From: "Palin, Megan" C
Summary
From: "Palin, Megan" C To: Cc: Subject: Ghislaine Maxwell Date: Mon, 13 Jul 2020 16:00:54 +0000 Hi there, I'm a senior journalist for News Corporation (The Sun, NY Post, Wall St Journal) covering the USA V Ghislaine Maxwell case. I'll be in court for the bail hearing tomorrow but wanted to put a few questions to your team in advance as I know Tuesday will be extremely busy for everyone involved. - What will the prosecution be arguing in court tomorrow? - Will any alleged victims or witnesses be taking the stand on Tuesday? If so, how many (and who are they)? What can the court expect to hear from them? - Will any prosecutors, victims or witnesses be making a statement to the media outside the court before or after the hearing? If so, could you please let me know a time and place if one is scheduled along with any other relevant details? - Anything to add? Would you please also include me in any future emails/alerts etc to the media regarding this case? Thank you. Kind
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STATEMENT OF
STATEMENT OF IN RESPONSE TO APRIL 2, 2019 LETTER FROM JEFFREY R. RAGSDALE To the extent possible, I have provided all information relevant to your inquiry, including applicable documents. Due to the passage of time, updates to various software and hardware, and the crash of my work laptop several years ago, I no longer have every piece of relevant material and my memory may be imperfect.' I have organized the response to conform with the April 2, 2019 letter from Jeffrey R. Ragsdale to Jonathan Biran. Please note that there were numerous oral and written communications between others at the U.S. Attorney's Office and the Justice Department with counsel for Mr. Epstein. While in some cases I was told of the communications or cc'ed on emails or letters summarizing the communications, for many conversations, meetings, and emails, I do not have knowledge of what occurred. Introduction The investigation of Jeffrey Epstein and I series of co-conspirators, named "Operation Leap
Ilafana, Ann Marie C. (USAFLS)
Ilafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, February 14, 20081:35 PM To: Richards, Jason R.; Kuyrkendall, E N. Subject: RE: DOBs Hi guys - sorry to bother you. On some of the new girls I don't have dobs. (the 302 says her dob is (and do we have a phone number?) Have you guys ever talked to or F Should I include them? A. Marie Villafaiia Assistant U.S. Attorney 561 209-1047 1679 08-80736-CV-MARRA P-014607 EFTA00225102 Villafana, Ann Marie C. (USAFLS) From: Villatrine, Ann Marie C. (USAFLS) Sent: Thursday, February 14, 2008 1:21 PM To: Richards, Jason R. Subject: RE: Epstein Indictment Ili Jason — I didn't send the indictment yet. I was just asking for input on who to include and who to exclude. How old was when she went with 4. Mark Vilkflitaa Assistant U.S. Attorney 561 209- I 047 From: Richards, Jason R. Sent: Thursday, February 14, 2008 1:00 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Epstein I
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
MARKUS / MOSS
MARKUS / MOSS July 9, 2021 VIA EMAIL TO CHAMBERS The Honorable Alison J. Nathan United States District Court Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Even though I do not currently represent Ms. Maxwell in any proceedings and have never entered an appearance in connection with her trial before Your Honor, the Government submitted a letter "to bring to the Court's attention" an article that I wrote on June 30, 2021, and asked that the Court "issue an order pursuant to Local Rule 23.1(h)" directed at me. (Dkt. No. 309). This Court ordered that I respond (Dkt. No. 312), and I do so here. I respectfully request that the Court deny the Government's request for the following reasons: I. The local rules do not apply as I do not currently represent Ghislaine Maxwell in any proceeding and have not entered an appearance in this Court. Because undersigned counsel does not currently represent Ms. Maxwell in any co
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. PARK DIETZ AND DR. ELIZABETH LOFTUS DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00070837 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 I. THE COURT SHOULD PRECLUDE CERTAIN OPINIONS FROM DR. DIETZ 1 A. Background 1 B. Legal Standard 5 C. Discussion 8 I. Response to the Opinions of Dr. Rocchio 8 2. Opinions as to Hindsight Bias 11 3. Opinions as to the "Halo Effect" 14 4. Opinions as to "Pathways to False Allegations of Sexual Assault" 17 5. Opinions Regarding the Credibility of Witnesses 21 6. Opinions Regarding Post-Traumatic Stress Symptoms 22 II. CERTAIN ASPECTS OF THE PROPOSED EX
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 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00154512 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. 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 Would Never Destroy Her Family By Leaving the Country 11 2. A Number of Ms. Maxwell's Family and Friends, and the Security Company Prote
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