2,267 results for "2020"
Page 68 of 91
DOJ-OGR-00006901.jpg
...Court should reject the government’s untimely effort to save
Rocchio’s testimony from exclusion. See United States v. Lewis, 818 F. App’x 74, 79 (2d Cir.
2020) (unpublished) (affirming exclusion of defendant’s proffered expert evidence “that did not
adhere to the discovery schedule”).
15
DOJ-OGR- 00006901
DOJ-OGR-00006921.jpg
...as to 1-3, until 2020 3g had never claimed Ms. Maxwell
participated in any abuse and never identified Ms. Maxwell -- indeed, she had never before been
asked to identify Ms. Maxwell. Concerning number 4 J was less than certain, as
demonstrated by her selection of someone else who may...
DOJ-OGR-00019560.jpg
...In the opening paragraph of her
reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose
under seal to certain judicial officers the following factual information:
1. Grand jury subpoenas were issued to an entity (“Recipient”) after the Government
opened a grand jury investigation...
DOJ-OGR-00001749.jpg
...In the opening paragraph of her
reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose
under seal to certain judicial officers the following factual information:
1. Grand jury subpoenas were issued to an entity (“Recipient”) after the Government
opened a grand jury investigation...
DOJ-OGR-00010453.jpg
...On July 6, 2020, exactly a year to the day after Epstein’s arrest, Ms. Maxwell was ordered
detained in the Metropolitan Detention Center (“MDC”) based on the government’s assertion that
she posed “an extreme risk of flight” and that “no condition or combination of conditions will
reasonably assure...
DOJ-OGR-00022070.jpg
...On January 23, 2020, the Government produced additional interview reports and
? The Government does not concede that production of all of the materials was required
under Rule 16, but nonetheless produced the materials in its possession out of an abundance of
caution.
DOJ-OGR-00022070
DOJ-OGR-00025085.jpg
...Inserted NCS]
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19/2020 10:39:22 AM
Spit Shft Officer
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New Status
Sick Leave Fb}(6); (DUTCH: (BYTE
(b(6) (bIWC}: (OMT MF)
(Time Change...
DOJ-OGR-00020099.jpg
CaSmai@2Otc680Re0ANbnt Docume We07 , FI6ES 1B ade4Pagel Bf 4
MINISTERE a _ ;
DE LA JUSTICE Direction des affaires criminelles et des graces
Liberté
Egatité
Fraternité
Sous-direction de la justice pénale spécialisée
Bureau de l’entraide pénale internationale
Paris, le 11 décembre 2020
Monsieur le garde des Sceaux, ministre de la...
DOJ-OGR-00002607.jpg
...Media reports regarding the November 2020 OPR report further support Ms. Maxwell’s
position. Only the executive summary of the OPR report was released to the public, and the
30
DOJ-OGR-00002607
DOJ-OGR-00003957.jpg
...The Government’s Collection and Review of Other Agencies’ Files
On October 7, 2020, the Government submitted a letter to the Court setting forth its plan
for collecting and reviewing certain files from other agencies with potential relevance to this case.
(Dkt. No. 63). Although Second Circuit law did not...
DOJ-OGR-00004821.jpg
...In fact, Cosby claimed that the two never
[J-100-2020] - 8
DOJ-OGR-00004821
DOJ-OGR-00004870.jpg
...22 Ultimately, the court did not grant the defendant relief under a theory of detrimental
reliance because there was “no claim in this case of such reliance.” Scotland, 614 F.2d
at 365.
[J-100-2020] - 57
DOJ-OGR-00004870
DOJ-OGR-00008208.jpg
...are intended by the client to be made public or revealed to third persons,
obviously the element of confidentiality is wanting.”) (8th ed. Jan. 2020 update). Jane’s
motivation for cooperating with the government and testifying against Ms. Maxwell is essential
to the government’s assessment of Jane’s credibility...
DOJ-OGR-00008377.jpg
...2 The defendant would also elicit from Scarola that, during a 2020 meeting, Scarola told the
Government that he had shown Carolyn a picture of the Epstein associate with the same name as
Jane, but Carolyn could not identify the person at the time. But the defendant did not ask...
DOJ-OGR-00008907.jpg
...1:19-cv-010125 (ALC), 2020 WL 5819864, at *2
2087306.1
DOJ-OGR-00008907
DOJ-OGR-00002824.jpg
...On June 8, 2020, however, the Government sought and obtained a
third superseding Indictment from a grand jury sitting in the District’s White Plains courthouse.
(Schulte Br, at 2; Gov’t Opp. Br. at 2.) The Indictment charges Schulte with nine criminal
counts relating to his alleged transmission of...
DOJ-OGR-00008368.jpg
...are intended by the client to be made public or revealed to third
persons, obviously the element of confidentiality is wanting.”) (8th ed. Jan. 2020 update).
Finally, Carolyn’s motivation for cooperating with the government and testifying against Ms.
Maxwell is essential to the jury’s assessment of Carolyn’s...
DOJ-OGR-00001304.jpg
...Robertson filed his motion for reconsideration on December
21, 2020. Doc. 274. The government had a month and a half to investigate alternatives and make
its argument against release. It cannot wait until an unfavorable ruling to present additional
evidence that it was capable of presenting in the first instance...
DOJ-OGR-00001744.jpg
...The Defendant’s Conditions of Confinement
In her August 10, 2020 letter motion, the Defendant also sought “an order directing
[BOP] to release Ms. Maxwell into the general population and provide Ms. Maxwell with
increased access to the discovery materials while she is detained so that she can meaningfully
participate...
DOJ-OGR-00003859.jpg
...Maxwell attempted to negotiate reciprocal protective order protections in
July 2020, but the government steadfastly then insisted that a separate negotiation would
occur at an undefined later time to any materials to be produced by defense counsel. Defense
counsel is prepared to confer with the government at the appropriate time...
DOJ-OGR-00005210.jpg
...A Tsunami of Pretrial Publicity About this Case
Countless articles, books, podcasts, television shows, and docuseries from various
sources have been published and broadcast concerning this case since it was filed in July 2020.
This followed closely on the heels of an avalanche of media reports preceding and following
Epstein...
DOJ-OGR-00020222.jpg
...Robertson filed his motion for reconsideration on December
21, 2020. Doc. 274. The government had a month and a half to investigate alternatives and make
its argument against release. It cannot wait until an unfavorable ruling to present additional
evidence that it was capable of presenting in the first instance...
DOJ-OGR-00001393.jpg
...Govt
Itr at 4-5) ignores the reality that time is needed to:
= supplement pending pretrial motions;
* critically review voluminous discovery produced in November 2020 that the
government represented was not relevant to the case against Ms. Maxwell;
= re-review discovery for the new time period and charges;
= commence new...
DOJ-OGR-00005823.jpg
...The defense claims that the Government’s October 11, 2021 notice was inadequate in light
of the 2020 amendments to Rule 404(b). The Government provided the defense with a letter, and
corresponding disclosures, seven weeks before trial. In fact, the defense has had the seven exhibits
for much longer...
DOJ-OGR-00006748.jpg
...The defense claims that the Government’s October 11, 2021 notice was inadequate in light
of the 2020 amendments to Rule 404(b). The Government provided the defense with a letter, and
corresponding disclosures, seven weeks before trial. In fact, the defense has had the seven exhibits
for much longer...
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