3,013 results for "2021"
Page 51 of 121
DOJ-OGR-00006207.jpg
...May 17, 2021)). In the motion, she renewed her claims
that the “horrific conditions [at MDC] make it impossible to prepare for trial.” (Ud. at 2; see also
id. at 2-3 (listing alleged horrific conditions, such as sleep deprivation, brown water, surveillance
of attorney-client meetings, overflowing sewage, computer...
DOJ-OGR-00006208.jpg
...907 (PAC), 2021 WL 371782, at *1 (S.D.N.Y. Feb. 3, 2021) (motion for reconsideration
of bail requires defendant to show “controlling decisions or data that the court overlooked—
matters, in other words, that might reasonably be expected to alter the conclusion reached by the
court” (internal citation...
DOJ-OGR-00001412.jpg
Case 21-770, Document 70-1, 05/17/2021, 3102450, Page6 of 14
letter to district court) (“MDC legal counsel has informed the government
that the defendant cannot be provided with an eye mask.”). So Ms.
Maxwell tries to shield her eyes with a sock or towel. Trying to sleep...
DOJ-OGR-00002435.jpg
...January 25, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957...
DOJ-OGR-00007493.jpg
Case 1:20-cr-00330-PAE
Document 499
Filed 11/23/21
Certificate of Service
Page 28 of 28
I hereby certify that on November 12, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Response to the Government’s Motion in Limine to Preclude Expert Testimony of Dr.
Park...
DOJ-OGR-00020330.jpg
Case 21-58, Document 89-1, 05/17/2021, 3102450, Page6 of 14
letter to district court) (“MDC legal counsel has informed the government
that the defendant cannot be provided with an eye mask.”). So Ms.
Maxwell tries to shield her eyes with a sock or towel. Trying to sleep...
DOJ-OGR-00010329.jpg
...During five sessions held over three days on November 4, 5, and 12, 2021, 694
prospective jurors completed the questionnaire. See Nov. 15, 2021 Tr. at 2, Dkt. No. 529.
Counsel reviewed the completed questionnaires and jointly submitted four lists to the Court: (1)
prospective jurors that both sides agreed...
DOJ-OGR-00010707.jpg
...447, 489 (2021). As Eleventh Circuit
16
DOJ-OGR-00010707
DOJ-OGR-00011134.jpg
...20-3768-CR, 2021 WL 4805218, at *2 (2d Cir.
Oct. 15, 2021).
Il. Discussion
As a preliminary matter, the Defense argues that the Government’s motion is
“premature” because the Government’s arguments are about the relevance and prejudice of the
DOJ-OGR-00011134
DOJ-OGR-00011141.jpg
...20-3768-CR, 2021 WL 4805218, at *2 (2d Cir.
Oct. 15, 2021).
Il. Discussion
As a preliminary matter, the Defense argues that the Government’s motion is
“premature” because the Government’s arguments are about the relevance and prejudice of the
witnesses’ testimony, not their qualifications or the reliability...
DOJ-OGR-00011368.jpg
...Nathan
December 16, 2021
Page 6
e In February 2020, Jane told the government that Eva was Mr. Epstein’s ex-girlfriend and
they stayed friends, just as Mr. Visoski testified. When the group massages began to
involve others beyond Mr. Epstein, Ms. Maxwell joined in with Sophie and Eva...
DOJ-OGR-00015135.jpg
Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page3of31
two perjury counts.’ It ended on December 29, 2021, with Maxwell’s conviction on five of the
six counts and her acquittal on the substantive enticement count.
The evidence adduced at trial is well-summarized in Judge...
DOJ-OGR-00020308.jpg
Casédse@- trai) 330s Asie ntDEcWAerY/ 2021 , RiRRDO38, 572g Rage Dof 8
LAW OFFICES OF BOBBI C. STERNHEIA\
investigation in 2007 (see Dkt. 199 at 1-2), long before commencing this prosecution against Ms.
Maxwell. We cannot adequately prepare for a trial containing the new charges and a
substantially expanded conspiracy...
DOJ-OGR-00005006.jpg
...Nathan
August 19, 2021
Page 2
The exhibits to the motion also attach documents that were obtained independent of the
criminal discovery. We submit that it is the government’s burden to justify any redactions to these
documents under Lugosch.!
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP...
DOJ-OGR-00005621.jpg
Case 1:20-cr-00330-PAE Document385 _ Filed 10/29/21 Page12of12
Certificate of Service
I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Motion to Exclude Any Evidence Offered by the Government Pursuant to Fed. R.
Evid. 404(b) for Failure to...
DOJ-OGR-00005705.jpg
...See 4/16/2021 Op. and Order (Dkt. 207) at 23-26; Fed. R.
Evid. 403.
BACKGROUND
The Court has already ruled that the perjury counts must be severed because trying the
perjury counts with the other counts in the indictment would risk admitting evidence that would
be “unduly prejudicial...
DOJ-OGR-00015134.jpg
...On March 29, 2021, a different
grand jury in this District returned a second superseding indictment. It added two counts, based
on a fourth minor victim, to whom it also referred pseudonymously. One charged a sex
trafficking conspiracy, in violation of 18 U.S.C. § 371; the other charged sex...
DOJ-OGR-00005023.jpg
...Nathan
August 30, 2021
Page 5
scheduling deadlines, this Court considered the parties’ positions, and it made a decision. Dkt.
297 at 1. The government has offered nothing to justify reconsideration.
Conclusion
Ms. Maxwell asks this Court to confirm what it already ordered: (1) that the government
disclose the identities...
DOJ-OGR-00005390.jpg
...October 27, 2021
New York, New York
DOJ-OGR-00005390
DOJ-OGR-00006583.jpg
Case 1:20-cr-00330-PAE Document 442 Filed 11/12/21 Page12o0f12
Certificate of Service
I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Motion to Exclude Any Evidence Offered by the Government Pursuant to Fed. R.
Evid. 404(b) for Failure...
DOJ-OGR-00011321.jpg
...Nathan
December 12, 2021
Page 2
Shawn). And during that time, and mostly at the request of the government, the Court on at least
forty-five occasions has admitted an exhibit or series of exhibits either partially or fully under
seal to protect the identity or privacy of a victim...
DOJ-OGR-00005824.jpg
...867 (PKC), 2021 WL 1851996, at *2 n.2 (S.D.N.Y. May 10, 2021).
The defense vaguely asserts that it cannot perform an independent investigation into the
Rule 404(b) evidence due to the inadequacy of the Government’s notice. (Def. Mot. 2 at 5-6).
That conclusory...
DOJ-OGR-00006749.jpg
...867 (PKC), 2021 WL 1851996, at *2 n.2 (S.D.N.Y. May 10, 2021).
The defense vaguely asserts that it cannot perform an independent investigation into the
Rule 404(b) evidence due to the inadequacy of the Government’s notice. (Def. Mot. 2 at 5-6).
That conclusory...
DOJ-OGR-00002436.jpg
Case 1:20-cr-00330-AJN Document136 Filed 02/04/21 Page 27 of 27
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 Ms...
DOJ-OGR-00002825.jpg
...Jd, The Jury
Plan provides that “the number of names drawn from each county should be proportionate to the
number of registered voters in that county.” Allen, 2021 WL 431458, *1.
The two master wheels draw from a different array of counties. The Manhattan master
wheel randomly draws names from...
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