Court Filing - Memorandum of Law: 148
Summary
This memorandum of law supports Ghislaine Maxwell's motion for a bill of particulars and pretrial disclosures, requesting the court to order the government to provide specific information and evidence. The motion includes requests for disclosure of exculpatory and impeachment material under Brady and Giglio, as well as other evidentiary materials. The document is a key part of Maxwell's defense strategy in her criminal trial.
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Court Filing - Memorandum in Support of Motion to Dismiss: 124
Ghislaine Maxwell's attorneys argue that the Superseding Indictment is too vague, failing to identify specific dates, accusers, or details of alleged crimes, and thus violates her constitutional rights. They request that Counts One through Four be dismissed or that the court direct the government to provide a Bill of Particulars.
Court Filing: 135
The document is a Notice of Motion filed by Ghislaine Maxwell's defense team, requesting the court to dismiss Counts Five and Six of the Superseding Indictment. The motion argues that the alleged misstatements are not perjurious as a matter of law. The filing includes the signatures of multiple defense attorneys representing Maxwell.
Court Filing - Reply Memorandum: 103
This reply memorandum supports Ghislaine Maxwell's renewed motion for bail, arguing that the government's case relies heavily on the testimony of three witnesses without significant contemporaneous documentary evidence. Maxwell's defense presents a substantial bail package, including a bond secured by her and her spouse's assets and additional sureties, arguing that these conditions reasonably assure her appearance in court.
Court Filing - Memorandum in Support of Motion to Strike Surplusage: 146
Ghislaine Maxwell's defense team files a motion to strike surplusage from the superseding indictment, arguing that allegations regarding Accuser-3 are irrelevant, prejudicial, and should be stricken or subject to the admissibility requirements of Fed. R. Evid. 404(b). The memorandum contests the government's inclusion of Accuser-3's allegations, claiming they do not support the charges against Maxwell.
Court Filing - Reply Memorandum: 171
This is a reply memorandum filed by Ghislaine Maxwell's attorneys in support of her third motion for bail. The memorandum argues that the court retains jurisdiction to decide on bail despite a pending appeal and presents a comprehensive bail package with strict conditions. It also disputes the government's opposition to bail, particularly regarding the renunciation of Maxwell's foreign citizenship as a condition of release.
Court Filing - Reply Memorandum of Law: 209
This is a reply memorandum of law in support of Ghislaine Maxwell's motion to dismiss counts one through six of the superseding indictment due to pre-indictment delay. The defense argues that the government's delay has prejudiced Maxwell's ability to investigate and defend herself, and that the government's failure to provide adequate discovery has exacerbated this issue. The defense requests that the court defer consideration of the motion until after the government has produced all relevant discovery.
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