2,983 results for "2021"
Page 108 of 120
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...history.” Jd. The
facts surrounding Epstein’s case “tell a tale of national disgrace.” Jn re Wild, 994 F.3d 1244, 1247
(11th Cir. 2021) (discussing the plea agreement secured by Epstein in Florida). The grand jury
records are thus “critical pieces of an important moment in our nation’s...
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...11, 2021).
'8 Td.
15
DOJ-OGR-00004155
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...After considering the arguments in Maxwell’s renewed motion and letter of supplemental
authority, the Court’s view remains unchanged from its April 16, 2021 Opinion & Order. Under
Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of
New York. It thus does...
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...history.” /d. The
facts surrounding Epstein’s case “tell a tale of national disgrace.” Jn re Wild, 994 F.3d 1244, 1247
(11th Cir. 2021) (discussing the plea agreement secured by Epstein in Florida). The grand jury
records are thus “critical pieces of an important moment in our nation’s...
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...As the Court explained in its April 16, 2021 Opinion & Order, the Second Circuit held in
United States v. Annabi that “[a] plea agreement binds only the office of the United States
Attorney for the district in which the plea is entered unless it affirmatively appears that the
agreement contemplates...
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...9] and a trial in the case will be set for April 5, 2021, about two months from today.
Although presumed innocent of all charges, Mr. Robertson has been in pretrial detention
in this case for over three years. He was arrested on December 11, 2017 and was ordered detained...
DOJ-OGR-00004977.jpg
...As the Court explained in its April 16, 2021 Opinion & Order, the Second Circuit held in
United States v. Annabi that “[a] plea agreement binds only the office of the United States
Attorney for the district in which the plea is entered unless it affirmatively appears that the
agreement contemplates...
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...a
reasonable doubt. Juries are not “to act based on their... sympathy.” United States v. Stroming,
838 F. App’x 624, 627 (2d Cir. 2021) (summary order); see, e.g., United States v. Mustaga, 753
F. App’x 22, 37 (2d Cir. 2018) (summary order) (“The district court correctly recognized...
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...Maxwell requests that the Court hold the hearing on November 10, 2021.
The Court gave the parties a simple directive which was to confer and pick a date for the
Daubert and Rule 412 hearing, the options being November 5, 9, or 10. Defense counsel attempted
this conferral and sent...
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...a
reasonable doubt. Juries are not “to act based on their... sympathy.” United States v. Stroming,
838 F. App’x 624, 627 (2d Cir. 2021) (summary order); see, e.g., United States v. Mustaga, 753
F. App’x 22, 37 (2d Cir. 2018) (summary order) (“The district court correctly recognized...
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...Nathan
December 15, 2021
Page 3
Filed 07/12/22 Page3of7
476:2-4 3509-008, p. 10, 4” Jane was asked if Maxwell ever touched or
paragraph kissed her to which she answered, “I don’t think
so.”
476:8-10 3509-005, p. 4,4" full | Jane was...
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...9] and a trial in the case will be set for April 5, 2021, about two months from today.
Although presumed innocent of all charges, Mr. Robertson has been in pretrial detention
in this case for over three years. He was arrested on December 11, 2017 and was ordered detained...
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...As explained above, it is apparent from the non-testifying witness material, which the
government produced just a few weeks ago on April 13, 2021, that Accuser-4 has only recently
included Ms. Maxwell in her allegations of sexual abuse. In her summary of Accuser-4’s
allegations that she...
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...theory of guilt. D’Amelio, 683 F.3d at 419; see also
United States v. Jones, 847 F. App’x 28, 30 (2d Cir. 2021) (summary order) (no constructive
amendment in sex trafficking case where indictment did not allege “advertising” but the
evidence “fell squarely within the charged scheme” (cleaned...
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...Nathan
November 22, 2021
Page 6
impeachment evidence constitutes exculpatory evidence that must be disclosed. The disclosure
of impeachment evidence, where ‘the [g]overnment’s case depended almost entirely on [the
victim’s] testimony,’ goes to the heart of Brady and Giglio.” (quoting Giglio v. United States,
405 U.S...
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...Nathan
November 22, 2021
Page 13
(1) furnishing, promising, or offering--or accepting, promising to accept, or
offering to accept--a valuable consideration in compromising or attempting
to compromise the claim; and
(2) conduct or a statement made during compromise negotiations about the
claim--except when offered in a criminal...
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...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 testtmony about sexual conduct did not describe “illegal sexual
activity” as alleged in the Indictment, which was a legal term that the Court...
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...See, e.g., 11/1/2021 Tr. 68:2-
4 (“With respect to the Mann Act conspiracies, the particular criminal sexual activity relates to a
particular statute in New York.”); Dkt. 410-1 at 52 (“The Government’s proposed instructions
only permit the jury to convict on a violation of...
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...Nathan
November 30, 2021
Page 3
Cases hold the same. E.g., United States v. Medearis, 380 F.3d 1049, 1057 (8th Cir.
2004) (Rule 16(b)(1)(A) does not require defense to disclose evidence he does “not seek to use . .
. in his case-in-chief”); United States v...
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...for trial, balanced against the two counts added by the S2 Indictment are the two perjury counts
severed by the Court’s April 16, 2021 opinion and order. (Dkt. No. 207). In other words, the
defense has long maintained that the perjury counts would substantially expand the scope of the...
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Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page2of6
Draft Pre-Voir Dire Remarks — November 2, 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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...3,
2021 Tr. at 53:13-55:2, United States v. Kelly, No. 19 Cr. 286 (E.D.N.Y.); Oct. 17, 2019 Tr. at
32:1-36:6, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.) Dkt. No. 198 (permitting
use of real first...
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...16, 2021 Tr. at 128:15-19. In response to questioning by
the Court about his knowledge of the defendant from the media, Juror 50 explained that he “heard
when Jeffrey Epstein had died that he had a girlfriend,” and reaffirmed that he was “[a]bsolutely”
able to put aside...
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...16, 2021 Voir Dire Tr. at 133 (stating that he “just got out of a relationship and I didn’t
want to see anything regarding them”).
Distractions continued, and increased, as he neared the end of the questionnaire. Juror 50
testified that he was seated near the table where prospective...
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...But without
such testimony, [defense] counsel had only words such as ‘episodes of rage’ and ‘racing
thoughts.’”); Hamlett, 2021 WL 5105861, at *2 (affirming exclusion of a psychological witness
that failed to show a “clear link between any particular mental health diagnosis and a witness’s
credibility”).
The Defense argues...
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