2,983 results for "2021"
Page 104 of 120
DOJ-OGR-00007360.jpg
...Maxwell with a
substantive violation of § 1591(a), claiming she "did recruit, entice, harbor, transport, provide,
' Pursuant to the Court’s ruling at the November 10, 2021 conference, we will refer to Accuser-3 as
“Witness-3.” However, for ease of reference, we will refer to these four women collectively...
DOJ-OGR-00009559.jpg
...factual showing for the Court to order disclosure, see 2
Wayne LaFave et al., Criminal Procedure §§ 4.8(b), 4.8(d) (4th ed. 2021); Matter of Warrant to
Search a Certain i:-Mail Acct. Controlled & Maintained by Microsoft Corp., 829 F.3d 197, 206
(2d Cir. 2016), vacated and...
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...On April 13,
2021, in a highly unusual, if not unprecedented disclosure, the government produced over 20,000
pages of interview notes, reports and other materials related to 226 separate witnesses whom the
government does not intend to call as witnesses at trial. Ms. Maxwell has not yet received these...
DOJ-OGR-00003940.jpg
...Nathan
April 22, 2021
Page 3
Oguns, 921 F.2d 442, 447 (2d Cir. 1990) (“The government bears the burden of proving that
the taint [of an illegal search] has been alleviated.”)). Like a Kastigar hearing, “the
government bears ‘the heavy burden of proving that all of the evidence it...
DOJ-OGR-00003969.jpg
...Nathan
April 22, 2021
Page 3
Oguns, 921 F.2d 442, 447 (2d Cir. 1990) (“The government bears the burden of proving that
the taint [of an illegal search] has been alleviated.”)). Like a Kastigar hearing, “the
government bears ‘the heavy burden of proving that all of the evidence it...
DOJ-OGR-00007414.jpg
...An employee who was aware of that
practice and who starts in 2021 can authenticate a copy of that book, even if the particular copy
was given to an employee who started in 2020. Or consider if the Yankees have distinctive team-
branded water bottles spread across their locker room...
DOJ-OGR-00007446.jpg
...Nathan
November 11, 2021
Page 10
consent in Florida was 18 years old, and the legal age of consent in
the U.S. Virgin Islands was 18 years old.
The alleged conduct that Accuser-3 has described in her testimony
was therefore not illegal. If you find that these incidents...
DOJ-OGR-00007470.jpg
...10, 2021 hearing), and Dr. Loftus all but wrote the book on the
science of memory.
Unable to challenge the qualifications of either Dr. Dietz or Dr. Loftus, the government’s
motion mischaracterizes their proposed opinions in an effort persuade this Court that they either
invade the province of the...
DOJ-OGR-00008229.jpg
...Nathan
December 5, 2021
Page 5
The photographs at issue were taken in 2019, twenty-five years after Jane was purportedly at the
house and fifteen years after any alleged conspiracy ended.
Although the government can show that the photos accurately reflect Mr. Epstein’s
apartment as it existed in...
DOJ-OGR-00010567.jpg
...b)(2)(B) applies to the use of undue
influence. See United States v. Kohlmeier, 858 F. App’x 444, 446-47 (2d Cir. 2021) (describing
the focus of § 2B1.3(b)(2)(B)); United States v. Arbaugh, 951 F. 3d 167, 173 (4th Cir. 2020) (“By
its plain terms...
DOJ-OGR-00015156.jpg
...This evidence was put before the grand juries in June 2020 and March
2021, in a case that remains on direct appeal. Cf In re National Security Archive, 104 F. Supp.
3d at 628-29 (1950 grand jury testimony regarding Julius and Ethel Rosenberg); Jn re AHA, 49
F. Supp...
DOJ-OGR-00004005.jpg
...Nathan
April 5, 2021
Page 5 of 17
The Defendant argues that Requests | through 5 are not a fishing expedition merely
because the government has admitted “that there were, in fact meetings and communications
between these individuals and the USAO-SDNY about Ms. Maxwell and gg” and
because Virginia Giuffre...
