2,983 results for "2021"
Page 103 of 120
DOJ-OGR-00008792.jpg
...Nathan
December 27, 2021
Page 3
In contrast to a constructive amendment, “[a] variance occurs when the charging terms of
the indictment are left unaltered, but the evidence at trial proves facts materially different from
those alleged in the indictment.” /d. at 20 (cleaned up).
Court Exhibit #15 indicates that...
DOJ-OGR-00009813.jpg
...N.Y. 2017) (citing Shaoul,
41 F.3d at 815), aff'd sub nom. United States v. McCoy, 995 F.3d 32 (2d Cir. 2021). That rule
exists for good reason: “To invalidate the result of a three-week trial because of a juror’s mistaken,
though honest response to...
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...Nathan
November 22, 2021
Page 5
A. The constitutional backdrop.
“Whether rooted directly in the Due Process Clause... , or in the Compulsory Process or
Confrontation clauses of the Sixth Amendment, the Constitution guarantees criminal defendants
a meaningful opportunity to present a complete defense.” Crane v. Kentucky, 476 U.S. 683...
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...And the information it contains is already almost entirely a matter of
longstanding public record, principally as a result of live testimony by percipient witnesses at the
2021 Maxwell trial.
B. Application of the In re Craig Factors
In cases involving grand jury testimony of significant historical or public interest...
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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page124 of 200 61
k7e2MaxC kj
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bank accoun
are by or...
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...As the Court stated at the November 4, 2021 pretrial conference, it
takes Mr. Robertson’s charges extremely seriously because the ability of witnesses to come
forward and safely provide information to the government, and to the Court, is at the core of our
criminal justice system.
With regard to...
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...Nathan
November 22, 2021
Page 14
This is clear from the language of the Rule. “The claim” to which subsections (a)(1) and
(a)(2) refer is the “disputed claim” referenced in subsection (a). When the “disputed claim” is
different from “the claim” compromised, the Rule’s prohibitions do not...
DOJ-OGR-00004222.jpg
...or inflicting sexual abuse.” “Sexual abuse,” Merriam-Webster.com
Legal Dictionary, Merriam-Webster, https:/(www.merriam-webster.com/legal/sexual%20abuse,
accessed 11 Mar. 2021.
Although the government concedes its inability to establish that Accuser-3’s alleged
interactions with Ms. Maxwell and Epstein were anything other than consensual and...
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...The defendant’s Rule 16 disclosures were due on November 8, 2021. (Dkt. No. 297 at 2).
Accordingly, any exhibits which the defense intends to offer as part of its case-in-chief, whether
through Government witnesses or its own, should have been disclosed at that time. The
Government of...
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...are . . . no countervailing
interests that would justify sealing.” United States v. Avenatti, 550 F. Supp. 3d 36, 48 n.3
(S.D.N.Y. 2021). The Defendant’s proffered justifications for sealing elide the reality that the
decision-maker at this stage of proceedings is not a jury but the...
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Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 2 of16
November 19, 2021
Page Two
effectively achieve the EVCP’s important societal goals of providing redress to victims and
efficiently resolving civil claims outside the glare of a public proceeding. Because Maxwell’s
subpoena would...
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...The Court
concludes that Juror 50’s comment to Annie Farmer on Twitter, made in January 2022, does not
provide a basis to question his testimony that as of November 4, 2021, he did not tell many
people about his sexual abuse.
At bottom, based on Juror 50’s demeanor...
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...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...
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...Nathan
April 1, 2021
Page 3
The testimony at issue is undeniably private: it relates exclusively to Ms. Maxwell’s
consensual adult sexual activities involving “sex toys or devices used in sexual activities” and
a “three-way sexual” encounter involving an adult “blond and brunette.” See Lawrence v.
Texas, 539...
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...Nathan
April 5, 2021
Page 8 of 17
Requests themselves. Resp. Ltr. at 7. In Requests 3 through 5, the Defendant seeks all
communications between BSF and its co-counsel in a civil litigation against Maxwell (Giuffre v.
Maxwell, 15-cv-07433-LAP) “between 2015 and the date of this...
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...STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fax besternhein@mac.com
October 18, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine...
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...STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 * Cell New York, NY 10007
888-587-4737 ° Fax besternhein@mac.com
October 29, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine...
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...Accordingly, the Government respectfully requests that the Court set a deadline for any
? In addition, on November 3, 2021, the Government provided the Court with the joint request to
charge and verdict form, for which the Government received full comments from the defense late
last night.
DOJ-OGR-00006163
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...On October 11, 2021, the Government served on defense counsel a short letter entitled
the “Maxwell Rule 404(b) letter’ (the “Rule 404(b) Letter” or the “Letter’’), attached as Exhibit
A. In it, the Government referenced two sets of evidence: (a) certain emails purportedly between
Ms. Maxwell and third...
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...Legal counsel for the MDC has informed the
Government that when the defendant was housed outside of the general population, her meals
arrived in containers that were both microwavable and oven safe, and her meals were heated in a
thermal oven as of at least April 6, 2021. As the...
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...In addition, on April 13, 2021, the
Government produced over 20,000 pages of interview notes, reports and other materials related
to non-testifying witnesses. After considering the circumstances, including the complexity of the
issues in this case and what the defense has already received and likely learned in the...
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...Nathan
April 2, 2021
Page 9
Requests 9-11
Requests 9, 10, and 1 1seek evidence for inspection in advance of trial. A subpoena issued
pursuant to Rule 17(c)(1) “may order the witness to produce designated ‘books, papers,
399
documents, data, or other objects’” so long as they...
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...Nathan
December 16, 2021
Page 2
very basis of the charges in this case. Id. But Eva, Michelle, and Kelly will all testify they were
not involved in and cannot “confirm” the group sexualized massages. Their testimony
contradicts Jane’s testimony, and it is relevant, material, and exculpatory. Finally, the...
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...On April 23, 2021, the Government timely notified the defendant of its intent to call Dr.
Rocchio in its case-in-chief. As the notice explains, Dr. Rocchio is expected to testify, based on
her relevant education, training, experience, and research, and offer the following opinions:
Individuals with particular vulnerabilities...
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...On April 23, 2021, the Government timely notified the defendant of its intent to call Dr.
Rocchio in its case-in-chief. As the notice explains, Dr. Rocchio is expected to testify, based on
her relevant education, training, experience, and research, and offer the following opinions:
Individuals with particular vulnerabilities...
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