2,983 results for "2021"
Page 106 of 120
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...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-00011112.jpg
...1, 2021 Tr. at 89-90. There is also the risk that the jury
may convict Ms. Maxwell due to feelings of immorality or sympathy for the witness despite the
lack of illegality with regard to the crimes charged in the Indictment. However, the Court
concludes that this risk of...
DOJ-OGR-00011430.jpg
...Nathan
November 22, 2021
Page 7
(“Nor was its evidentiary relevance under Rule 401 affected by the availability of alternative
proofs of the element to which it went... . If, then, relevant evidence is inadmissible in the
presence of other evidence related to it, its exclusion must rest not on the...
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Casédse@- trai 330s Asie ntDEcWAeIY 2021 , RiLRDO3A, 572ge Rage of 8
LAW OFFICES OF BOBBI C. STERNHEIA\
The defense has tried to streamline its review of the discovery even before the filing of
superseding indictment by using term searches and key word searches. But given the nature of
the discovery...
DOJ-OGR-00002875.jpg
...Nathan
March 29, 2021
Page 2
District of Florida during the course of the Florida Investigation. As a result of that review, the
Government has learned that agents assigned to the FBI New York Office assisted the FBI Florida
Office by contacting and interviewing or attempting to interview, at the...
DOJ-OGR-00003983.jpg
...Nathan
April 2, 2021
Page 12
justification for payment of the funds. BSF does not explain why it claims the submissions are
“witness statements” and cites no authority for this proposition. Second, because the material is
not in the possession of the government it is not a “statement” falling within...
DOJ-OGR-00003996.jpg
...Nathan
April 22, 2021
Page 9
Defense counsel’s investigative efforts should commence promptly and should
explore appropriate avenues that reasonably might lead to information relevant to
the merits of the matter, consequences of the criminal proceedings, and potential
dispositions and penalties. Although investigation will vary depending on the
circumstances...
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Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 10 of 16
November 19, 2021
Page Ten
Confidentiality was a “cornerstone” of the EVCP,"! “critical” to its success,” and of “paramount
importance.”“? Confidentiality was an indispensable term necessary to interested parties’
support for the EVCP.“4...
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Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page3of16
Draft Pre-Voir Dire Remarks — November 8, 2021
United States v. Maxwell, 20cr330
Preliminary Remarks Prior to Voir Dire
To be recorded and played on 11/16-11/19
Introduction
Welcome back...
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...Nathan
December 27, 2021
Page 4
Despite the government’s confidence, Court Exhibit #15 indicates that the jury is
considering a conviction on Count Four based on Jane’s travel to and from New Mexico and
alleged sexual abuse that purportedly took place in New Mexico. Should the jury convict...
DOJ-OGR-00011357.jpg
...Nathan
December 15, 2021
Page 2
Filed 07/12/22 Page 2of7
448:12 — 15
3509-007, p. 3, para. 13
Doe was sitting alone on a bench between
classes when Epstein and Maxwell approached
her.
450:21 —451:15
3509-028, p. 1
At first tea w/ Epstein, just...
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...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 E-Mail Acct. Controlled & Maintained by Microsoft Corp., 829 F.3d 197, 206
(2d Cir. 2016), vacated and...
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...See Allen, 2021 WL
431458, at *11 (finding same error to have had “minimal” effect on venires). And as to the latter
claim, the parties concede that this glitch actually augmented, not diminished, African American
and Hispanic American representation in the White Plains master wheel. (Gov't Opp. Br. at...
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...7 On February 11, 2021, to help gather facts relevant to the reporting contained in the New York
Daily News article, the USAO-SDNY and the FBI conducted a telephonic interview of AUSA-1.
Notes of that interview are attached as Exhibit 4.
?8 Peter Skinner of Boies Schiller is...
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...Nathan
April 5, 2021
Page 16 of 17
(“A general assertion that certain material ‘might contain exculpatory information’ is insufficient
to prevail against a motion to quash under Rule 17(c).”). BSF has no duty to cull through broad
sets of documents to determine whether any Brady materials might exist...
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...Nathan
August 30, 2021
Page 4
If disclosure of the witness and exhibit lists were by themselves sufficient to give Ms.
Maxwell notice of the specific co-conspirator statements the government intends to admit at trial,
this Court would not have separately ordered the government to disclose “co-conspirator
statements...
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...11, 2021 Sealed Tr., at
194). But at present, the defendant has identified no relevant fact testimony that Dr. Hall could
offer. Because his expert testimony is similarly inadmissible, he should be excluded as a witness
absent further developments at trial.
10 To be clear, although Dr. Hall could conceivably...
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...Nathan
November 30, 2021
Page 5
Criminal Procedure, and nothing in any of them suggests that impeachment evidence is
discoverable.”).
Because Ms. Maxwell offered the photograph while cross-examining Jane during the
government’s case-in-chief and not as “evidence in chief” during her own “case-in-chief,”
Moore...
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...age of
16). This is well more than required by the Guidelines. See United States v. Telles, 18 F 4th 290,
303 (9th Cir. 2021) (applying the enhancement where “Telles sexually abused T.B. on two separate
occasions—the first night he arrived in the United Kingdom and the second...
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...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.” Jd. at 20 (cleaned up).
Court Exhibit #15 indicates that...
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...Nathan
April 5, 2021
Page 10 of 17
Il. Requests 6 and 7: Engagement Letters
The Defendant provides no explanation at all as to how engagement agreements between
BSF and Annie and Maria Farmer would be relevant and admissible at trial, and thus cannot clear
the Nixon hurdles. She states...
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...It advised the Court it would be able to provide Rule 404(b) notice back
in May 2021. Dkt. 229 at 3. With the trial continuance, it gained an additional five months. See
Dkt. 297.
There is no acceptable excuse for failure to follow the requirements of the Rule. Given...
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...which the grand jury voted,” a constructive amendment
occurs and reversal is required. United States v. Khalupsky, 5 F 4th 279, 293 (2d Cir. 2021).
“To prevail on a constructive amendment claim, a defendant must demonstrate that either
the proof at trial or the trial court’s jury instructions so...
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...On March 29, 2021, a grand jury sitting in this District returned a superseding indictment
(the “Indictment”) which charged the defendant in eight counts. (Dkt. No. 187). Count One of
the Indictment charged the defendant with conspiring with Jeffrey Epstein and others to entice
minors to travel to engage in...
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...Nathan
May 12, 2021
Page 6
of 3500 Material: (1) a statement by the witness, (2) in the possession of the United States, (3)
that relates to the subject matter of the witness's testimony.”).
This case now involves a ten-year time period beginning 27 years ago. The indictment...
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