803 results for "November 15 2021"
Page 15 of 33
DOJ-OGR-00011286.jpg
...Nathan
November 15, 2021
Page 4
surrounding the statement during the trial and evaluate admissibility prior to any attempt by the
government to introduce the statement. The government should be instructed that it cannot
discuss the alleged statement in its opening remarks.
Similarly, the second example concerns direction from Epstein...
EFTA00085038.pdf
...MoNo Building
One Saint Andrew's Plaza
New York New York 10007
November 29, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Laura Menninger, Esq.
ism
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below...
EFTA00094633.pdf
...Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203...
EFTA00072474.pdf
...I/15/2
January 14, 2021
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, to respectfully request that the Court
order the Bureau of Prisons to give Ms. Maxwell access to the laptop computer provided by...
DOJ-OGR-00011465.jpg
Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page15of16
November 19, 2021
Page Fifteen
inconsistent statement or a contradiction.” Fed. R. Evid. 408(a). The Court should decline to
uphold the subpoena based on a possible permissible use under Rule 408(b) when the most
readily...
EFTA00073592.pdf
...MoNo Building
One Saint Andrew's Plaza
New York New York 10007
November 24, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen. Es 4.
Laura Menninger, Esq.
Bobbi Stemheim, Es .
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed...
EFTA00078120.pdf
...January II, 2021, Government responses be
due on February 12, 2021, and defense replies be due on February 19, 2021. Second, the defense
asked that the Government provide a laptop for the defendant to use to review her discovery inside
the Metropolitan Detention Center ("MDC") by November 23, 2020. The...
DOJ-OGR-00019254.jpg
...Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 ( Discovery due...
DOJ-OGR-00019272.jpg
...Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020. Motions are due by Monday, December 21, 2020. Motion
responses are due by Friday, January 22, 2021. Motion replies are due by Friday,
February 5, 2021. Trial is set for Monday, July 12, 2021 ( Discovery due...
EFTA00157056.pdf
November 29, 2021 Meeting with Dr. Rocchio
•
Loftus studies are laboratory based; lot of her research has been done with credible person
telling someone that something happened to them; Loftus studies say can get people to
endorse false details and experiences that haven't occurred
•
Wouldn't just see something...
DOJ-OGR-00008063.jpg
...At the conference on November 1, 2021,
the Court precluded “affirmative evidence by the defense that goes to the thoroughness of the
investigation,” (11/01/21 Tr. at 17:15-17), including “evidence of the public outcry and scrutiny
that preceded the decision to charge the defendant,” (id. at 21...
EFTA00087194.pdf
...Nathan
United States District Court
Southern District of New York
United States Courthouse
November 10, 2021
The parties are ORDERED to submit the lists
referenced in this letter on or before November 14,
2021, in accordance with Dkt. No. 427. The parties
may continue submitting proposed redactions in
accordance with...
EFTA00058414.pdf
...MOI dated February 15, 2022, regarding Interview
BOP, with attachments.
U.S. Department of Justice
Office of the Inspector General
DATE:
CASE NUMBER:
2019.010614
EFTA00058414
14. MOI dated July 27, 2021, regarding Interview of
BOP, with
attachments.
15. Email dated July 31, 2019, from
o NYM/Executive Staff at...
DOJ-OGR-00011459.jpg
Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page9of16
November 19, 2021
Page Nine
Argument
The subpoena should be quashed because (i) compliance would be unreasonable or
oppressive; (ii) it seeks documents that are inadmissible under Rule 408 of the Federal Rules of
Evidence; and (iii...
EFTA00099089.pdf
...Mono Building
One Saint Andrew's Plana
New York, New York /0007
November 10, 2021
The parties are ORDERED to submit the lists
referenced in this letter on or before November 14,
2021, in accordance with Dkt. No. 427. The parties
may continue submitting proposed redactions in
accordance with the...
EFTA00102344.pdf
...Mono Building
One Saint Andrew's Plana
New York, New York /0007
November 10, 2021
The parties are ORDERED to submit the lists
referenced in this letter on or before November 14,
2021, in accordance with Dkt. No. 427. The parties
may continue submitting proposed redactions in
accordance with the...
EFTA00088748.pdf
...IT IS FURTHER STIPULATED AND AGREED THAT this stipulation,
marked as Government Exhibit 1004, and Government Exhibits I1, 12, 13, 14, 15, and 16, may
be received in evidence at trial.
Dated:
November
2021
New York, New York
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York...
DOJ-OGR-00010301.jpg
...at 13:15).
After asking Juror 50 how he would have answered those follow-up questions on the
questionnaire, the Court took Juror 50 “back in time” to November 16, 2021, the day of voir dire,
and asked Juror 50 the additional questions it would have asked that day had...
DOJ-OGR-00011456.jpg
Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page6of16
November 19, 2021
Page Six
C. The Critical Importance of Confidentiality to the EVCP and Similar Programs
Ms. Feldman’s declaration explains why confidentiality is so critical to programs like the
EVCP.”? As she notes, “it can...
EFTA02730486.pdf
...2/26/2021 11:14
an
2/26/2021 11:13
580
2/24/2021 15:21
579
2/24/2021 14:48
578
2/23/2021 20:21
fl
2/23/2021 17:06
576
2/23/2021 14:00
575
2/23/2021 13:59
514
2/23...
DOJ-OGR-00011284.jpg
...Nathan
November 15, 2021
Page 2
Indictment occurred in 2004. It is Ms. Maxwell’s position that any post-2004 statements by
Epstein or other alleged co-conspirators were not in furtherance of any conspiracy at issue in this
case.
The first exemplar is a statement allegedly from Epstein to...
EFTA00159745.pdf
...November 18 2021 11:49 AM
>
Re: [EXTERNAL] Re: travel
743 (added pages).pdf; IMG_1152.jpg; 742 (added pages) .pdf
Daniel Besselsen
Hi
See attached as requested for GX 742 and 743. I included all the pages in the attachments, those pages that you had
previously and the few...
DOJ-OGR-00007410.jpg
...Nathan
November 15, 2021
Page 2
page that the government intends to offer has various handwritten notations on the copy. The
book, as an entire document, contains numerous handwritten notations, added tabs, and
additional handwritten pages. The government does not explain how the one selected page is
authentic and does...
DOJ-OGR-00005227.jpg
...Maxwell should not be required to file her Rule 412 motion any time
before November 15, since it was just three days ago (October 11) that the government disclosed
its 3500 material, including more than 8,000 pages of testifying witness disclosures. It will
require significant time and resources to...
DOJ-OGR-00011266.jpg
...Maxwell should not be required to file her Rule 412 motion any time
before November 15, since it was just three days ago (October 11) that the government disclosed
its 3500 material, including more than 8,000 pages of testifying witness disclosures. It will
require significant time and resources to...
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