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Case 1:20-cr-00330-PAE Document 410-2 Filed 11/04/21
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
-y.-
$2 20 CR 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
HON
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 86 of 93
Preparation of Witnesses
You have heard evidence during the trial that witnesses have discussed the facts of the
case and their tes
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 87 of 93
Redaction Of Evidentiary Items
[If Applicable]
We have, among the exhibits received in evidence, some documents that are redacted.
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21
Charts and Summaries — Admitted as Evidence
[If Applicable]
Now, some of the exhibits that were admitted into evidence were in the form of charts
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 63 of 93
OTHER INSTRUCTIONS
Direct and Circumstantial Evidence
There are two types of evidence that you may use in reaching your verdict. On
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 3of 93
Role of the Jury
Your role is to pass upon and decide the fact issues that are in the case. You, the
members of the jury, are the sol
__ Case 1:20-cr-00330-PAE Document 410 Filed 11/04/21 Page 1of2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page1of 93
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
-Vv. -
S2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
D
Case 1:20-cr-00330-PAE Document 410 Filed 11/04/21 Page2of2
Page 2
that was not itself publicly docketed and therefore is submitting Exhibit A under seal.
Respectfully submitted,
DAMIAN WILLIAMS
U
Case 1:20-cr-00330-PAE Document 409 _ Filed 11/03/21 Pagelof2
UNITED STATES DISTRICT COURT im
SOUTHERN DISTRICT OF NEW YORK piers
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/3/21 :
United States of
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page5of7
LAW OFFICES OF BOBBI C. STERNHEIA\
Little has been done to improve Ms. Maxwell’s situation, despite repeated disclosures by
counsel. Neit
Case 1:20-cr-00330-PAE Document 409 _ Filed 11/03/21 Page2of2
The parties are further ORDERED to docket Exhibit A to Dkt. No. 406 with any
proposed redactions on or before November 8, 2021. In order
Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Page3of7
LAW OFFICES OF BOBBI C. STERNHEIA\
Judge Pauley granted a motion for a new trial as to Parse’s three co-defendants but held
that Parse had
Case 3:17-Cy00 ZONK bbseb!P AecumedUARS 4Bied FOBP/LioTage 2mige Papgid#: 21160
subject to the Court’s orders regarding confidentiality in Dkt. 1172 and 1204, and shall not be
disclosed to any other
Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Page4of7
LAW OFFICES OF BOBBI C. STERNHEIA\
Assn. (2014); see also New York State Bar Association, Dec. 8, 2015 Report of the Social Media
Committee
Case 3:17-Cy0072ONKbbsebiP Aecumecuarh® 4bied FARP/LioTage 1mige Papgid#: 21159
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF VIRGINIA
CHARLOTTESVILLE DIVISION
ELIZABETH SINES, et al.,
CASE No.
Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Page2of7
LAW OFFICES OF BOBBI C. STERNHEIA\
States District Court for the Western District of Virginia ordered a semi-anonymous jury (jurors
were pu
Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page5of6
Page 5
Fifth, should the Court limit or exclude Dr. Roccio’s opinions, rebuttal opinions will
most likely be unnecessary.
Sixth, the test
Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page6of6
Page 6
DAMIAN WILLIAMS
United States Attorney
s/_Jeffrey S. Pagliuca By: __/s
Jeffrey S. Pagliuca Alison Moe
Laura A. Menninger Lara Pomera
Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page4of6
Page 4
The government makes many unfounded accusations including that the timely
disclosure of potential experts is “gamesmanship.” The si
Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page3of6
Page 3
credibility will be the central question for the jury in this case.” (Dkt. No. 291 at 12). From the
face of the expert notice, it a
Case 1:20-cr-00330-PAE Document 405 - Filed 11/02/21 Pagelof1
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
Ne
Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page1of6
USDC SDNY
UNITED STATES DISTRICT COURT NicTRuEi
SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED
DOC #: .
