UNITED STATES DISTRICT COURT
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 10/31/21 20-CR-330 (AJN) ORDER ALISON J. NATHAN, District Judge: The Court is in receipt of the Defendant's motion under Federal Rule of Evidence 412, Dkt. No. 378, and the Defendant's motion in limine to exclude under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), Dkt. No. 386. The issues raised in the two motions overlap significantly. The Court is required under Federal Rule of Evidence 412 to conduct an in camera hearing. Fed. R. Evid. 412 ("Before admitting evidence under this rule, the court must conduct an in camera hearing and give the victim and parties a right to attend and be heard. Unless the court orders otherwise, the motion, related materials, and the record of the hearing must remain under seal.). In addition, the Court has
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th
Farmer, Jaffe, Weissing,
Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22
Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Introduction This Court asked the parties to brief three issues: "(a) the weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any co
FRENCH REPUBLIC
FRENCH REPUBLIC MINISTRY OF JUSTICE APPEAL COURT OF PARIS PUBLIC PROSECUTOR'S OFFICE OF PARIS COURT OF JUSTICE Paris, July 8, 2020 DIVISION Section P4 - Public Prosecution Service for Minors. The Public Prosecutor To Prosecutor-General at the Appeal Court of Paris. SUBJECT: Request for international legal assistance in criminal matter addressed to the United States authorities concerning the investigation related to Jean-Luc BRUNEI., and others, in connection with the "EPSTEIN case". N/REF : prosecution number : 19 235 449 V/REF : APPLICANT AUTHORITY The Public Prosecutor at the Paris Court of Justice. AUTHORITY ADDRESSED TO The competent authorities of the United States of America. Having regard to the accord between the European Union and the United States of America dated June 25, 2003 which entered into force on February 1, 2010 ; Having regard to the Article 14 of the Treaty on Mutual Legal Assistance between France and the United States dated December 10,
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18
Case 1:20-cr-00330-AJN Document 17 Filed 07/08/20 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT S1 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victim
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