Court Filing: Case1:20-cr-00030-PAE
Summary
The court discusses the application of § 3283 to the defendant's offenses involving the sexual abuse of a minor and determines that Counts Three and Four qualify under this statute. The court also addresses Maxwell's argument that certain counts are barred by the statute of limitations, referencing relevant case law such as Landgraf v. USI Film Products.
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Court Filing: 704
The government opposes Ghislaine Maxwell's request to allow three defense witnesses to testify using pseudonyms or first names, arguing that it is unprecedented and not necessary to protect the defendant's constitutional rights. The government contends that the witnesses do not fit into established categories of witnesses who are permitted to testify anonymously, such as victims of sex abuse or undercover law enforcement officers.
Court Filing: 708
The prosecution responds to the defendant's letter regarding prior inconsistent statements, agreeing to stipulate to certain statements while objecting to others as inadmissible or cumulative. The letter outlines the applicable law and discusses specific statements, providing tables to clarify their positions on each statement.
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.
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: DOJ-OGR-00021862
The court discusses the application of 18 U.S.C. § 3283 to the defendant's case, rejecting a categorical approach in favor of a case-specific approach, and determines that Counts Three and Four qualify as offenses involving the sexual abuse of a minor. The court also addresses Maxwell's argument that the statute of limitations bars certain counts, citing Landgraf v. USI Film Products.
Court Filing: 107
The defense team for Ghislaine Maxwell requests a two-week extension to file pretrial motions and modify the briefing schedule due to COVID-19 restrictions and the large volume of discovery. The government consents to the requested extension. The proposed new deadlines are January 25, 2021, for the defendant's motions, February 26, 2021, for the government's response, and March 5, 2021, for the defendant's reply.
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