2,983 results for "2021"
Page 105 of 120
DOJ-OGR-00001296.jpg
...As bad as
the pandemic had been to that point, the Court did not expect the federal judiciary to remain in a
state of near total suspension for another six months, requiring the trial to be continued twice more
to the current April 5, 2021 trial date. Second, when the...
DOJ-OGR-00002918.jpg
...The Government contacted defense counsel
on March 29, 2021 to convey its availability for a call to discuss some of the issues above as well
as a supplemental briefing schedule for certain of the defendant’s pending motions, among other
issues. Although such a call has not yet taken place...
DOJ-OGR-00004987.jpg
...The Court has ordered the Government to disclose all Jencks Act and Giglio material by
October 11, 2021. Dkt. No. 297 at 1. That date is seven weeks in advance of trial. The Court
sees no reason to depart from the rule in this district that impeachment material of anticipated...
DOJ-OGR-00006416.jpg
...Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
August 30, 2021
BY FIRST CLASS MAIL
Mr. Kenneth A. Polite, Jr.
Assistant Attorney General
Criminal Division
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, D.C. 20530-0001
Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN...
DOJ-OGR-00007685.jpg
...13, 30, 2021.
* Boldface indicates Ryan C. W. Hall, MD
ABSTRACTS/POSTERS:
1. Hall RCW, Hazard SC, Hall RCW, Pacheco CA, Blakey RE, Abraham J: Thyroid
Disease in Eating Disordered and Depressed Patients.
-146th Annual Meeting, American Psychiatric Association, May 25, 1993, San
Francisco, CA, P.1.57 (Poster Session...
DOJ-OGR-00008144.jpg
...13, 30, 2021.
* Boldface indicates Ryan C. W. Hall, MD
ABSTRACTS/POSTERS:
1. Hall RCW, Hazard SC, Hall RCW, Pacheco CA, Blakey RE, Abraham J: Thyroid
Disease in Eating Disordered and Depressed Patients.
-146th Annual Meeting, American Psychiatric Association, May 25, 1993, San
Francisco, CA, P.1.57 (Poster Session...
DOJ-OGR-00011244.jpg
...Nathan
May 12, 2021
Page 4
and is belied by an “understanding” months earlier where the government represented that
Accuser-2 “stopped writing in her journal about a month after” her meeting with Epstein, Dkt.
100, p.11 n.2.
Incredibly, the government has never examined or taken possession of...
DOJ-OGR-00011433.jpg
...Nathan
November 22, 2021
Page 10
interview on July 17, 2020. See 3500 material at 3505-067. Of course, this is the first time that
Ms. Maxwell’s name surfaces. The economic incentives here are obvious—having settled her
claims in 2009, Accuser-4 needed new, more sensational information to...
DOJ-OGR-00020214.jpg
...As bad as
the pandemic had been to that point, the Court did not expect the federal judiciary to remain in a
state of near total suspension for another six months, requiring the trial to be continued twice more
to the current April 5, 2021 trial date. Second, when the...
DOJ-OGR-00003956.jpg
...Attorneys in other districts; or (11) cover Maxwell specifically,
as “evidence supporting Maxwell’s interpretation of the NPA” that it would be required to disclose.
(See April 16, 2021 Opinion, Dkt. No. 207, at 8, 3-7 (discussing the bases for Maxwell’s motion
under the NPA)). As set forth...
DOJ-OGR-00003975.jpg
...Nathan
April 2, 2021
Page 4
communications” between “the law enforcement entity, Virginia Giuffre, David Boies, Stan
Pottinger, Sigrid McCawley, Paul Cassell, [and] Brad Edwards.” Curiously, although the
government purportedly subpoenaed all of the BSF files relating to Giuffre v. Maxwell,’ the
production from the government to Ms. Maxwell does...
DOJ-OGR-00005449.jpg
...Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
August 30, 2021
BY FIRST CLASS MAIL
Mr. Kenneth A. Polite, Jr.
Assistant Attorney General
Criminal Division
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, D.C. 20530-0001
Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN...
