in New Mexico, were contained in a civil lawsuit filed last December. 
Papers filed in Maxwell's case on Saturday allege that "Maxwell spent years overseeing and managing Epstein's sex-
trafficking network ... Epstein's preference was to have three different girls a day for his sexual pleasure and Maxwell was in 
charge of recruiting the girls," according to a report in the Sunday Times of London. 
The documents say that Farmer's parents divorced when she was young and her "mother struggled financially to support 
Annie and her siblings". 
"Maxwell appeared charming and friendly to Annie. "Upon arriving, Maxwell and Epstein took Annie shopping and lavished 
her with gifts, including beauty products and a pair of brand new cowboy boots." Annie's older sister Maria, an artist, also 
claims that she was abused by Epstein. 
Maxwell and Epstein also took Farmer to see a movie while she was in New Mexico. While they were standing in line, 
Maxwell "pulled down Epstein's sweatpants, exposing part of his buttocks. Both Epstein and Maxwell repeatedly fondled 
each other in front of Annie, trying to normalize sexual behavior to a child." 
"Upon returning [to the ranch] from the movie, Maxwell repeatedly told Annie that she wanted to give her a massage ... 
Maxwell directed Annie to take off all of her clothes and lay on the massage table. 
1114119 
Ghislaine Maxwell's 
'lieutenant' Sarah Kellen 
may be arrested next, her 
parents fear 
"Maxwell touched intimate parts of Annie's body against her will for the sexual benefit of Maxwell and Epstein. Maxwell 
exposed Annie's breasts and groped her. Annie was extremely distressed and afraid. She was a child in a massive ranch, 
away from her family, and isolated from any source of help." 
The following mornin...

July 21, 2020
Ghislaine Maxwell paid $25k to Jacob Wohl to 'smear
victims'
dailymail.co.uk/news/article-8531293/Ghislaine-Maxwell-paid-25K-Jacob-Wohl-smear-victims-AG-fired.html
EXCLUSIVE: Ghislaine Maxwell paid $25K to fake news purveyor
Jacob Wohl to 'smear Epstein victims and to get prosecutor
Geoffrey Berman fired in attempt to stall sex trafficking
investigation against her'
Ghislaine Maxwell hired Jacob Wohl to smear alleged victims of Jeffrey
Epstein and her, a former friend told DailyMail.com in an exclusive
interview
As part of a $25k deal, Wohl and his lobbyist colleague Jack Burkman
also allegedly pushed to get former New York US Attorney Geoffrey
Berman fired 
Wohl and Burkman are far-right lobbyists who have become a laughing
stock in DC after several failed attempts to smear top political figures 
Maryland paralegal Kristin Spealman claims she was initially contacted
by the duo to use her in a smear campaign against Nancy Pelosi and Ted
Cruz
Spealman told DailyMail.com they bragged to her they had been hired in
early June for $25,000 to dig up dirt on Maxwell's alleged sex trafficking
victims
Federal documents filed this month show a company linked to Maxwell
had hired Wohl and Burkman to lobby on ‘issues relating to US DOJ,
Senate Judiciary, House Judiciary,’ DailyMail.com can exclusively
reveal  
Berman's removal was intended to stall or stop the criminal investigation
into Maxwell, Spealman said    
Berman was ultimately pushed out by Barr in June, but two weeks later
Maxwell was charged as part of Epstein's sex trafficking ring 
By Josh Boswell For Dailymail.com
Published: 09:15 EDT, 21 July 2020 | Updated: 02:55 EDT, 22 July 2020
e-mail
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6.7k shares
Ghislaine Maxwell hired fake news purveyor Jacob Wohl to smear her and Jeffrey Epstein's
alleged victims, a former friend has told DailyMail.com in an exclusive interview.
As part of a $25,000 deal made in June, Wohl and his lobbyist colleague Jack Burkman
also allegedly pushed to get New York US Attorney Geoffrey Berman, who had led Epstein's
case, fired in order to stall or stop the criminal investigation into Maxwell.  
Wohl and Burkman are far-right lobbyists who have become a laughing stock in DC after
several failed attempts to smear top political figures including Elizabeth Warren, Kamala
Harris, Nancy Pelosi, Ted Cruz, Robert Mueller and Dr. Anthony Fauci by paying women
to make false claims of sordid affairs and drug-dealing.
One of the women they tried to use for their smear plots, Maryland model and paralegal
Kristin Spealman, told DailyMail.com the men had been hired by Maxwell, who currently
faces trial over charges she and Epstein trafficked underage girls for sex.
Spealman, 36, said the lobbyists bragged to her they had been hired in early June for
$25,000 to dig up dirt on Maxwell's alleged sex trafficking victims and to get Berman fired
using Burkman’s supposed influence with Attorney General William Barr.
Berman ultimately stepped down after a push from Barr. But less than two weeks later,
Maxwell was charged on July 2 as being part of Epstein's sex trafficking ring and taken
into custody. 
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Ghislaine Maxwell hired fake news purveyor and accused felon Jacob Wohl to smear
alleged victims of her and Jeffrey Epstein, Wohl's former friend has told DailyMail.com in
an exclusive interview
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'I' '1" ..._,.~---
Getty Images 

