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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 185 of 239
conspiracy is timely. Second, the description of Minor Victim-3’s experiences in the Indictment
is no more inflammatory or prejudi
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 174 of 239
of proof of the conspiracy and perjury crimes permitted joinder of the offenses . . . and denial of
appellant’s Rule 14 pretrial m
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 167 of 239
in a bankruptcy proceeding). Similarly, “[c]ourts have repeatedly recognized the appropriateness
of trying perjury or obstruction
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 164 of 239
statements at the heart of that case and the evidence that might have been uncovered had the
defendant answered the questions trut
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 149 of 239
Finally, even if a defendant makes a knowing false statement, a perjury conviction requires
that the statement be material. A fals
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 148 of 239
natural meaning in the context in which words were used they were materially untrue, perjury was
established.” United States v. Bo
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 145 of 239
Gow stated that Giuffre’s claims were “untrue” and “obvious lies.” (15 Civ. 7433 (LAP), Dkt.
No. | at 6).
As described in the pre
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 141 of 239
alleged omissions and correcting the alleged errors, the “ultimate inquiry” is whether “there
remains a residue of independent and
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 92 of 239
The protective order, among other things, restricted the parties from disclosing discovery materials
marked confidential to third p
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 89 of 239
No. 1). In short, Giuffre alleged that Maxwell had defamed her when Maxwell stated that Giuffre
was not the victim of sex crimes pe
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 68 of 239
court resolved the issue by answering a common sense question: “Does someone who merely
possesses child pornography sexually abuse
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 54 of 239
denied, 546 U.S. 1007 (2005)); United States v. Brown, 800 F. App’x 455, 461 (9th Cir. 2020)
(“Because Congress evinced a clear int
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 38 of 239
would not, without more, establish that the USAO-SDFL intended to bind other districts, much
less that the USAO-SDFL communicated a
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 37 of 239
The privilege log also does not establish that the USAO-SDFL involved other U.S.
Attorney’s Offices in plea negotiations with Epste
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page5of 239
EXHIBIT LIST
Exhibit 1: Notes from the U.S. Attorney’s Office for the Southern District of New York
Exhibit 2: June 14, 2007 Email
E
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page1 of 239
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ARR RE RR RRs Xx
UNITED STATES OF AMERICA
-V.- i S1 20 Cr. 330 (AJN)
GHIS
Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 6 of 8
LAW OFFICES OF BOBBI C. STERNHEIA\
witnesses, including potential FRE 404(b) witnesses, and trial exhibits, the government’s
speculation
Cétash: 2Q20roCk RSP AON DecunmeantZ20D AréelOevi771 Paéteye afadf 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
— x
UNITED STATES OF AMERICA,
ORDER
-against-
S2 20 Cr. 330 (AJN)
GHIS
Case 1:20-cr-00330-PAE Document 200 Filed 04/14/21 Page2of2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
— x
UNITED STATES OF AMERICA,
ORDER
-against-
S2 20 Cr. 330 (AJN)
GHISLAINE MAX
Case 1:20-cr-00330-AJN Document 197 Filed 04/07/21 Page 3of5
LAW OFFICES OF BOBBI C. STERNHEIA\
up because it is part of her medical record, which is protected by the American Health Insurance
Portab
Case 1:20-cr-00330-PAE Document196- Filed 04/06/21 Page6of6
Page 6
Should the Court have any questions or require any additional details regarding this topic,
the Government will promptly provide ad
Case 1:20-cr-00330-PAE Document196- Filed 04/06/21 Page1of6
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New
Case 1:20-cr-00330-PAE Document190_ Filed 03/29/21 Page 3of3
Honorable Alison J. Nathan
March 29, 2021
Page 3
discoverable under Rule 16, it has nevertheless made this production as a courtesy in l
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 18 of 24
financially and by receiving anything of value, from
participation in a venture which has engaged in any such act,
knowing that the per
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page15 of 24
18. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, wou
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page11 of 24
offered to assist Minor Victim-4 with obtaining a passport for
purposes of such travel, but Minor Victim-4 declined the
invitation. On m
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 12 of 24
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
Kes
e
Case 1:20-cr-00330-PAE Document186 Filed 03/26/21 Pagelof1
Uspc SDNY
DOCUMENT |
UNITED STATES DISTRICT COURT ELECTRONICALLY FILED
DOC #;
SOUTHERN DISTRICT OF NEW YORK ae ae ee
United States of Ame
Case 1:20-cr-00330-PAE Document 182-4 Filed 03/26/21 Page 1of2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Case No.: 20-CR-330-AJN
V. ORDER FOR ADMISSION PRO
Case 1:20-cr-00330-PAE Document182 Filed 03/26/21 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Case No.: 20-CR-330-AJN
MOTION FOR ADMISSION PRO HAC VI
Case 1:20-cr-00330-PAE Document 182-1 Filed 03/26/21 Page1of1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Vv.