DOJ-OGR-00010560.jpg
...If anything, the
fact that the defendant will be sentenced under the 2004 Guidelines, and not the higher range under
the 2021 Guidelines, should be a factor that warrants a higher sentence. Indeed, the Supreme Court
has expressly noted that sentencing courts may consider subsequent increases in offense levels for...
DOJ-OGR-00020822.jpg
...The Court has ordered the Government to disclose all Jencks Act and Giglio material by
October 11, 2021. Dkt. No. 297 at 1. That date is seven weeks in advance of trial. The Court
sees no reason to depart from the rule in this district that impeachment material of anticipated...
DOJ-OGR-00002422.jpg
...19, 2021 Hearing at 6-7 (emphasis supplied). After
finding that the questions were “far afield” from the allegations in the case, Judge Preska kept
sealed or redacted the entire testimony that forms the basis of Count 6.
ARGUMENT
I. Poorly Worded Questions and Literally Truthful Responses Cannot Support
a...
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...Nathan
April 1, 2021
Page 4
Publicity concerning pretrial suppression hearings such as the one involved in
the present case poses special risks of unfairness. The whole purpose of such
hearings is to screen out unreliable or illegally obtained evidence and insure
that this evidence does not become known to...
DOJ-OGR-00004002.jpg
...Nathan
April 5, 2021
Page 2 of 17
she may not use Rule 17 to circumvent Rule 16. For this reason and the additional reasons
explained below, the Court should deny the Defendant’s motion to authorize the Subpoena to BSF.
1. Requests 1-5: Communications About the Defendant and...
DOJ-OGR-00008184.jpg
...the ken
of the average person,” and so is not proper expert testimony. United States v. Felder, 993 F.3d
57, 72 (2d Cir. 2021). The Court finds that jurors do not require expert testimony that, for
example, lying, intoxication, or severe personality disorders that cause hallucinations can lead to...
DOJ-OGR-00009006.jpg
...18-2825, 2021 WL 2822179
Ge, CSF, TORT Pg DOE Ph comenaes ames cosas ace MEMES HEE SOE SOMERS SE SERENE SSE. COMRERNIRNES HEE eH 46
Murphy v. Nogam, No. CV 14-4268 (KM), 2018 WL 278735 (D.N.J. Jan. 3, 2018) ...... 46
Neder v. United States, S27 WS...
DOJ-OGR-00010392.jpg
...1, 2021 Tr. at 67-68. The second limiting
instruction pertained to Annie, who testified about sexual contact in New Mexico only. The
instruction explained that her testimony about sexual conduct did not describe “illegal sexual
activity” as alleged in the Indictment, which was a legal term that the Court...
DOJ-OGR-00011210.jpg
...Kate described the home in an interview
with the Government on September 1, 2021, a report of which was produced to the defense on
October 11. See 3513-037 at 8 (FBI 302); 3513-038 at 12 (underlying notes). Although Kate did
not give the street address, she identified the...
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...Nathan
December 16, 2021
Page 3
testimony are tested.” Davis, 415 U.S. at 316. The importance of cross-examination cannot be
overstated where, as here, the government’s proof depends almost entirely on the uncorroborated
testimony of the accusers. Poventud v. City of New York, No. 07 CIV. 3998...
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...Nathan
November 22, 2021
Page 9
Maxwell and the jury have a right to know to what extent, if any, the accusers claimed that Ms.
Maxwell was involved in the alleged abuse. As this Court well knows, the accusers have been
anything but consistent on this front.
Accuser-4, for...
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...For the very same reasons, the Jencks Act and
404(b) evidence should be produced to the defense no later than March 12, 2021.
For the reasons set forth below, the Court should grant Ms. Maxwell’s request for a bill
of particulars and her other requests for pretrial disclosures...
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...STERNHEIA
212-243-1100 © Main 33 West 19th Street - 4th Floor
917-306-6666 ® Cell New York, New York 10011
888-587-4737 ° Fax bc@sternheimlaw.com
April 29, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United...
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