185 results for "November 23 2021"
Page 6 of 8
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...Nathan
November 22, 2021
Page 15
Finally, “evidence that a party lied during settlement negations may be admissible to
impeach that party under Federal Rule of Evidence 608(b) when she later testifies at trial,”
Wright & Miller, 23 Fed. Prac. & Proc. Evid., § 5305 Scope—Impeachment by Prior
Inconsistent Statement or...
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Case 1:20-cr-00330-PAE Document 499-1 Filed 11/23/21 Page 178 of 375
Research...
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...Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
November 14, 2021
BY EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge...
DOJ-OGR-00006195.jpg
...STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fax besternhein@mac.com
November 8, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine...
DOJ-OGR-00000935.jpg
...Ghislaine Maxwell,’ The Sun, November 20, 2019, available at:
https://tinyurl.com/3vewtnx3. Anyone facing these unprecedented safety
concerns from the media mob would try to keep a low profile. But a low
23
DOJ-OGR-00000935
DOJ-OGR-00019853.jpg
...Ghislaine Maxwell,’ The Sun, November 20, 2019, available at:
https://tinyurl.com/3vewtnx3. Anyone facing these unprecedented safety
concerns from the media mob would try to keep a low profile. But a low
23
DOJ-OGR-00019853
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20
21
22
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Case 1:20-cr-00330-PAE Document 427 Filed 11/09/21 Page3of16
Draft Pre-Voir Dire Remarks — November 8, 2021
United States v. Maxwell, 20cr330
Preliminary Remarks Prior to Voir Dire
To be recorded and played on 11/16-11/19
Introduction
Welcome back...
DOJ-OGR-00010402.jpg
...Mexico on November 6, 2021, more than three weeks before trial. At
that point, the parties were still litigating the very instructions for Kate and Annie that the
Defendant claims she would have sought for Jane had she received adequate notice. See, e.g.,
Nov. 23, 2021 Tr. at 28...
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...
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Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 23 of 25
The Honorable Alison J. Nathan
November 22, 2021
Page 23
ee
a
DR (cy cannot reasonably claim an entitlement to
confidentiality when that entitlement must be balanced against the truth-seeking function of a...
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20
21
22
23
24
Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page2of6
Draft Pre-Voir Dire Remarks — November 2, 2021
United States v. Maxwell, 20cr330
Preliminary Remarks Prior to Voir Dire
To be recorded and played on 11/16-11/19
Introduction
Welcome back...
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...And when you filled out the questionnaire on
November 4, 2021, you left that blank. What is an accurate
answer to question 48A?
A. I would have put I was abused as a child.
Q. Without listing names, what happened?
A. It was a family member, who is no longer...
DOJ-OGR-00021019.jpg
...Mexico on November 6, 2021, more than three weeks before trial. At
that point, the parties were still litigating the very instructions for Kate and Annie that the
Defendant claims she would have sought for Jane had she received adequate notice. See, e.g.,
Nov. 23, 2021 Tr. at 28...
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...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...
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...November 12, 2021
Ze
DOJ-OGR-00007491
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...I'll see you in
(Adjourned to November 30,
Thank you.
the morning.
SOUTHERN D
STR
CT REPORT
ERS,
(212) 805-0300
PG ew
Have a good
2021 at 8:45 a.m.)
DOJ-OGR-00011770
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...I'll see you in
(Adjourned to November 30,
Thank you.
the morning.
SOUTHERN D
STR
CT REPORT
ERS,
(212) 805-0300
PG ew
Have a good
2021 at 8:45 a.m.)
DOJ-OGR-00016215
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Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page6of13
The Hon. Alison J. Nathan
April 22, 2021
Page 6
are minimal. See United States v. Rojas-Contreras, 474 U.S. 231, 234 (1985) (no prejudice to
superseding indictment which changed the date of offense by ten...
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...73 (ordering the government to
produce documents related to certain non-testifying witnesses by March 12, 2021 “to ensure that
> Ms. Maxwell is still reviewing the discovery, including the over two million pages produced in November 2020.
In deference to the Court’s schedule and in light of the trial...
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Case 1:20-cr-00330-PAE Document 499-1 Filed 11/23/21 Page 15 of 375
Comey, Moe, Pomerantz and Rohrbach
November 1, 2021
Page 14
H. Jennifer Naso
Ms. Naso is a Forensic Document Examiner who worked for and received specialized
training from the United States Secret Service...
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...The Court
concludes that Juror 50’s comment to Annie Farmer on Twitter, made in January 2022, does not
provide a basis to question his testimony that as of November 4, 2021, he did not tell many
people about his sexual abuse.
At bottom, based on Juror 50’s demeanor...
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...Filed 11/23/21 Page 2 of 375
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
O 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
JPagliuca@hmflaw.com
BUA. D DON
MORGAN
FOREMAN
November 1, 2021
VIA EMAIL
Maurene...
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...In an order dated November 21st, 2021,
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Her
leading questions by government
ted testimony on the therapist
to provide more detail about a
ruled that
DOJ-OGR-00013876
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...In an order dated November 21st, 2021,
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Her
leading questions by government
ted testimony on the therapist
to provide more detail about a
ruled that
DOJ-OGR-00016500
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...The Government, in its letter to the Court, is simply fronting the reasons why
the completion of discovery will likely not occur by November 9, 2020.
Ms. Maxwell, when agreeing to a trial in July 2021, outside the time limits established by
18 U.S.C. § 3161, thought that she...
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