1,467 results for "May 11 2021"
Page 28 of 59
DOJ-OGR-00005227.jpg
...Nathan
October 14, 2021
Page 2
Ms. Maxwell’s counsel conferred with the government about the timing for filing a
motion under Rule 412. The government seeks to have the motion briefed before jury selection
begins.
Implicit in the language of Rule 412(c)(1)(B) is authority for the...
DOJ-OGR-00011266.jpg
...Nathan
October 14, 2021
Page 2
Ms. Maxwell’s counsel conferred with the government about the timing for filing a
motion under Rule 412. The government seeks to have the motion briefed before jury selection
begins.
Implicit in the language of Rule 412(c)(1)(B) is authority for the...
EFTA00093448.pdf
...Friday, March 12, 2021 11:44 AM
To: Laura Menninger ;
(USANYS)
Cc: Jeff Pagliuca cjpagliuca@hmflaw.com>• Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
. 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence...
DOJ-OGR-00005627.jpg
...CR-2041-NGG-VMS, 2019 WL 2212639, at *7 (E.D.N.Y. May
22, 2019) ee eeccecseceneesrcnsesecssessessessessecnevsecnseseensessessessevsecaevseeneeseensesessessevsesnevseeneeerensessesaerateaeeneed 9
United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010)... eee eeeeseeeeeneeees 7,8, 10, 11
United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at...
EFTA00098000.pdf
...Friday, March 12, 2021 11:44 AM
To: Laura Menninger ;
(USANYS)
Cc: Jeff Pagliuca , Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
• 'BOBBI C STERNHEIM'
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence...
EFTA00085811.pdf
...WHEREAS, Section 4(a) of the Agreement provides in relevant part that "...in no event
shall the Closing take place later than May 7, 2021 (the "Closing Date")";
WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for
in Section 4(a) until May 13, 2021...
DOJ-OGR-00006578.jpg
Case 1:20-cr-00330-PAE Document 442 Filed 11/12/21 Page 7of12
ARGUMENT
I. By Failing to Comply with the Rule 404(b) Notice Requirement, the
Government Has Waived the Admission of Any Evidence Pursuant to the
Rule
Under the version of Rule 404(b) in effect for...
DOJ-OGR-00006713.jpg
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page5of84
ARGUMENT
1. The Court Should Admit the Testimony of Dr. Lisa Rocchio
The Government intends to call Dr. Lisa Rocchio as an expert witness. Dr. Rocchio is the
President-Elect of the Division of Trauma Psychology at...
DOJ-OGR-00006522.jpg
Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page6 of 40
As noted in the Government’s motion, an order imposing privacy safeguards at trial for
victims of sex crimes is commonplace. See Aug. 3, 2021 Tr. at 53:13-55:2, United States v. Kelly...
EFTA00090656.pdf
...Mon, 24 May 2021 11:58:50 +0000
Inline-Images: image001.prig; image002.png
Just as an FYI, I've looked at our files and we do not have for the files listed in the "overlay", we have no matching MD5s. The
MD5s from the non-nude index are correct...
EFTA00650080.pdf
...OS/11/2021
Call feature: None, i.e. the securities are non-callable
Payment at Maturity: Par ($1,000 per note) + any accrued and unpaid interest
EFTA00650080
Interest Payment Schedule: Quarterly interest payments; The 11th calendar day of each February, May, August and
November during the term of the notes...
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-00011112.jpg
Case 1:20-cr-00330-PAE Document690 Filed 11/19/21 Page4of23
The probative value of the anticipated testimony must of course be balanced with any
potential prejudice under Rule 403. As the Court noted at the November 1 conference, there is a
risk that the jury may confuse the...
EFTA00089904.pdf
...See Hamlett, 2021 WL 5105861, at *2.
Even if any diagnosis were probative, the Court further finds that Rule 403 prejudice
outweighs. First, the testimony may confuse jurors with old diagnoses that have little connection
to the conduct at issue or Alleged Victim 4's credibility today. See id. Confusion...
EFTA00072407.pdf
...Friday, March 12_2021 11:44 AM
To: Laura Menninger
(USANYS)
Cc: Jeff Pagliuca
; Christian R Everdell - Cohen & Gresser LLP
•
;.; 'BOBBI C STERNHEIM' •=
1>
Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been...
DOJ-OGR-00006623.jpg
Case 1:20-cr-00330-PAE Document 443-2 Filed 11/12/21 Page 9 of 12
Lisa Marie Rocchio, Ph.D. 8
Presented at the National Meeting of the American Psychological Association, Honolulu, HI.
Rocchio, L.M. (August 2011). Development of a successful independent group practice in psychology.
Hospitality...
EFTA02731737.pdf
...Wednesday,
November 17, 2021
9
EFTA02731745
11:18 AM
To:
Cc:
Subject: RE:
[EXTERNAL]
/ Leon Black
Great, thanks. My cell
would actually be
better as I'm sitting in
another office right
now.
From:
Sent: Wednesday,
November 17, 2021
11:10 AM
To:
Cc:
Subject: RE:
[EXTERNAL]
/ Leon Black
Thank...
DOJ-OGR-00006086.jpg
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21
Count Two: Enticement to Engage in Illegal Sexual Activity — First Element
The first element of Count Two which the government must prove beyond a reasonable
doubt is that the-defendantMs. Maxwell knowingly persuaded or induced or enticed...
DOJ-OGR-00006453.jpg
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 36 of 69
for admissibility. To the extent the government seeks a pretrial ruling that a// prior consistent
statements may be admitted after any attack on the accusers’ credibility, this Court should deny
such a request.
i...
DOJ-OGR-00015153.jpg
...witnesses at the
2021 Maxwell trial.
B. Application of the In re Craig Factors
In cases involving grand jury testimony of significant historical or public interest, /n re
Craig supplies a framework for evaluating whether disclosure, on balance, is warranted. It
identifies non-exclusive factors that may weigh against disclosure...
DOJ-OGR-00006408.jpg
Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page 48 of 54
IX. The Court Should Preclude Evidence or Argument Sounding in Nullification
The defendant may attempt to offer evidence of aspects of her life that may tend to elicit
the juror’s sympathy, such as...
EFTA00650756.pdf
...he's losing money on ops until 2021 even if everything goes acc to plan.
And as you are aware, there are some personality issues that really underscore the whole "all or nothing" part
On Oct 13, 2014, at 11:16 AM, jeffrey E. wrote:
I'm...
DOJ-OGR-00006580.jpg
...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...
EFTA00093641.pdf
...her
federal complaint. (DE 11) Because she is the victim of sexual assault, her identity is exempt from a F0IA
disclosure. 5 U.S.0 552 (a) (8) (b) (7) (C). She will be referred to as Lola Doe in this letter.
EFTA00093641
September 14, 2021
Page 2
Please contact...
DOJ-OGR-00008191.jpg
...2021. (Dkt. No. 297 at 2).
Accordingly, any exhibits which the defense intends to offer as part of its case-in-chief, whether
through Government witnesses or its own, should have been disclosed at that time. The
Government of course understands that there are circumstances in which intervening event may...
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