court filing: 20-cv-01484-DG-RML
Summary
The court is considering a stay of civil proceedings against Maxwell due to the overlap with a related criminal case. The Government has confirmed that the allegations in the civil case will touch on matters related to the pending Indictment. The court notes that the status of the criminal case is a significant factor in determining whether to grant a stay.
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Court Filing - Motion: 393
Ghislaine Maxwell's motion to preclude law enforcement witnesses from offering expert opinion testimony without proper disclosure and qualification under Federal Rules of Evidence and Criminal Procedure. The motion argues that the government should not be allowed to circumvent disclosure requirements and the court's gatekeeping role by presenting expert testimony from law enforcement officers as lay witnesses.
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 - Memorandum in Support of Motion: 134
Ghislaine Maxwell's attorneys argue that the government circumvented a protective order in a civil case, Giuffre v. Maxwell, to obtain evidence used in her criminal prosecution. They request that the court suppress this evidence and dismiss Counts Five and Six of the indictment due to the government's alleged misconduct.
Court Filing - Memorandum of Law: 148
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.
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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