2,985 results for "2021"
Page 101 of 120
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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page127 of 200
k7e2MaxC kjc
We believ
ther
the reach of
be...
DOJ-OGR-00001262.jpg
...mention the integrity of the entire
+ Accuser-3 is identified in the Indictment as “Minor Victim-3.”
5 “Opp.” references are to page numbers of the Government’s Omnibus Memorandum in Opposition to Defendant’s
Pre-Trial Motions, dated February 26, 2021 and not yet publicly filed.
DOJ-OGR-00001262
DOJ-OGR-00003978.jpg
...Nathan
April 2, 2021
Page 7
admissible, either as a written supplement to the motions, or at any motion hearing under Fed. R.
Evid. 104 and 803(6). Ms. Maxwell has requested, and is entitled to, an evidentiary hearing on
her motions to suppress. The requested information would establish the...
DOJ-OGR-00005489.jpg
...Evid. § 6753 Consistent
Premotive Statements (2021 ed.) ("As in Tome, prior consistent statements will frequently be
tainted by the same alleged motive to lie that is claimed to impugn the witness' trial testimony. If
so, Rule 801(d)(1)(B)(1) does not permit their introduction. This result has favorable...
DOJ-OGR-00006451.jpg
...Evid. § 6753 Consistent
Premotive Statements (2021 ed.) ("As in Tome, prior consistent statements will frequently be
tainted by the same alleged motive to lie that is claimed to impugn the witness' trial testimony. If
so, Rule 801(d)(1)(B)(1) does not permit their introduction. This result has favorable...
DOJ-OGR-00008270.jpg
...Nathan
December 8, 2021
Page 6
Id. at 331. The government’s attempt to authenticate Exhibit 52 through Ms. Maxwell’s
testimony about something else entirely fails.
The flaws in the government’s argument don’t end with these two problems, though each
problem itself is dispositive of the government...
DOJ-OGR-00011242.jpg
...Nathan
May 12, 2021
Page 2
produce Brady material with various disclaimers such as “although the government is not
obligated to do so” (Dkt. 269 pp. 8, 9), and obfuscate the importance of legitimate defense
requests for discovery. The government repeatedly demonstrates that it views this process not as
a...
DOJ-OGR-00002831.jpg
...See Allen, 2021 WL 431458, at *1,
With this background in mind, the legal issue at hand becomes straightforward. The
Second Circuit’s decision in United States v. Bahna, 68 F.3d 19 (2d Cir. 1995), frames the
inquiry and supplies its answer. In Bahna, a defendant was indicted, tried...
DOJ-OGR-00006240.jpg
...Dietz is not planning on attending the November 10, 2021
Daubert hearing of Dr. Rocchio, and the Government has not to date received any Rule 26.2
disclosures from Dr. Dietz, or even a complete bibliography of the sources cited in his disclosure.
The Government respectfully requests that, should a...
DOJ-OGR-00007398.jpg
...At the November 1, 2021 conference, the defendant sought to preclude
the Government from arguing that the Minor Victims’ settlements with the EVCP reflects an
endorsement of their claims, which “would be confusing to the jury” and “open the door to an
explanation from the defense about what really happened...
DOJ-OGR-00019968.jpg
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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page109 of 200
k7e2MaxC kjc
So we underst
process,
relevant to the...
DOJ-OGR-00020180.jpg
...mention the integrity of the entire
+ Accuser-3 is identified in the Indictment as “Minor Victim-3.”
5 “Opp.” references are to page numbers of the Government’s Omnibus Memorandum in Opposition to Defendant’s
Pre-Trial Motions, dated February 26, 2021 and not yet publicly filed.
DOJ-OGR-00020180
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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page120 of 200
k7e2MaxC kjc
Faraday bag,
briefcases,
from being hacked,
whe...
DOJ-OGR-00001394.jpg
...Maxwell’s arraignment on July 14%, 2020, counsel prioritized the
July 12, 2021 trial date, clearing and scheduling our calendars to avoid interference. Counsel
have other clients and firm commitments to try cases specifically scheduled to follow the
summer trial of this case. These commitments make us unavailable from September...
DOJ-OGR-00002929.jpg
...As set forth above, the government’s hyperbolic claim that
it can “ensure that the defense will be fully prepared to proceed to trial on July 12, 2021” (Govt
Itr at 4-5) ignores the reality that time is needed to:
= supplement pending pretrial motions;
= critically review voluminous discovery produced...
DOJ-OGR-00005036.jpg
...252, April 27, 2021
Op., at 3-4. As set forth in the subpoenas, the term “communications” encompasses “all forms
of correspondence, including regular mail, email, text message, memorandum, or other written
DOJ-OGR-00005036
DOJ-OGR-00006343.jpg
...Rocchio’s expertise should be excluded as failing to comply with
the Court’s order that the Government make all expert witness disclosures by April 23, 2021.
Dkt. No. 250. But that Order, made pursuant to Federal Rule of Criminal Procedure 16(a)(1)(G),
required only that the Government...
DOJ-OGR-00008207.jpg
...Nathan
December 3, 2021
Page 2
relevant to her memory and capacity as a witness since she cannot recall a highly consequential
conversation she had just months ago.”
For two reasons, the government is wrong to say that the attorney-client privilege bars
Ms. Maxwell from pursuing this line of...
DOJ-OGR-00011439.jpg
...Nathan
November 22, 2021
Page 16
whether they are telling the truth, and if they aren’t, she is allowed to impeach them. Fed. R.
Evid. 613(b) (allowing proof of inconsistent statement by extrinsic evidence).
The government’s position is classic gamesmanship. The government says that whatever
the accusers...
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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page120 of 200
k7e2MaxC kjc
Faraday bag,
briefcases,
from being hacked,
whe...
DOJ-OGR-00004014.jpg
...Nathan
April 5, 2021
Page 14 of 17
The Defendant has not explained how any of the photographs are relevant to her defense and
would “help in establishing her innocence” or why “the dates of creation” or “other specifics”
about these photographs are relevant to her defense. Resp. Ltr. at...
DOJ-OGR-00009052.jpg
...TR 10/21/2021, p 25-26. Because Juror No. 50 did not honestly answer these material
questions, however, the Court and the defense were not alerted to probe these issues and
instead relied on Juror No. 50’s claim that he could be fair and impartial. In hindsight,
that...
DOJ-OGR-00010373.jpg
...1, 2021 Tr. at
6-7.
DOJ-OGR-00010373
DOJ-OGR-00010709.jpg
...en
banc 2021) (Hull, J., dissenting). And Epstein’s escape from conviction through apparent suicide in
circumstances where federal authorities should have been more vigilant has created a widely spread
meme that “Epstein didn’t kill himself.”
Against this backdrop, if Maxwell’s victims are prevented from speaking at her...
DOJ-OGR-00015067.jpg
...The grand jury met
in June and July of 2020 and March of 2021 in the Maxwell case. Here, the passage of time has
not dulled the public’s interest in these cases. See In re Craig, 131 F.3d at 107 (“if historical interest
in a specific case has...
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