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Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page1of14
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
S2 20 Cr. 330 (AJN)
V.
GHISLAINE MAXWELL,
Defendant
Case 1:20-cr-00330-PAE Document 387 Filed 10/29/21 Page 21 of 21
CERTIFICATE OF SERVICE
I hereby certify that on October 18, 2021, I served by email, pursuant Rule 2(B) of the
Court’s individual pra
Case 1:20-cr-00330-PAE Document 387 Filed 10/29/21 Page/7of21
with the requested massages, and during those massages, Epstein
sexually abused [Accuser-3]. MAXWELL was aware that Epstein
engaged in
Case 1:20-cr-00330-PAE Document 387 Filed 10/29/21 Page1of21
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
S2 20 Cr. 330 (AJN)
V.
GHISLAINE MAXWELL,
Defendant
Case 1:20-cr-00330-PAE Document 386-1 Filed 10/29/21 Page2of4
[LL
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Pl
Case 1:20-cr-00330-PAE
Document 386
Filed 10/29/21
Certificate of Service
Page 24 of 24
I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Motion
Case 1:20-cr-00330-PAE Document 386 _ Filed 10/29/21 Page 10 of 24
element of the crime charged or of a defense” because those “matters are for the trier of fact
alone.” Fed R. Evid. 704(b).
Rule 40
Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page /7 of 24
evidence can be both powerful and quite misleading because of the difficulty in evaluating it,”?
and for all the other reasons given b
Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page5of24
TABLE OF EXHIBITS
EXHIBIT 1: Government’s Apr. 23, 2021 Notice of Expert Witness Dr. Lisa M. Rocchio
EXHIBIT 2: Dr. Lisa M. Rocchio’s Cur
Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page1of24
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
wee xX
UNITED STATES OF AMERICA,
y : 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
De
Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 2of3
; 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 Document385 _ Filed 10/29/21 Page12of12
Certificate of Service
I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Motion to Ex
Case 1:20-cr-00330-PAE Document 385 _ Filed 10/29/21 Page 8of12
charged crimes [and (i1)] her [unspecified] role in scheduling sexualized massages for Jeffrey
Epstein with underage girls," apparently
Case 1:20-cr-00330-PAE Document 385 _ Filed 10/29/21 Page1of12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defenda
Case 1:20-cr-00330-PAE Document 384-1 Filed 10/29/21 Page2of3
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 384-1 Filed 10/29/21 Page3of3
Page 2
Please be advised that the above list is limited to the individuals the Government may refer
to as co-conspirators at trial. Whil
Case 1:20-cr-00330-PAE Document 384 _ Filed 10/29/21 Page12of12
Certificate of Service
I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Motion to P
Case 1:20-cr-00330-PAE Document 384 _ Filed 10/29/21 Page /7of12
Ill. The Failure to Disclose Prevents Defense Cross Examination at Trial and
Facilitates the Presentation of False Testimony
None of
Case 1:20-cr-00330-PAE Document 384 _ Filed 10/29/21 Page6of12
rejected by the Court which ordered disclosure at the same time as the government's witness list,
Rule 404(b) notice, exhibits, and 3500
Case 1:20-cr-00330-PAE Document 384 _ Filed 10/29/21 Page1of12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
wee xX
UNITED STATES OF AMERICA,
y : 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Case 1:20-cr-00330-PAE Document 383 _ Filed 10/29/21 Page 40 of 40
ensure that only relevant evidence and arguments are presented at trial, and that the defense be
precluded from offering inflammator
Case 1:20-cr-00330-PAE Document 383 _ Filed 10/29/21 Page 38 of 40
The defense also argues that they should be permitted to elicit information that the Minor
Victims engaged in voluntary acts, becaus
Case 1:20-cr-00330-PAE Document 383 _ Filed 10/29/21 Page 21 of 40
private rather than public,” which avoids “catering” to “sensational” interests. (Gov’t Mot. at 16
(quoting United States v. Amodeo,
Case 1:20-cr-00330-PAE Document 383 _ Filed 10/29/21 Page 20 of 40
Finally, the defense argues that this motion is purely tactical on the part of the Government,
because this motion affords sympathy
Case 1:20-cr-00330-PAE Document 383 _ Filed 10/29/21 Page 19 of 40
to make the point. She does not. Much of this information can be elicited without using names at
all, such as Minor Victim-4’s past
Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page 6 of 40
As noted in the Government’s motion, an order imposing privacy safeguards at trial for
victims of sex crimes is commonplace. See Aug. 3
Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page4of40
PRELIMINARY STATEMENT
The Government respectfully submits this memorandum of law in further support of its
October 18, 2021 motions in lim
Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page1of40
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Bs S2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant
Case 1:1Ga8P A126 GAGS SHBARnerPacemenieBe 6n FERS BERV2d5/1NA0te GdGe 4 of 15
Terms of the Agreement:
1. Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending agai
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 62 of 69
VIII. THE GOVERNMENT’S MOTION TO LIMIT THE INTRODUCTION OF MS.
MAXWELL’S STATEMENTS IS PREMATURE AND SHOULD BE DENIED AT
THIS TIME
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 58 of 69
purpose or agreement with any co-conspirator to facilitate an illegal objective. The ill-founded
motion should be denied.
A. The Gove
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 50 of 69
no authority indicating that more is required. Indeed, the government’s demand for a proffer is
nothing more than an attempt to force
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 53 of 69
government has provided "notice" tha ae :: a "victim" in this case, and has disclosed
a number of exhibits related to her — school re
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 38 of 69
whom the government identified as a victim of his offenses so that they could sue him for
damages in civil lawsuits. See NPA at 4 was
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 31 of 69
I. SUPPRESSION OF THE EXHIBITS IS CONTRARY TO WELL-
ESTABLISHED SECOND CIRCUIT LAW
At this point, everyone associated with this litig
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 24 of 69
The movant bears the burden of proof to show factors that outweigh the ordinary
presumption of judicial openness. Doe v. Cook Cty., Il
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 3 of 69
Ill. EVIDENCE AND ARGUMENT ABOUT PRIOR CHARGING DECISIONS AND THE
COURSE OF PRIOR INVESTIGATIONS IS ADMISSIBLE ...............ccccccec
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 2 of 69
TABLE OF CONTENTS
PRELIMINARY STATEMENT .........cccecsecsesscssessesseseessecseveccneeseesaeseesaesaessesaeeeeeneeseenaeseesaesateate
Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page1of69
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
S2 20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defend
Case 1:20-cr-00330-PAE Document 381 Filed 10/29/21 Page1of5
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 * Cell New York, NY 10007
888-587-4737 ° Fax b
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 53 of 54
the court to declare the defendant the prevailing party in that suit, because Minor Victim-2 had
dismissed the case with prejudice i
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 54 of 54
CONCLUSION
For the reasons set forth above, the Government respectfully requests that the Court grant the
Government’s in limine mo
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 35 of54
value of such evidence is substantially outweighed by the unfair prejudice to the Government
and risk of distracting the jury or enco
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 33 of 54
(see generally Dep’t of Justice, Office of Professional Responsibility Report, Dkt. No. 293 Ex. A
at v-vi), evidence or argument on
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page17 of 54
disclosure of such information will identify the Minor Victims with particularity, and thus
subject them to harassment, retaliation,
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page13 of 54
examination of other witnesses; (2) preclude the defense from eliciting personal identifying
information for the Minor Victims, Witne
Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page8of54
Zhong, No. 16 Cr. 614 (DLI), 2018 WL 6173430, at *2 (E.D.N.Y. Nov. 26, 2018) (granting
government’s motion to have victim witnesses testif
Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 2 of54
TABLE OF CONTENTS
Did x 0d Day We, eS ego Wd A OY 8 RESET ec essee ape pean eC mens Me PROERT SNC NR ere Up ee 2
FE |, fl See nee eee ea
Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page5of54
protect against unnecessary public disclosure of their identities, in order to protect the Minor
Victims from potential harassment from th
Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page4of54
Po Eleventh, and finally, the Government moves to preclude the
defense from misleadingly suggesting to the jury that the defendant prevai