3,013 results for "2021"
Page 50 of 121
DOJ-OGR-00011247.jpg
...Nathan
May 12, 2021
Page 7
of the same entry, produced in the criminal discovery and attached as exhibit B, is obviously, and
noticeably, different. The remaining six pages are identical except for the identifying bate ranges.
Examination of the original document would answer legitimate questions about whether the
document...
DOJ-OGR-00020311.jpg
Casédse@- trai 330s Asie ntDEcWAeIY/ 2021 , RIRRDO3A, 572gePageDof 8
LAW OFFICES OF BOBBI C. STERNHEIA\
years and elected to commence prosecution of Ms. Maxwell in the throes of the pandemic. A//
counsel have been laboring under the difficulties caused by this unprecedented circumstance.
The government’s challenges pale in comparison...
DOJ-OGR-00003997.jpg
...Nathan
April 22, 2021
Page 10
voluminous photographs from this time period that are in the discovery. The metadata
associated with thousands of these photographs that were produced to counsel (but missing from
Ms. Maxwell’s production) were stripped and included in Excel spreadsheets. One of the Excel
spreadsheets is...
DOJ-OGR-00020947.jpg
...21, 2021 Tr., Dkt. No. 459. The questionnaire
was designed to pre-screen for “the major for-cause strike issues in the case”—that is, “the trial’s
length and schedule, a juror’s personal knowledge of the parties, [the] extent of a juror’s
awareness of publicity about the...
DOJ-OGR-00002529.jpg
Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 26 of 26
Certificate of Service
Thereby certify that on January 25, 2021, I served by email, pursuant Rule 2(B) of the
Court’s individual practices in criminal cases, the Memorandum of Law in Support of...
DOJ-OGR-00002803.jpg
FedEx Ship Manager - Print Your Label(s)
3/24/2021
ORIGIN !D:MPBA (305) 379-6667 SHIP DATE: 24MAR21
DAVID MARKUS ACTWGT:
MARKUS/MOSS PLLC CAD: 9297036/INET4340
40 NW THIRD STREET
PENTHOUSE ONE
MIAMI, FL 33128 BILL SENDER
UNITED STATES US
TO FINANCE DEPARTMENT
US DISTRICT COURT OF NEW...
DOJ-OGR-00004064.jpg
...Nathan
April 30, 2021
Page 2
Accordingly, we respectfully request that the Court issue an order directing the MDC to
accept the master hard drives either from defense counsel or from the government. We will send a
copy of this letter to the MDC Legal Department so that they can...
DOJ-OGR-00008164.jpg
...Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 27, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 82 20...
DOJ-OGR-00011314.jpg
...Nathan
December 6, 2021
Page 4
Finally, at 11:17 p.m. last night (December 5), the government disclosed yet more expert
opinions from Examiner Flatley, again in the form of notes apparently taken by Ms. Pomerantz!
December 5, 2021 Call with Flatley
Pomerantz
Young
e Checked registry file called...
DOJ-OGR-00001459.jpg
Case 21-770, Document 73, 05/27/2021, 3109708, Page19 of 24
nighttime checks involve shining a flashlight directly into her eyes (as opposed to
the ceiling), that the checks in fact disturb her sleep, or that the checks prevent her
from being able to prepare her defense.*
36. It...
DOJ-OGR-00020377.jpg
Case 21-58, Document 92, 05/27/2021, 3109708, Page19 of 24
nighttime checks involve shining a flashlight directly into her eyes (as opposed to
the ceiling), that the checks in fact disturb her sleep, or that the checks prevent her
from being able to prepare her defense.*
36. It...
DOJ-OGR-00000063.tif
...District Court for the Southern District of New
York (April 16, 2021) oo... ccccceessseecceeeessesseenees
APPENDIX E: ORDER, U.S. Court of Appeals
for the Second Circuit (November 25, 2024) ......
APPENDIX F: Excerpts of the Department of
Justice Office of Professional Responsibility
Report (November 2020) ............ccccccccscsssssseeeeeeees
Page
la
24a
39a
52a...
