Court Filing - Letter to Judge: 521
Summary
The letter, filed by Ghislaine Maxwell's attorneys, argues that Maxwell has a constitutional right to call Jane's attorney, Robert Glassman, as a witness to testify about his advice to Jane regarding cooperating with the government and testifying against Maxwell. The attorneys contend that the attorney-client privilege does not apply or has been waived, and that Glassman's testimony is relevant to Jane's credibility and Maxwell's defense.
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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: 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: 528
The document is a letter from the US Department of Justice to Judge Alison J. Nathan arguing that the defense's motion to call Jane's attorney, Robert Glassman, to testify should be denied due to attorney-client privilege and lack of probative value under Rule 403. The government asserts that Glassman's conversations with Jane are privileged and that the defense's theories for why the privilege does not apply are without merit.
Court Filing - Letter Motion: 120366003830
The letter is a reply in support of Ghislaine Maxwell's request to modify a protective order to allow her to disclose certain information to civil litigation under seal. The government opposes the request, claiming it will jeopardize an ongoing criminal investigation, but Maxwell's attorney argues that the government's arguments lack merit.
Letter to the Court: 120366003830-Adt. Doc.0812412530-Filing808908P20ePage01of03
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.
Court Filing - Letter to Judge: 547
The defense attorney, Bobbi C. Sternheim, writes to Judge Alison J. Nathan arguing against the government's attempt to limit Dr. Loftus's expert testimony on the science of memory and suggestive questioning. The letter cites examples from witness testimony and government interviews, asserting that the government's actions are an effort to restrict relevant testimony and undermine the defendant's right to a defense.
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