3,013 results for "2021"
Page 99 of 121
DOJ-OGR-00003982.jpg
...Nathan
April 2, 2021
Page 11
defendants and material either to his guilt or eventual punishment such evidence must be made
available to that defendant as Brady material.”).
Request 10 is another piece of physical evidence, boots purportedly purchased by Epstein
for alleged victim 2. Once again, the government has...
DOJ-OGR-00004994.jpg
...Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
August 18, 2021
VIA 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-00020000.jpg
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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page141 of 200 78
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because the conduct is 25 years...
DOJ-OGR-00003977.jpg
...Nathan
April 2, 2021
Page 6
impeachment material. Accordingly, the Court “encourages the government to
obtain evidence that may be relevant to the credibility and impeachment of its
witnesses and disclose this information” to the defendants as soon as practicable.
By contrast, in this case, the government has scrupulously avoided...
DOJ-OGR-00006964.jpg
...Those excerpts have been marked as Government Exhibits
52A through 52F and were produced to the defense on October 11, 2021.' Most notably,
Government Exhibit 52G, which the Government intends to offer,” contains | s—‘sCiY
Employee-1 is expected to testify that, while working for Epstein in. Employee-1 was...
DOJ-OGR-00011316.jpg
...Nathan
December 6, 2021
Page 6
The government did not timely disclose Examiner Flatley’s expert opinions, waiting until
November 26, December 3, and late last night to make the disclosures. Under Rule of Criminal
Procedure 16(d)(2), this Court can exclude these opinions.
Rule 16(d)(2) says...
DOJ-OGR-00014542.jpg
...So somehow in 2021,
that people get added
very year and taken away every
a black address book shows up on the
SOUTHERN
D
STR
CT REPORT
ERS,
(212)
805-0300
PG ew
DOJ-OGR-00014542
DOJ-OGR-00017163.jpg
...So somehow in 2021,
that people get added
very year and taken away every
a black address book shows up on the
SOUTHERN
D
STR
CT REPORT
ERS,
(212)
805-0300
PG ew
DOJ-OGR-00017163
DOJ-OGR-00005847.jpg
...The defense, citing Zaylor, accuses the Government of willfully violating the Court’s September
3, 2021 Order. (See Def. Mot. 1 at 6-7; see id. at 3 (accusing the Government of “attempting to
overstuff an already full sandbag”)). The Government did no such thing. The Government has
simply read...
DOJ-OGR-00005852.jpg
...Minor
Victim-4 then mentioned the defendant by description or by name in 2007, 2009, 2020, and 2021,
all prior to being shown the photo book. And the circumstances of the identification were not
suggestive. Minor Victim-4 was shown 20 photos, LT rrrr——eee—ee
ee. She was not...
DOJ-OGR-00008267.jpg
...Nathan
December 8, 2021
Page 3
(D) all these conditions are shown by the testimony of the custodian or another
qualified witness, or by a certification that complies with Rule 902(11) or (12) or
with a statute permitting certification; and
(E) the opponent does not show that the source...
DOJ-OGR-00009543.jpg
...Background
On December 29, 2021, the jury returned a verdict in this case, finding the Defendant
guilty of five counts. A week after the jury announced its verdict, on January 5, 2022, the
Government informed the Court that a juror had given at least three post-verdict interviews to
DOJ...
DOJ-OGR-00011335.jpg
...Nathan
December 13, 2021
Page 3
First, Ms. Maxwell did not contravene Rule 16. As a matter of reciprocal discovery, that
Rule requires the defense to disclose an item to the government if “the defendant intends to use
the item in the defendant’s case-in-chief at trial.” Fed...
DOJ-OGR-00001062.jpg
ay
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page121 of 200 58
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regular contact with the government,
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...1995)
(examining caselaw); see also Allen, 2021 WL 431458 (stating that the “Second Circuit has not
stated a preference for the use of one wheel over the other”). In Rioux, for example, the Second
Circuit observed that the “relevant jury poo! may be defined by: (1) the master list; (2...
DOJ-OGR-00003979.jpg
...Nathan
April 2, 2021
Page 8
Regardless, the government has failed to produce, or even look for these communications
and Ms. Maxwell has no other means to obtain them.
Requests 6 and 7
Requests 6 and 7 request the engagement agreements between BSF and alleged victim 2
and her sister...
DOJ-OGR-00005615.jpg
...On October 11, 2021, the Government served on defense counsel a short letter entitled
the “Maxwell Rule 404(b) letter’ (the “Rule 404(b) Letter” or the “Letter’’), attached as Exhibit
A. Init, the Government referenced two sets of evidence: (2) x
2
(b) a Witness i who worked for...
DOJ-OGR-00006772.jpg
...The defense, citing Zaylor, accuses the Government of willfully violating the Court’s September
3, 2021 Order. (See Def. Mot. 1 at 6-7; see id. at 3 (accusing the Government of “attempting to
overstuff an already full sandbag”)). The Government did no such thing. The Government has
simply read...
DOJ-OGR-00006777.jpg
...Minor
Victim-4 then mentioned the defendant by description or by name in 2007, 2009, 2020, and 2021,
all prior to being shown the photo book. And the circumstances of the identification were not
suggestive. Minor Victim-4 was shown 20 photos, LT rrrr——eee—ee
ee. She was not...
DOJ-OGR-00011431.jpg
...Nathan
November 22, 2021
Page 8
As explained below, the government’s relevance arguments also fall short.
1. Payment Records.
The payment records are relevant for an obvious reason: They show how much money
each accuser was paid in relation to their claims against Mr. Epstein based on his conduct...
DOJ-OGR-00019980.jpg
ay
Case 21-58, Document 39-2, 04/01/2021, 3068530, Page121 of 200 58
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regular contact with the government,
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DOJ-OGR-00005227.jpg
...Nathan
October 14, 2021
Page 2
Ms. Maxwell’s counsel conferred with the government about the timing for filing a
motion under Rule 412. The government seeks to have the motion briefed before jury selection
begins.
Implicit in the language of Rule 412(c)(1)(B) is authority for the...
DOJ-OGR-00009567.jpg
...and fairly inform the defendant of the charge against which he
must defend.” United States v. Khalupsky, 5 F.4th 279, 293 (2d Cir. 2021). “[W]hen the charge
upon which the defendant is tried differs significantly from the charge upon which the grand
jury voted,” a constructive amendment occurs...
DOJ-OGR-00010404.jpg
...The Court has twice
concluded that “nothing in the record indicates that the Government’s delay in bringing these
charges was designed to thwart Maxwell’s ability to prepare a defense.” Maxwell, 2021 WL
3591801, at *5. It is the Defendant’s burden to prove the Government’s improper motive...
DOJ-OGR-00011266.jpg
...Nathan
October 14, 2021
Page 2
Ms. Maxwell’s counsel conferred with the government about the timing for filing a
motion under Rule 412. The government seeks to have the motion briefed before jury selection
begins.
Implicit in the language of Rule 412(c)(1)(B) is authority for the...
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