As part of a $25,000 deal made in June,
Wohl (left) and his lobbyist colleague Jack
Burkman (right) also allegedly pushed to get
New York US Attorney Geoffrey Berman,
who had led Epstein's case, fired to stall or
stop the criminal investigation into Maxwell
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/I 
.. !r~~'-. MAUREEN CA11ANAN 
OPINION 
Authorities are letting Jeffrey Epstein's fixer Ghislaine Maxwell get 
awaywithit 
By Maureen Callahan 
June 22, 2020 I 5:00pm 
Jeffrey Epstein and Ghislaine Maxwell 
Photo by Joe Schildhorn/Patrick McMullan via Getty Images 
We got Osama bin Laden, but we can't catch a repulsive fugitive socialite? 
Since the death of sex trafficker-rapist-pedophile Jeffrey Epstein last August, the woman who allegedly recruited his many, 
many underage girls and sexually abused them herself has been in hiding. 
And Ghislaine Maxwell has hardly been moving cave-to-cave. 
Most recent reports put the 58-year-old in a luxury apartment in Paris, right off the Champs Elysees. 

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At the risk of stating the obvious, Paris, too, is on COVID-19 lockdown. The Sun reports that Maxwell is currently living on 
Avenue Matignon in the city's 8th arrondissement, in an apartment reportedly owned by a Normandy-based millionaire. 
This would put her just five minutes away from the late Epstein's own Parisian apartment, which was raided shortly after his 
suicide. 
So: where is the urgency? Why hasn't this depraved criminal suspect, one who by many credible accounts sexually abused 
minors for years, been arrested yet? 
France may not have an extradition treaty with the U.S., but that doesn't explain why French authorities haven't taken her 
into custody. It's well-known that Jeffrey Epstein was a sexual predator who knew no geographic boundaries. Maxwell 
appears to have been his madam, his pimp, his enabler, his co-conspirator, and reportedly a sexual offender herself. 
The world would be better off without her moving around in it. Yet it seems there are powerful people who disagree. What 
other explanation is there? 
Maxwell is one of the world's most wanted women, sought by the FBI for questioning. Yet before the lockdown, she was 
seen swanning around Paris, patronizing high-profile, four-star restaurants and cafes, dropping into art galleries, a scarf tied 
around her head as if she were Jackie O on Fifth Avenue. 
These are the defiant actions of a remorseless woman who knows she is well protected. Her hiding seems almost 
performative. Maxwell isn't hunkered down on a private island or on a yacht in international waters. Her whereabouts are 
well known. 
Yet we're still playing "Where in the World is Ghislaine Maxwell?" 
i;:;Luxury apartments on on Avenue Matignon in Paris where Maxwell has reportedly been living. 
Luxury apartments on Avenue Matignon in Paris where Maxwell has reportedly been living. 
Getty Images 
There's a reason conspiracy theories still swirl aro...

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And that Maxwell recruited and groomed her back in 1999, along with many other underage girls through the years. 
Maxwell doesn't even have the temerity of a Roman Polanski, who also fled to France and whose stance for decades has 
been "Yes, I raped a 13-year-old girl. Bygones." 
We are living in a fraught and electric moment, one in which all manner of injustice is no longer tolerated, protests in the 
streets day after day, forcing us to ask hard and painful questions in pursuit of a fairer and freer world. 
-
ADVERTISEMENT -
Don't let Ghislaine Maxwell benefit from this as a distraction. Make her part of it. Make her -
and whoever else, no matter 
how powerful -
pay. 
FILED UNDER 
FBI, FRANCE, GHISLAINE MAXWELL, JEFFREY EPSTEIN, PARIS, SEX TRAFFICKING, 6/22/20 

July 29, 2020
Ghislaine Maxwell latest news: Socialite and Jeffrey
Epstein said to have had ‘mysterious’ relationship over
the years
thesun.co.uk/news/12041691/ghislaine-maxwell-live-jeffrey-epstein-latest-news/
JAIL BIRD
- Who is Ghislaine Maxwell and where is she now? 
- Is Scott Borgerson Ghislaine Maxwell's husband?
- Who was Ghislaine's famous father Robert Maxwell?
- More news on Ghislaine Maxwell
Live Blog
Alex Winter
Debbie White
29 Jul 2020, 15:09
Updated: 29 Jul 2020, 15:09
Ghislaine Maxwell and Jeffrey Epstein are said to have had a “mysterious” relationship
over the years.
The two are thought to have linked up not long after she moved to New York in 1991.
One pal claims that Epstein and Maxwell were not linked romantically as has been often
reported, but instead their relationship was a financial one.
“I couldn’t work out at first how, the second Ghislaine landed in New York, she was all of a
sudden — overnight really — very chummy with Jeffrey,” the source said.
“Then he started spending on a different level, suddenly buying these extraordinary
townhouses.”
Meanwhile, Ghislaine Maxwell could strike a plea deal, exonerate Prince Andrew from any
wrongdoing and walk in a few years, according to a pal.
An anonymous friend told the Sunday Times that they expect her to get a good deal with
the prosecutors by turning on key members of the Epstein inner circle.
But the pal said Maxwell would use the deal to "exonerate" Prince Andrew of his alleged
links - with the Duke of York denying any wrongdoing.
Follow our live blog below for all the latest news and updates on the Ghislaine
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Patrick
Knox
July 24, 2020
Jeffrey Epstein rape survivor, now 22, claims
paedophile was abusing girls right up to his death
thesun.co.uk/news/12220305/jeffrey-epstein-rape-survivor-claims-billionaire-abusing-girls-right-death/
A JEFFREY Epstein rape survivor believes the warped financier was still abusing girls right
up until he was jailed and hanged himself.
The former model claimed this will leave behind a “second wave” of younger victims too
afraid to even tell their parents.
⚠️Click here for the latest news on Ghislaine Maxwell
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Jeffrey Epstein's mugshot after his arrest in 2019.... one of his victims claims he was abusing right up to
this pointCredit: AFP or licensors
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The girl alleges she was raped by Epstein in his Manhattan mansion — dubbed the House of Horrors by
many of his victimsCredit: Getty Images - Getty
The woman who was speaking to DailyMail.com says she was raped and molested during
two visits to Epstein's mansion in New York, in the summer of 2015.
She said: "I believe he was abusing young girls right up until the day he was arrested.
"There are likely to be multiple young victims out there who are still in their teens, perhaps
still living with their parents and too ashamed and confused to speak out.
"I know how it feels because I was one of them. I thought about suicide, I tried to cut my
wrists. These girls need support before it's too late. 
"They need to know it's OK to tell their stories."
She contacted the FBI and police after Epsetin’s arrest last July 6 on federal sex trafficking
charges filed in the Southern District of New York because she knew Epstein was locked
up.
The 22-year-old, who is thought to be the youngest woman to come forward, wants to
remain anonymous because she fears reprisals from Epstein's powerful pals and
accomplices.
This is despite the 66-year-old being found hanged in a New York jail cell nearly a year
ago. 
Marie was an aspiring 16-year-old model in the Autumn of 2014 when she met an older
woman called Madison in a bar.
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There are likely to be multiple young victims out there who are still in their teens, perhaps
still living with their parents and too ashamed and confused to speak out
Epstein victim
Last week Ms Maxwell pleaded not guilty to charges that in the 1990s she recruited three
girls, one aged 14, for Epstein to sexually abuse. 
It is also alleged that she sometimes participated in the abuse during massage sessions at
Epstein's Manhattan mansion and properties in Palm Beach, New Mexico and London. She
also denies this.
When Epstein brought her into a dimly lit room with red velvet curtains she claimed he
began fondling her, saying it was normal for young models to do "favours" for older men in
the fashion industry.
She was later raped by Epstein, who in doing so took her virginity.
Epstein was subject to two criminal indictments.
One focused largely on his activities in Palm Beach, Florida before 2008 when Epstein
signed a controversial non-prosecution deal to avoid federal charges.
The other cites abuse in New York, Florida and other locations between 2002 and “at least
in or about 2005”.
But civil lawsuits give a broader timeframe for his crimes..
A January 2020 suit filed by prosecutors in the US Virgin Islands alleges that Epstein
trafficked, raped and abused children on his private island as recently as 2019.
This was the year he was arrested and was later found dead last August 10.
Jeffrey Epstein accusers claim he rigged his New York mansion with CCTV and kept videos
to use as blackmail
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July 29, 2020
Ghislaine Maxwell latest news: Socialite and Jeffrey
Epstein said to have had ‘mysterious’ relationship over
the years
thesun.co.uk/news/12041691/ghislaine-maxwell-live-jeffrey-epstein-latest-news/
JAIL BIRD
- Who is Ghislaine Maxwell and where is she now? 
- Is Scott Borgerson Ghislaine Maxwell's husband?
- Who was Ghislaine's famous father Robert Maxwell?
- More news on Ghislaine Maxwell
Live Blog
Alex Winter
Debbie White
29 Jul 2020, 15:09
Updated: 29 Jul 2020, 15:09
Ghislaine Maxwell and Jeffrey Epstein are said to have had a “mysterious” relationship
over the years.
The two are thought to have linked up not long after she moved to New York in 1991.
One pal claims that Epstein and Maxwell were not linked romantically as has been often
reported, but instead their relationship was a financial one.
“I couldn’t work out at first how, the second Ghislaine landed in New York, she was all of a
sudden — overnight really — very chummy with Jeffrey,” the source said.
“Then he started spending on a different level, suddenly buying these extraordinary
townhouses.”
Meanwhile, Ghislaine Maxwell could strike a plea deal, exonerate Prince Andrew from any
wrongdoing and walk in a few years, according to a pal.
An anonymous friend told the Sunday Times that they expect her to get a good deal with
the prosecutors by turning on key members of the Epstein inner circle.
But the pal said Maxwell would use the deal to "exonerate" Prince Andrew of his alleged
links - with the Duke of York denying any wrongdoing.
Follow our live blog below for all the latest news and updates on the Ghislaine
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