3,013 results for "2021"
Page 73 of 121
DOJ-OGR-00020375.jpg
Case 21-58, Document 92, 05/27/2021, 3109708, Page17 of 24
of confinement do not warrant temporary release. Nothing in Maxwell’s renewed
motion alters that conclusion.
32. “Asa general matter, this Court will adhere to its own decision
at an earlier stage of the litigation.” United States v...
DOJ-OGR-00000936.jpg
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page26 of 31
profile is not flight. Ms. Maxwell could have left the United States had
she wanted to flee. She did not want to do that and she did not do that.
Instead, she chose to stay here and...
DOJ-OGR-00001375.jpg
Case 21-770, Document 57, 04/19/2021, 3080288, Page3 of 30
that the presumption of innocence is more than mere words on a page.
This Reply responds to the arguments the Government does raise:
1. The Court did not conduct a “lengthy bail hearing.” Resp.§2.
The transcript of...
DOJ-OGR-00007556.jpg
...www.parkdietzassociates.com
CURRICULUM VITAE (July 15, 2021)
Park Dietz, M.D., M.P.H., Ph.D.
CURRENT POSITIONS:
1996-
1990-
1987-
1987-
1981-
EDUCATIO
1970 A.B.
President, Park Dietz & Associates, Inc., Newport Beach,
California, and Washington, DC (Employer ID: 33-
0690184) (PD&A is a multidisciplinary forensic firm...
DOJ-OGR-00008190.jpg
...Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 30, 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-00019854.jpg
Case 21-58, Document 39-1, 04/01/2021, 3068530, Page26 of 31
profile is not flight. Ms. Maxwell could have left the United States had
she wanted to flee. She did not want to do that and she did not do that.
Instead, she chose to stay here and...
DOJ-OGR-00020293.jpg
Case 21-58, Document 76, 04/19/2021, 3080288, Page3 of 30
that the presumption of innocence is more than mere words on a page.
This Reply responds to the arguments the Government does raise:
1. The Court did not conduct a “lengthy bail hearing.” Resp.§2.
The transcript of...
DOJ-OGR-00020343.jpg
...Defendant-Appellant Ghislaine Maxwell appeals from orders of the District Court entered
December 28, 2020 and March 22, 2021, which denied her renewed requests for bail pending trial.
See Dkts. 1,20. Upon due consideration, it is hereby ORDERED that the District Court’s orders
are AFFIRMED and that Appellant...
DOJ-OGR-00001432.jpg
...Defendant-Appellant Ghislaine Maxwell appeals from orders of the District Court entered
December 28, 2020 and March 22, 2021, which denied her renewed requests for bail pending trial.
See Dkts. 1,20. Upon due consideration, it is hereby ORDERED that the District Court’s orders
are AFFIRMED and that Appellant...
DOJ-OGR-00012859.jpg
...fair to say through 2012,
So
Filed 08/10/22
you just said when you were in your early 30s,
it's 2021,
Page 108 of 261 1269
you said you don't have one. Please tell m
probably within ten
You just stopped at some point?
Yes.
you were...
DOJ-OGR-00018445.jpg
...fair to say through 2012,
So
Filed 08/10/22
you just said when you were in your early 30s,
it's 2021,
Page 108 of 261 1269
you said you don't have one. Please tell m
probably within ten
You just stopped at some point?
Yes.
you were...
DOJ-OGR-00001332.jpg
Case 21-770, Document 40-1, 04/12/2021, 3075763, Page15 of 25
ARGUMENT
The District Court Properly Denied Maxwell’s Motions for Bail and
Temporary Release
27. Judge Nathan did not clearly err when she determined that
Maxwell is a risk of flight and that no conditions would reasonably...
DOJ-OGR-00001379.jpg
Case 21-770, Document 57, 04/19/2021, 3080288, Page? of 30
erroneously adopted its conclusory proffer.
5. Ms. Maxwell’s intention to evade the media does not even
marginally amount to risk of flight. Resp.{33. The Government does not
dispute that the media placed a bounty on Ms...
DOJ-OGR-00005623.jpg
...Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
October 11, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203...
DOJ-OGR-00011322.jpg
...Nathan
December 12, 2021
Page 3
felt constrained not to help or not to be fully forthright in their testimony, which is exactly what
will happen if these three witnesses are not given the same consideration as was given the
government’s witnesses. Indeed, defense counsel have encountered significant resistance...
DOJ-OGR-00019797.jpg
Case 21-58, Document 23, 03/29/2021, 3065988, Page2 of 24
APPEAL,ECF,INTAPP
U.S. District Court
Southern District of New York (Foley Square)
CRIMINAL DOCKET FOR CASE #: 1:20-cr-—00330-AJN All Defendants
Case title: USA v. Maxwell Date Filed: 06/29/2020
Assigned to: Judge...
DOJ-OGR-00020249.jpg
Case 21-58, Document 58-1, 04/12/2021, 3075763, Page15 of 25
ARGUMENT
The District Court Properly Denied Maxwell’s Motions for Bail and
Temporary Release
27. Judge Nathan did not clearly err when she determined that
Maxwell is a risk of flight and that no conditions would reasonably...
DOJ-OGR-00020269.jpg
...Nathan
January 14, 2021
Page 2
would not require any change in Ms. Maxwell’s movements to give her the requested access.
Furthermore, on at least three occasions since she was released from quarantine, Ms. Maxwell’s
security team gave her the laptop to review discovery on the weekend.
There...
DOJ-OGR-00020297.jpg
Case 21-58, Document 76, 04/19/2021, 3080288, Page? of 30
erroneously adopted its conclusory proffer.
5. Ms. Maxwell’s intention to evade the media does not even
marginally amount to risk of flight. Resp.{33. The Government does not
dispute that the media placed a bounty on Ms...
DOJ-OGR-00000841.jpg
Case 21-770, Document 1-2, 03/24/2021, 3065965, Page2 of 24
APPEAL,ECF,INTAPP
U.S. District Court
Southern District of New York (Foley Square)
CRIMINAL DOCKET FOR CASE #: 1:20-cr-—00330-AJN All Defendants
Case title: USA v. Maxwell Date Filed: 06/29/2020
Assigned to...
DOJ-OGR-00000879.jpg
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page3 of 25
APPEAL,ECF,INTAPP
U.S. District Court
Southern District of New York (Foley Square)
CRIMINAL DOCKET FOR CASE #: 1:20-cr-—00330-AJN All Defendants
Case title: USA v. Maxwell Date Filed: 06/29/2020
Assigned to...
DOJ-OGR-00000931.jpg
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page21 of 31
requires relief. Add to that the barriers she is facing to preparing her
defense and this Court should order her release under 3142(i).
II. The trial court erred in relying on the government’s
proffer—which...
DOJ-OGR-00008439.jpg
...Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
December 19, 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, S2 20...
DOJ-OGR-00019747.jpg
Case 21-58, Document 20-2, 03/24/2021, 3065965, Page2 of 24
APPEAL,ECF,INTAPP
U.S. District Court
Southern District of New York (Foley Square)
CRIMINAL DOCKET FOR CASE #: 1:20-cr-—00330-AJN All Defendants
Case title: USA v. Maxwell Date Filed: 06/29/2020
Assigned to...
DOJ-OGR-00019773.jpg
Case 21-58, Document 21-2, 03/24/2021, 3065978, Page3 of 25
APPEAL,ECF,INTAPP
U.S. District Court
Southern District of New York (Foley Square)
CRIMINAL DOCKET FOR CASE #: 1:20-cr-—00330-AJN All Defendants
Case title: USA v. Maxwell Date Filed: 06/29/2020
Assigned to...
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