DATE FILED: 11/2/21
United
Case 1:20-cr-00330-PAE Document 403 Filed 11/02/21 Page3of4
Page 3
(Monday, October 11 was a federal holiday); the package scheduled for delivery on October 14,
2021 was delivered to the defendant o
Case 1:20-cr-00330-PAE Document 403 Filed 11/02/21 Page2of4
Page 2
office at 12 p.m. on Monday, but the mail room staff already picked up the mail for the day, the
mail would not be retrieved by MDC
Case 1:20-cr-00330-PAE Document 403 Filed 11/02/21 Page4of4
Page 4
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: ___s/
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant Unit
_ Case 1:20-cr-00330-PAE Document 403 _ Filed 11/02/21 Page1of4
a U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaz
Case 1:20-cr-00330-PAE Document 402 Filed 10/29/21 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK ibmiataiinied
DOCUMENT
ELECTRONICALLY FILED ||
DOC #;
United States of Americ
Case 1:20-cr-00330-PAE Document 401 Filed 11/01/21 Pagelof2
UNITED STATES DISTRICT COURT USDC SDNY
SOUTHERN DISTRICT OF NEW YORK = iininennBarmen:
ELECTRONICALLY FILED
DOC #: j
DATE FILED: 11/1/21
Case 1:20-cr-00330-PAE Document 400 Filed 10/31/21 Page1of2
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK etna
ELECTRONICALLY FILED ||
DOC #:
DATE FILED:
United States of A
Case 1:20-cr-00330-PAE Document 399 _ Filed 10/29/21 Page3of4
Page 3
Exclude GX-52 should be filed under seal because it contains phone numbers, addresses, email
addresses and other personally ident
Case 1:20-cr-00330-PAE Document 399 _ Filed 10/29/21 Page4of4
Page 4
8. The defense’s proposed redactions to Ms. Maxwell’s Reply are necessary for the same
reasons (the defense will provide the pro
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 50 of 52
F. Government Exhibit 313
GX 313 was seized in 2019. It was not seized from Ms. Maxwell. No one will testify
about where it was take
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 49 of 52
knowledge. The government does not provide any clues about who may have touched the
evidence after it was seized in October 2005, ten
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 47 of 52
prejudice because the [witness's] choice of language implied that he and the prosecution believed
the complainant's testimony." Jd.
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 48 of 52
a pre-trial hearing at which the government must demonstrate that the proposed evidence is both
authentic, admissible, relevant and n
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 39 of 52
It was not until 2020, after making a multi-million dollar claim to the Epstein Victim
Compensation fund, that the SDNY interviewed J
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 38 of 52
activity for which the defendant could be charged with specific New Jersey, Pennsylvania, New
York, and Canadian criminal offenses” (
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 28 of 52
The government denies Ms. Maxwell’s argument that “a lay jury will be unable to
apply Dr. Rocchio’s analyses to the facts of this cas
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 27 of 52
as well as [her] experience conducting forensic psychological evaluations of
people who have experienced sexual abuse and trauma.” M
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 26 of 52
situation here, in which the alleged “groomer” was not the person who perpetrated
the alleged abuse.
e Even where the “groomer” and
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 22 of 52
In any case, the newly discovered material doesn’t help the government’s cause. Exhibit
A (literally) to the government’s response is
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page19 of 52
2. The government has apparently abandoned efforts to introduce her
testimony as Rule 404(b) evidence.
In their response, the governm
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page9of52
In United States v. Velez, No. 3:10CR147 JBA, 2010 WL 4929266, at *7 (D. Conn. Nov.
30, 2010), the defendant moved for disclosure of any
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page3of52
VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS.
MAXWELL’S ALLEGED FALSE STATEMENTS AND AGREES TO MS.
MAXWELL’S PROPOS
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page1of52
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
S2 20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defe
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 84 of 84
enforcement officers identified by the defense as experts and will not elicit expert testimony from
them. Those witnesses are being ca
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 77 of 84
consistent with the rules in this exhibit.'? The relevance of the document is self-evident: among
other things, it directs employees t
Case 1:20-cr-00330-PAE Document397 Filed 10/29/21 Page 76 of 84
Fourth, the defendant argues that Government Exhibit 294 is irrelevant. (Def. Mot. 13 at
2-3). Government Exhibit 294 displays a box co
Case 1:20-cr-00330-PAE Document397 Filed 10/29/21 Page 74 of 84
First, the defendant moves to exclude Government Exhibit 52, which it says was obtained
by the Government “as part of discovery in Guif