2,983 results for "2021"
Page 109 of 120
DOJ-OGR-00004011.jpg
...Nathan
April 5, 2021
Page 11 of 17
No. 138 at 2 n.2. Again, however, the Defendant does not explain why Maria Farmer’s
engagement letter with BSF is relevant to support this proposition or is otherwise relevant to the
motion. The Defendant’s conclusory arguments that the engagement...
DOJ-OGR-00004738.jpg
...15-CR-317 (KMW), 2018 WL 2254538, at
*2 (S.D.N.Y. May 17, 2018), aff'd, 988 F.3d 645 (2d Cir. 2021) (collecting cases).
The other theory of relevance that Maxwell proffers is that if the rest of the journal does
not mention her, the journal as...
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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...
DOJ-OGR-00021005.jpg
...which the grand jury voted,” a constructive amendment
occurs and reversal is required. United States v. Khalupsky, 5 F Ath 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...
DOJ-OGR-00004276.jpg
...Based on our review of
the prior statements of non-testifying witnesses, which the government only recently produced to
the defense on April 13, 2021, we know that FBI Special Ac | i i
interviewed the person we believe to be Accuser-4 in connection with the Florida Investigation.
(Ex. C...
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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 Tr. at 18-19, 52-57, 200, 207-08, 259, 293, 532, 635). In the event the Court
believes that details need to be elicited, beyond those few details Juror 50 has provided publicly,
such inquiry should be conducted at sidebar or in camera. See Janniello, 866 F...
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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...
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...5/25/2021
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America
Deferred Prosecution Agreement
Vy.
19 Cr. 830 (AT)
Tova Noel,
Defendant,
TO: TOVA NOEL
On November 19, 2019, a grand jury sitting in this District returned a six-count indictment
(the “Indictment”), which charged...
DOJ-OGR-00003858.jpg
...Nathan
April 15, 2021
Page 6
documents . . . are not protected if a party voluntarily discloses them” and determining that
government waived the work-product privilege even though its disclosure was inadvertent).
iI. The Government Has No “Need” to Know.
The government claims, without support, that “[t]he only way for...
DOJ-OGR-00010345.jpg
...In short, Juror 50’s willingness to disclose his sexual abuse changed to some extent
between November 4, 2021, and January 2022. He made a conscious decision to share the fact
of his sexual abuse with a wider circle of people than he had prior to the time that he...
DOJ-OGR-00010741.jpg
...Cir. 2013) (applying preponderance of of the evidence standard to victim restitution
issue); United States v. Kim, 988 F.3d 803, 809 (Sth Cir. 2021) (same).
Against that backdrop, Kate is a “victim” who has a right to speak at sentencing just as she
was permitted to testify during the...
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...Nathan
April 22, 2021
Page 2
The government says that this Court need not resolve Ms. Maxwell’s motions to
suppress or hold an evidentiary hearing before the trial on the non-perjury counts because it
“does not intend to use these materials”—i.e., any of the materials subject...
DOJ-OGR-00003968.jpg
...Nathan
April 22, 2021
Page 2
The government says that this Court need not resolve Ms. Maxwell’s motions to
suppress or hold an evidentiary hearing before the trial on the non-perjury counts because it
“does not intend to use these materials”—i.e., any of the materials subject...
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...16, 2021 Tr. at 18-19, 52-57, 200, 207-08, 259,
293, 532, 635). In each case, the juror affirmed that he or she could be fair, and not only did the
Court not strike the juror for cause, neither party even moved to do so on these grounds...
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...23, 2021, Final Pretrial Conference Tr. at 31-38. And
second, instructing on state law that the Defendant was not alleged to have violated ran a serious
risk of confusing the jury as to the role of that law. Indeed, it was the Defendant’s proposal that
33
DOJ-OGR...
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...Nathan
November 30, 2021
Page 4
Ms. Maxwell does not have disclose any “books, papers, documents, data, photographs, tangible
objects, buildings or places, or copies or portions of any of these items” she does not intend to
use in her “case-in-chief.”
The government is doubly wrong to say...
DOJ-OGR-00009820.jpg
...16, 2021 Tr. at 18-19, 52-57, 200, 207-08, 259,
293, 532, 635). In each case, the juror affirmed that he or she could be fair, and not only did the
Court not strike the juror for cause, neither party even moved to do so on these grounds...
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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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...at *14 (S.D.N.Y. Aug.
AO 0) eee 7,12
Electra v. 59 Murray Enterprises, Inc., 987 F.3d 233 (2d Cir. 2021) ......ceccesceeeseeeneeeeteeeeeeesneeenees 4
Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1999) oo. ceesssscssecnsecneeseeseesseesaecsaesseesaeeseeseesaeenaeenaesas 7
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999...
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...at *14 (S.D.N.Y. Aug.
AO 0) eee 7,12
Electra v. 59 Murray Enterprises, Inc., 987 F.3d 233 (2d Cir. 2021) ......ceccesceeeseeeneeeeteeeeeeesneeenees 4
Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1999) oo. ceesssscssecnsecneeseeseesseesaecsaesseesaeeseeseesaeenaeenaesas 7
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999...
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...Nathan
December 27, 2021
Page 5
a curative instruction. Moreover, because the same issues arise with respect to the substantive
enticement offense charged in Count Two, the Court must give the same instruction as to Count
Two as well.!
Supplemental Jury Instruction
Second, we believe that the Court’s response...
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...15-CR-317 (KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018), aff'd, 988
F.3d 645 (2d Cir. 2021) (“[A] criminal subpoena should not be used as ‘a discovery device,’ but
999
instead should be used only as ‘a mechanism for obtaining specific admissible...
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...any
? The Court notes that this conclusion does not rely on the Government’s citation in its December 8, 2021, letter to
the transcript of Ms. Maxwell’s April 2016 civil deposition.
5
DOJ-OGR-00008307
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...5, 2021). For example, in a recent murder
trial, the Court permitted the nephew of the victim to describe his uncle’s wounds because the
nephew, who had served as a caretaker, had some information that was not cumulative of the
medical records. The Court expressly cautioned the Government that...
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