Browse by Document Type
Court Filings (12,056 documents)
Case 1:20-cr-00330-PAE Document 462 Filed 11/15/21 Page 2 of 32
FINAL Juror ID:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ween eee eee xX
UNITED STATES OF AMERICA
-V- : 20 Cr. 330
Case 1:20-cr-00330-PAE Document 462
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America,
—V—
Ghislaine Maxwell,
Defendant.
ALISON J. NATHAN, District Judge:
Filed
Case 1:20-cr-00330-PAE Document 460 Filed 11/15/21 Pagelof1
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AM
USA / Plaintiff(s)
20 Cr. 330
Case No.:
be
NO
Ww
ws
Oo
OY
~]
oO
Ke)
a
oO
he
be
No
(ee)
=
Hs
Oo
_
OY
a
~]
a
oO
a
Ke}
20
21
22
23
24
25
Case 1:20-cr-00330-PAE Document 459 _ Filed 11/15/21 Page 31 of 43 31
LalWmaxC
M
Case 1:20-cr-00330-PAE Document 459 _ Filed 11/15/21 Page 29 of 43 29
LalWmaxC
1 THE COURT: OK. That is a follow-up in the voir dire,
2 believ Let me double-check.
3 MS. STERNHEIM: It is, