Grand Jury-NY

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United States wv. Ghislaine Maxwell 07/08/20 2

PREOCEEZDTINIGS

(10:05 a.m.)

I Let the record reflect that there are
17 grand jurors present and that the foreperson is present.

Food morning, ladies and gentlemen. My name is
BEE BB 2c I am an Assistant United States Attorney
here in the Southern District of New York.

Can everyone hear me okay? All right. I see
everybody's heads nodding. Thank vou.

I am here today to present for your consideration
a proposed superseding indictment charging Ghislaine Maxwell
in six counts. This indictment is wirtually identical to
the indictment that you returned last week charging Maxwell
in those same six counts except that it corrects two
clerical errors, or two typographical errors that were

contained in Counts Five and Six which are the perjury

charges.

As a result, I will not be presenting any new
evidence or new witnesses today. Instead, I will identify
for you those two clerical errors in the indictment. I will

point out the portion of the exhibits that vou saw last week
that provide the correct information. Then I will identify
the corrected portion of the superseding indictment in the
proposed superseding indictment.

Before I do that though, I must ask you all the

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Court Reporting Transcription
D.C. Area 301-281-1902
Balt. & Annap. 410-374-0947

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United States wv. Ghislaine Maxwell 07/08/20 3
same preliminary questions that we went over last week.
First, do any of you believe that you personally know or
have met the proposed defendant, Ghislaine Maxwell? I see
no hands.

Next, have vou any heard or read about, or learned
anything Ghislaine Maxwell, Jeffrey Epstein or anyone else
related to this case, if you could just raise your hand? I
see a number of hands. Virtually every hand is in the air.
You can all put your hands down. Thank you.

As you know, you must make your determination as a
grand jury based on the evidence presented before you in the
grand jury, in this room alone. Accordingly, vou must set
aside any other knowledge vou may have about this case or
the people involved in it, and base your decision solely on
the evidence presented to this grand jury to determine
whether there is probable cause to believe that the charges
in the proposed indictment were committed.

Is there any grand juror here today who cannot
follow these instructions? I see no hands. Just to be
sure, 1s there any grand juror here who would have any
difficulty setting aside the outside information you may
have about the defendant or the facts of this case? I see
no hands.

Finally, do any of you believe you know me in

anything other than my professional capacity? I see no

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Court Reporting Transcription
D.C. Area 301-281-1902
Balt. & Annap. 410-374-0947

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United States wv. Ghislaine Maxwell 07/08/20 4
hands.

Now, as I mentioned, I will not be calling any
witnesses today. Instead I will present vou with the
exhibits from last week, the transcript of the testimony you
heard from last week and the proposed superseding
indictment. I will then walk you through the error that the
superseding indictment seeks to correct.

Flease keep in mind though that what I say 1s not
evidence. Only the testimony of the witnesses and the
exhibits are evidence. 50 as I'm walking you through these
exhibits, your understanding of them and your understanding
of the evidence controls. I am just trying to provide you
with an overview.

With that instruction in mind, I am going to put
up onto the Elmo what was previously received and marked as
Grand Jury Exhibit 1. That is the proposed six-count
indictment that vou voted to return last week. A copy of 1t
will be available for review when you deliberate.

You also received what has been marked as Grand
Jury Exhibit 2, which I will not put up on the Elmo. That
was a FowerFoint presentation containing photographs and
excerpts of certain documents that was shown to vou during
the testimony last week. You also heard testimony from FEI

Today I am marking, as Grand Jury Exhibit 3, a

FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-281-1902
Balt. & Annap. 410-374-0947

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United States wv. Ghislaine Maxwell 07/08/20 5
copy of the transcript of that testimony. It is up on the
Elmo now and it will be available for vou to review if you
would like as vou deliberate. I will not read it back to
you now, but vou can read through it as you deliberate.

Finally, I am marking, as Grand Jury Exhibit 4,
the proposed superseding indictment, which I have now placed
up on the Elmo. As I mentioned, this proposed superseding
indictment corrects two clerical errors and is otherwise
identical to the original indictment, Grand Jury Exhibit 1.

I'm now going to walk you through the errors that
we're going to correct starting on Grand Jury Exhibit 1.
Fage 15 contains the beginning of Count Five which charges
Maxwell with perjury. Paragraph £21 on that page refers to
the civil case in which Maxwell gave deposition testimony on
April 2Znd, 201¢, as 15 Civ. 7344, That is the error we are
going to correct.

Similarly, page 16 contains the beginning of Count
S5ix which charges another count of perjury. Paragraph 23 on
that page refers to the civil case in which Maxwell gave
deposition testimony on July 22nd, 2016, under the same
number, 15 Civ. 7344.

Turning now to Grand Jury Exhibit 2. Slide ZZ of
that exhibit contains the first page of the deposition
transcript from the testimony that Maxwell gave on

April 2Znd, 2016. As you can see here, the docket number

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United States wv. Ghislaine Maxwell 07/08/20 6
for that case is in fact 15 Civ. 7433 not 7244.

Similarly, slide 25 contains the first page of the
transcript from the July 22nd, 2016 deposition that Maxwell
gave. As you can see here, again, the docket number for
that case is 15 Civ. 7433 not 7344.

Finally, I will turn to the proposed indictment,
Grand Jury Exhibit 4. On page 15, you have again the same
per jury count with one change. Paragraph 21 corrects the
docket number for the civil case to be 15 Civ. T7433.

Similarly, on page 16, which contains the second
per jury count for the July 2Znd, 2016 deposition, the docket
number is corrected to 15 Civ. 7433. There are otherwise no
changes to the substance of this indictment.

That is my presentation. Before I leave vou to
deliberate, would anyone like me to read the full proposed
superseding indictment out loud? I see no hands.

I must advise you that vou must independently find
probable cause, again, for each count in the superseding
indictment. The evidence before vou in support of the
charges in the superseding indictment is the same evidence
that was before vou when you considered the indictment last
week,

Does anyone have any questions about that
evidence? I see no hands.

The legal instructions that vou received before

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Balt. & Annap. 410-374-0947

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United States wv.
voting on the indictment last
that apply to vour considerati
indictment. Would anyone like
out loud for vou again? I see

Does anyone have any
instructions? I see no hands.

I will leave you now
deliberate. As always, 1f vou
concerns about the proposed in
before you vote so that I may
have on the law,

or bring any

to consider. Thank you, all.

(Matter concluded)

(Time MNoted: 10:14

FREE STATE REPORTING,

Court Reporting

Ghislaine Maxwell

07/08/20 7

week are the same instructions

on of the proposed superseding
me to read those instructions
no hands.

questions about the legal

with the exhibits to
have any questions or
dictment, please let me know

answer any guestions you may

additional evidence before you

INC.

Transcription

D.C. Area 301-2Z261-1%02

Balt. & Annap.

410-974-0247

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I hereby certify that the foregoing is a true and
accurate transcription, to the best of my skill and ability,

from my electronic notes of this proceeding.

July 22, 2020__
Date

CERTIFICATE

Acting Grand Jury Reporter
Free State Reporting, Inc.

Court Eeporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947

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