3,013 results for "2021"
Page 76 of 121
DOJ-OGR-00007347.jpg
...Smith
patrick.smith@smithvillazor.com
T 212.582.4400
SMITH | VILLAZOR
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
November 18, 2021 DOC #:
BY E-MAIL to NathanNYSDChambers@nysd.uscourts.gov DATE FILED: 11/19/21 __
The Honorable Alison J. Nathan
United States District Judge
Southern District of New York The Clerk of...
DOJ-OGR-00020300.jpg
Case 21-58, Document 76, 04/19/2021, 3080288, Page10 of 30
paradise,’ not one of the most notorious prisons in America. A “day room.”
Two computers. Recreation. Eye masks. But the Government’s description
of Ms. Maxwell’s conditions is not true. For example, she has no eye
mask...
DOJ-OGR-00000046.tif
...On March 29, 2021, the government added in its
superseding indictment an alleged sex trafficking
offense (Count Six) related to conduct and offenses
wholly within the timeframe and subject matter cov-
ered by the NPA. The sole complainant to the allega-
tions in Count Six had been presented to the...
DOJ-OGR-00001327.jpg
Case 21-770, Document 40-1, 04/12/2021, 3075763, Page10 of 25
Government’s proffer that “additional evidence, including flight records and other
witnesses’ corroborating testimony, will further support the main witnesses’
testimony and link [Maxwell] to Epstein’s conduct.” (/d. at 10). She thus concluded
that the case...
DOJ-OGR-00003675.jpg
...Trial is set to
begin on July 12, 2021.
Maxwell filed twelve pretrial motions seeking to dismiss portions of the S1 superseding
indictment, suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and...
DOJ-OGR-00005042.jpg
...September 3, 2021 A \) ia
New York, New York
ALISON J. NATHAN
United States District Judge
DOJ-OGR-00005042
DOJ-OGR-00008209.jpg
...Nathan
December 3, 2021
Page 4
protection ... .” See Fed. R. Evid. 502(a) (defining the limits of such a waiver as to undisclosed
or inadvertently disclosed information); /n re Steinhardt Partners, L.P., 9 F.3d 230, (2d Cir.
1993) (when a party voluntarily discloses otherwise privileged information to the...
DOJ-OGR-00011360.jpg
...Nathan
December 15, 2021
Page 5
Filed 07/12/22 Page5of7
B. Carolyn Inconsistent Statements!
Trial Testimony
Prior Inconsistent
Statement Cite
Prior Inconsistent Statement Quote
1564: 4-7, 1565:18-
23
3505-005, page 1,
2d paragraph
Virginia approached [Caryoln] at a party and
asked her if she would like...
DOJ-OGR-00011363.jpg
...Pagliuca
oO 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jeagliuca@hmflaw.com
HADDON
MORGAN
FOREMAN
December 16, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York...
DOJ-OGR-00020244.jpg
Case 21-58, Document 58-1, 04/12/2021, 3075763, Page10 of 25
Government’s proffer that “additional evidence, including flight records and other
witnesses’ corroborating testimony, will further support the main witnesses’
testimony and link [Maxwell] to Epstein’s conduct.” (/d. at 10). She thus concluded
that the case...
DOJ-OGR-00000926.jpg
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page16 of 31
the real ability to meet with your lawyers face-to-face while being kept
up all night and being given inedible food makes it virtually impossible,
and violates Ms. Maxwell’s constitutional rights.
Section 3142(1) makes...
DOJ-OGR-00001322.jpg
Case 21-770, Document 40-1, 04/12/2021, 3075763, Paged of 25
allegations in the Indictment are supported by the detailed, credible testimony of
three different victim-witnesses. (See, e.g., Ex. A at 5; Ex. F at 9-10). Each victim-
witness’s testimony is not only corroborated...
DOJ-OGR-00004167.jpg
...March 15, 2021
2 Tf this Court concludes an affidavit is required before it holds a hearing, Maxwell requests
leave, as she did in her Motion, to attempt to obtain such an affidavit. But if, as is likely, none of the
participants—e.g., AUSA yg, AUSA J, Boies, Edwards...
DOJ-OGR-00005867.jpg
...October 25, 2021
New York, New York
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
By: /s/
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
partner in the narcotics distribution conspiracy. Garcia, 413 F.3d at 216. That is distinguishable
from cases...
DOJ-OGR-00006792.jpg
...October 25, 2021
New York, New York
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
By: /s/
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
partner in the narcotics distribution conspiracy. Garcia, 413 F.3d at 216. That is distinguishable
from cases...
DOJ-OGR-00008268.jpg
...Nathan
December 8, 2021
Page 4
For her part, Ms. Maxwell wasn’t even shown a book, let alone a book that was either
two inches thick or 1/4 inch thick. She was shown photocopies of pages from something, the
origin of which no one knows.
Second, even if...
DOJ-OGR-00010473.jpg
...Maxwell including 14 sessions with her from
October 2020 to August 2021, including a battery of psychological tests to assess whether any
psychological matters were present that might be relevant to the disposition of her criminal matters.
In summary, Dr. Bardey determined:
Ms. Maxwell’s ability to cope with the...
DOJ-OGR-00011311.jpg
...Pagliuca
oO 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jeagliuca@hmflaw.com
HADDON
MORGAN
FOREMAN
December 6, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York...
DOJ-OGR-00011356.jpg
...Pagliuca
oO 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
joagliuca@hmflaw.com
HADDON
MORGAN
FOREMAN
December 15, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York...
DOJ-OGR-00012064.jpg
...Well, what you said to the government in October of 2021 at
4 3509-28 in the handwritten notes is, it was just Epstein, mom
5 and you present, correct?
6 MS. MOE: Again, your Honor, I think we've been over
7 reading documents that are not in evidence...
DOJ-OGR-00017653.jpg
...Well, what you said to the government in October of 2021 at
4 3509-28 in the handwritten notes is, it was just Epstein, mom
5 and you present, correct?
6 MS. MOE: Again, your Honor, I think we've been over
7 reading documents that are not in evidence...
DOJ-OGR-00019844.jpg
Case 21-58, Document 39-1, 04/01/2021, 3068530, Page16 of 31
the real ability to meet with your lawyers face-to-face while being kept
up all night and being given inedible food makes it virtually impossible,
and violates Ms. Maxwell’s constitutional rights.
Section 3142(1) makes...
DOJ-OGR-00020239.jpg
Case 21-58, Document 58-1, 04/12/2021, 3075763, Paged of 25
allegations in the Indictment are supported by the detailed, credible testimony of
three different victim-witnesses. (See, e.g., Ex. A at 5; Ex. F at 9-10). Each victim-
witness’s testimony is not only corroborated...
DOJ-OGR-00023476.jpg
...The OIG determined that as
of August 2021—nearly 3 years after MCC New York contracted for replacement camera equipment—the
system upgrade still had not been completed.*’
87 The BOP temporarily closed MCC New York in October 2021 due to substandard conditions that are unrelated to this
investigation and...
DOJ-OGR-00007464.jpg
...Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 23, 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, 20 Cr...
Search Tips
- Use quotes for exact phrases:
"flight manifest" - Use OR for alternatives:
bank OR financial - Use wildcard for partial matches:
invest* - Exclude words:
document -redacted - Search names:
John Smith