GHISLAINE MAXWELL
Defendant.
I, Sigrid S. M
Case 1:20-cr-00330-PAE Document181 Filed 03/26/21 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
we No. 1:20-cr-00330 (AJN)
GHISLAINE MAXWELL
, NOTIC
Case 1:20-cr-00330-PAE Document173 _ Filed O3/#Af2d 1 Papa dor 1
Criminal Notice of Appeal - Form A DOCUMENT
ELECTRONICALLY FILED
NOTICE OF APPEAL DOC#:
DATE FILED: 3/24/2021
United States District
Case 1:20-cr-00330-PAE Document180 Filed 03/26/21 Pagelof1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
we No. 1:20-cr-00330 (AJN)
GHISLAINE MAXWELL
, NOTIC
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page4of18
instead guided by concerns of efficiency. Here, it is unclear whether interlocutory appeal of a
district court’s decision regarding bail “d
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page2of18
Preliminary Statement
The issue before the Court, as it has been since Ms. Maxwell’s first bail application,
is whether conditions exist t
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page1of18
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ae x
UNITED STATES OF AMERICA,
v.
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defenda
Case 1:20-cr-00330-PAE Document tf Filed 03/22/21 (Page 1 of2
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-AJN Document169 Filed 03/22/21 Page 11 of 12
concerns about whether the full extent of the Defendant’s assets have been disclosed in light of
the lack of transparency when she was
Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 8 of 12
that the Defendant poses a significant risk of flight. Thus, the Court again concludes that there
are no conditions of release that wil
Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 7 of 12
of the government’s case and warrant granting bail on the conditions proposed.” Def. Mot. at 7.
Those motions became fully briefed one
Case 1:20-cr-00330-AJN Document169 Filed 03/22/21 Page 5 of 12
If, as here, there is probable cause to find that the defendant committed an offense
specifically enumerated in § 3142(e)(3), a rebuttab
Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 3 of 12
escape; and that the Defendant’s lack of candor regarding her family ties and financial situations
raised serious doubts as to her will
Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 2 of 12
provided in denying bail, proposing two additional conditions to the ones she proposed in her
second motion for bail. Specifically, she
Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 1 of 12
USDC SDNY
UNITED STATES DISTRICT COURT DOCUMENT
SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED
DOC #;
DATE FILED: 3/22/21
United
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page5of5
above, however, the Court will give the Government an opportunity to justify the ongoing need
to redact this information and these document
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 4of5
Onondaga, 435 F.3d 110, 124 (2d Cir. 2006). Courts have noted that “disclosing the details of
the Government’s efforts to obtain evidence
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 2 of 5
The proposed redactions mostly satisfy this test. First, the Government’s brief in
opposition to the Defendant’s pre-trial motions is a
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page1of5
Uspc SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT DOC #;
SOUTHERN DISTRICT OF NEW YORK DATE FILED: __ 3/18/21
United S
Case 1:20-cr-00330-AJN Document 167 Filed 03/16/21 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIA
212-243-1100 © Main 33 West 19th Street - 4th Floor
917-306-6666 ® Cell New York, New York 10011
888-