DOJ-OGR-00002308.jpg
Case 1:20-cr-00330-AJN Document 122 Filed 01/25/21 Page 9 of 9
Certificate of Service
Thereby certify that on January 25, 2021, I electronically filed the foregoing
Memorandum of Ghislaine Maxwell in Support of Her Motion to Dismiss Either Count One Or
Count Three of the...
DOJ-OGR-00002318.jpg
Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 8 of 8
Certificate of Service
Thereby certify that on January 25, 2021, I electronically filed the foregoing
Memorandum of Ghislaine Maxwell in Support of Her Motion to Dismiss Counts One through
Four of the Superseding Indictment...
DOJ-OGR-00003673.jpg
...March 15, 2021
New York, New York
Respectfully submitted,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, Colorado 80203
Phone: 303...
DOJ-OGR-00003914.jpg
Case 1:20-cr-00330-PAE Document224 Filed 04/20/21 Page17of17
Certificate of Service
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court’s individual practices in criminal cases, the Reply Memorandum of Ghislaine Maxwell in
Support of Her...
DOJ-OGR-00006206.jpg
...27, 2021)).
Following that decision, the defendant submitted a letter to this Court asking it “to address
Ms. Maxwell’s sleeping conditions by directing MDC to cease 15-minute light surveillance of Ms.
Maxwell or justify the need for the disruptive flashlight surveillance.” (Dkt. 256 at 2). The Court
promptly...
DOJ-OGR-00009123.jpg
...The Jury Selection Process
Before trial, the jury department for the Southern District of New York conducted five
sessions over the course of November 4, 5, and 12, 2021 during which 694 jurors completed a
juror questionnaire approved by the Court. Nov. 15, 2021 Tr. at 2:20-21. The...
DOJ-OGR-00009802.jpg
...The Jury Selection Process
Before trial, the jury department for the Southern District of New York conducted five
sessions over the course of November 4, 5, and 12, 2021 during which 694 jurors completed a
juror questionnaire approved by the Court. Nov. 15, 2021 Tr. at 2:20-21. The...
DOJ-OGR-00011285.jpg
...Nathan
November 15, 2021
Page 3
page 3524-013, page 3 of 8, on May 14, 2021, after being interviewed multiple times, the
witness said:
EPSTEIN noted once that when he and Maxwell dated that MAXWELL would
bring more girls for threesomes, saying they were sexual relationships.
did not recall...
DOJ-OGR-00003868.jpg
Case 1:20-cr-00330-PAE Document 221 Filed 04/20/21 Page4of5
deadline to submit requests for jury selection dates in the third quarter of 2021 is May 15.
Following the submission of requests, the Clerk’s Office will assign jury selection dates
according to a protocol that has...
DOJ-OGR-00020312.jpg
Casédse@- trai 320s Asie ntDEcWAeIY/ 2021 , RiRRDO38, 572geHageDof 8
LAW OFFICES OF BOBBI C. STERNHEIA\
witnesses, including potential FRE 404(b) witnesses, and trial exhibits, the government’s
speculation about the length of the trial is entirely one-sided and lacking in any reliable estimate
of a defense case. The...
DOJ-OGR-00002297.jpg
Case 1:20-cr-00330-AJN Document120 Filed 01/25/21 Page 19 of 19
Certificate of Service
Thereby certify that on January 25, 2021, I electronically filed the foregoing
Memorandum of Ghislaine Maxwell in Support of Her Motion for a Severance of and Separate
Trial on Counts Five and...
DOJ-OGR-00002672.jpg
...January 25, 2021
New York, New York
Respectfully submitted,
/s/ Mark S. Cohen
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, Colorado...
DOJ-OGR-00008802.jpg
...Nathan
January 5, 2021
Page 2
Should the defense prevail on
this motion—and we believe the law and facts are clearly on our side—it would render all other
post-trial motions moot. Ms. Maxwell should not have to expend precious time and resources
briefing other motions when this...
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