DOJ-OGR-00004713.jpg
...Jeffrey Epstein’s Non-Prosecution Agreement Does Not Bar the Superseding
Indictment
In an Opinion and Order dated April 16, 2021, the Court denied the defendant’s previous
motion to dismiss the Indictment based on a 2007 non-prosecution agreement (“NPA”) between
Jeffrey Epstein and the U.S. Attorney’s...
DOJ-OGR-00007443.jpg
...Nathan
November 11, 2021
Page 7
While some may find this morally reprehensible, or even repugnant, it is perfectly legal and does
not in any way establish a “sexual preference” for underage girls. Moreover, to the extent the
government is seeking to introduce Accuser-3’s evidence to show Epstein...
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...those counts are different in law and fact
for double jeopardy purposes. See United States v. Hicks, 5 F.4th 270, 275 (2d Cir. 2021) (citing
Blockburger v. United States, 284 U.S. 299 (1932)). The defendant asks this Court to ignore the
first Korfant factor because it is fatal...
DOJ-OGR-00002919.jpg
...The defense has now had three bites at that
particular apple and is currently appealing the issues raised therein to the Second Circuit, where
argument is scheduled to take place on April 26, 2021. The introduction of additional charges,
reflecting additional evidence, in no way supports a fourth argument for...
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...1, 2021 Tr. at
6-7.
DOJ-OGR- 00020990
DOJ-OGR-00008243.jpg
...As of
August 17, 2021, the date of the statement from Glassman to the Government, Jane had been paid
by the Epstein Victims Compensation Fund, and her civil case had been dismissed. And Glassman
appears to have advised Jane that the civil cases were fully resolved. See 12/01/21...
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Case 1:20-cr-00330-PAE Document548- Filed 12/15/21 Page2of6
At a conference on November 1, 2021, the Court granted the Government’s motion in
limine to permit alleged victims to testify under pseudonyms and, as a consequence, to redact
their real identities from exhibits. Nov. 1 Tr...
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1/26/22, 8:52PM Case 1:20-cr-00330-Bébis GhidaIDeMEReN [ubisinifally dbubed doaiberd / Air sayPaGaers Of 4
/3 Jeffrey Epstein associate Ghislaine Maxwell sits as the guilty verdict in her sex abuse trial is read ina
courtroom sketch in New York City, U.S., December 29, 2021. REUTERS...
DOJ-OGR-00011187.jpg
...When the Government first provided
notice of Flatley’s testimony in September, the defendant did not object to its sufficiency or file a
motion to preclude, but instead noticed her own counter-expert to Flatley on November 1, 2021,
stating that he would testify about substantially the same subjects. Moreover...
DOJ-OGR-00009867.jpg
1/26/22, 8:52PM Case 1:20-cr-00330-Bébie GhidaiDe MERE [uUBAInifally dbutbed dochbark/ Air sayPaRGaers Of 4
/3 Jeffrey Epstein associate Ghislaine Maxwell sits as the guilty verdict in her sex abuse trial is read ina
courtroom sketch in New York City, U.S., December 29, 2021...
DOJ-OGR-00010378.jpg
...if the same people are serving
the same roles in each phase. United States v. Pena, 846 F. App’x 49, 51 (2d Cir. 2021)
(summary order) (quoting United States v. Berger, 224 F.3d 107, 114-15 (2d Cir. 2000)); see
also United States v. Maldonado-Rivera, 922 F...
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...a harsh sanction not to be
imposed lightly.” /d. at 117; see United States v. Canada, 858 F. App’x 436, 439 (2d Cir. 2021)
(Mem.) (affirming a decision to permit an expert to testify who was noticed “the night before the
last day of trial” because the defendant “would...
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...Nathan
December 14, 2021
Page 8
to either the subject of this trial (alleged sexual abuse and trafficking) or the
subject of his testimony (authenticating and laying foundation for the admission
of a document).
Accordingly, under Rule 608(b), the government may not question Mr. J about the
conduct that...
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