Letter to the Court: 120366003830-Adt. Doc.0812412530-Filing808908P20ePage01of03
Summary
The letter, submitted by Ghislaine Maxwell's counsel, proposes redactions to her Request to Modify Protective Order and Reply, and objects to the government's proposed redactions, arguing they go beyond what is required by the Protective Order.
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Court Filing - Letter to Judge: 709
The letter is a response to the government's November 12, 2021, letter to the court, objecting to certain categories of alleged co-conspirator hearsay statements and representative examples proffered by the government. The defense argues that these statements are not in furtherance of any conspiracy and are therefore inadmissible. The letter also requests that the court exclude certain statements under Fed. R. Evid. 403 due to their prejudicial impact.
Court Filing - Letter to Judge: 722
The letter, filed by Jeffrey S. Pagliuca on behalf of Ghislaine Maxwell, notifies the court and the government of the defendant's intention to present extrinsic evidence of prior inconsistent statements made by witnesses Jane and Carolyn during their testimonies. The letter details specific inconsistencies between the witnesses' trial testimonies and their prior statements as recorded in 3500 materials.
Court Filing: 12036600638
The document is a court filing in the case against Ghislaine Maxwell, where her defense counsel requests the court to modify a protective order to allow her to refer to and file under seal certain materials in related civil litigation. The government opposes this request, citing concerns about grand jury secrecy and ongoing investigations.
Court Filing: 331
The document is a court filing by Ghislaine Maxwell's defense team, responding to the government's letter dated August 18, 2021. The defense argues that the government is attempting to reconsider previous court orders regarding the disclosure of co-conspirators' identities and statements, and urges the court to confirm its previous orders.
Court Filing: 525
The defense responds to the government's letter arguing that the '900 series photos' of Jeffrey Epstein's apartment are inadmissible due to lack of authentication and relevance, as they were taken in 2019, long after the alleged events. The defense argues that without testimony confirming the photos accurately depict the apartment during the relevant time period, they are irrelevant and potentially misleading. The court had previously sustained the defense's objection to the photos' admission.
Court Filing: 721
The defense is requesting that the court preclude the government from cross-examining a witness, Mr. □, about a regulatory settlement agreement, arguing that it is irrelevant and inadmissible under Rules 608 and 403. The witness is a retired British Solicitor who will testify to authenticate documents related to Ghislaine Maxwell's purchase of a property.
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