3,013 results for "2021"
Page 93 of 121
DOJ-OGR-00021798.jpg
...United States Attorney’s Office
for the Southern District of New York (“USAO-SDNY”); (2) whether
Maxwell’s second superseding indictment of March 29, 2021 (the
“Indictment”) complied with the statute of limitations; (3) whether the
District Court abused its discretion in denying Maxwell’s Rule 33
motion for a...
DOJ-OGR-00021881.jpg
...United States Attorney’s Office
for the Southern District of New York (“USAO-SDNY”); (2) whether
Maxwell’s second superseding indictment of March 29, 2021 (the
“Indictment”) complied with the statute of limitations; (3) whether the
District Court abused its discretion in denying Maxwell’s Rule 33
motion for a...
DOJ-OGR-00001040.jpg
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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page99 of 200
k7e2MaxC kjc
the det
hiding,
extradition,
community tie
presumption...
DOJ-OGR-00002925.jpg
...STERNHEIA
212-243-1100 © Main 33 West 19th Street - 4th Floor
917-306-6666 ® Cell New York, New York 10011
888-587-4737 © Fax bc@sternheimlaw.com
April 15, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United...
DOJ-OGR-00008791.jpg
...Nathan
December 27, 2021
Page 2
Constructive Amendment / Variance
First, without further instruction, the jury could convict Ms. Maxwell based on a
constructive amendment and/or prejudicial variance from the S2 Indictment. The Court has
recently explained the law on constructive amendment and variance. “To prevail on a constructive
amendment...
DOJ-OGR-00009735.jpg
...TR 11/16/2021, pp 155-59.
Here, too, Juror No. 50 falsely denied having a Twitter account. It also appears
that he was not telling the truth when he said he deleted his Instagram account. But he
also did much more, falsely denying that he had been a victim...
DOJ-OGR-00011422.jpg
...Nathan BOYLE
December 15, 2021 LLP
Page 2
Ms. Maxwell would like to ask Mr. Glassman whether he made a $25 million demand to
Ms. Maxwell to settle the civil case against her. It should be noted that defense counsel did not
question Jane about this demand when they had...
DOJ-OGR-00011461.jpg
Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page11of16
November 19, 2021
Page Eleven
Islands’ probate court order approving the program—and the associated, mandatory
confidentiality protections of the Protocol—provides yet another reason to quash the subpoena.”
See THCF Med. Clinic Recs., 504 F. Supp...
DOJ-OGR-00019958.jpg
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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page99 of 200
k7e2MaxC kjc
the det
hiding,
extradition,
community tie
presumption...
DOJ-OGR-00020276.jpg
...Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 6, 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...
DOJ-OGR-00020313.jpg
Casédse@- trai 330s Asie nt DEcWAeIY/ 2021 , RiRRDO38, 572geRageDof 8
LAW OFFICES OF BOBBI C. STERNHEIA\
government in person to confer on a briefing schedule for supplemental pretrial motions, as well
as other deadlines, which we are prepared to discuss with the Court at the arraignment.
The government’s revised...
DOJ-OGR-00003872.jpg
...The proposed redactions are consistent with the
proposed redactions requested by the Government on pages 158 to 159 and 163 of its opposition
to the defendant’s pre-trial motions, which the Court granted on March 18, 2021. (Dkt. 168 at 1).
The defense has indicated that it has no...
DOJ-OGR-00003933.jpg
...The proposed redactions are consistent with the
proposed redactions requested by the Government on pages 158 to 159 and 163 of its opposition
to the defendant’s pre-trial motions, which the Court granted on March 18, 2021. (Dkt. 168 at 1).
The defense has indicated that it has no...
DOJ-OGR-00005004.jpg
...Nathan
August 18, 2021
Page 4
Insofar as the defendant claims that identification of uncharged co-conspirators is
necessary for her to interpose objections to the admissibility of co-conspirator statements (Dkt.
No. 291 at 10-11), such an argument “misunderstands the hearsay exception for the statements of
co-conspirators...
DOJ-OGR-00005044.jpg
...Maxwell’s first ex parte and in camera motion (“First Motion”)
for issuance of a subpoena to the law firm Boies, Schiller and Flexner LLP (“BSF”), filed with
the Court on February 21, 2021, and Ms. Maxwell expressly incorporates that First Motion by
reference. Because additional subpoenas are necessary for...
DOJ-OGR-00007440.jpg
...Nathan
November 11, 2021
Page 4
PB Hence, even if we assume for the sake of argument that everything Accuser-3 told the
government is true (which we do not concede), her testimony would not in any way establish that
“minors who gave sexualized massages to Epstein were compensated.” Accuser...
DOJ-OGR-00021851.jpg
...United States Attorney’s Office
for the Southern District of New York (“USAO-SDNY”); (2) whether
Maxwell’s second superseding indictment of March 29, 2021 (the
“Indictment”) complied with the statute of limitations; (3) whether the
District Court abused its discretion in denying Maxwell’s Rule 33
motion for a...
DOJ-OGR-00000151.tif
...In addition, on April 18,
2021, the Government produced over 20,000 pages of
interview notes, reports and other materials related to
non-testifying witnesses. After considering the circum-
stances, including the complexity of the issues in this
case and what the defense has already received and
likely learned in...
DOJ-OGR-00001043.jpg
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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page102 of 200 39
k7e2MaxC kjc
obligation to her through emotional
manipulation...
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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page152 of 200
k7e2MaxC kjc
89
1 court is greatly concern by the Bureau of Prisons' ability to
2 keep inmates and detainees safe during the health crisis and
3 has found those considerations to be significant in other
4...
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...Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 23, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, 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...
DOJ-OGR-00006049.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 3, 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-00006612.jpg
...Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 23, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, 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...
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...
DOJ-OGR-00009606.jpg
...Third, the defendant’s “motion is unsupported by any proof that might substantiate a
finding of actual and substantial prejudice as a result of the delay.” Berry, 2021 WL 2665585, at
*2 (citing Birney, 686 F.2d at 106). The defendant’s “bare assertions do not satisfy the ‘definite
and...
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