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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Xx
UNITED STATES OF AMERICA
STIPULATION
¥.
. $2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL, '
Defendant.
x
IT IS HEREBY STIPULATED AND AGREED by and among the United States of
America, by Damian Williams, United States Attorney for the Southern District of New York,
and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United
States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her
attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi
Sternheim, Esq., that:
IL. Sgt. Michael Dawson, who previously testified in this case, would have given the
following additional testimony on cross-examination:
a. The cardboard box shown in GX-294, which was recovered during the search
of Jeffrey Epstein’s Palm Beach residence on October 20, 2005, was found in
the closet of one of the guest bedrooms on the second floor of the residence.
b. The two items inside the carboard box, which are visible in GX-294, were still
in their original boxes, unopened.
DOJ-OGR-00015185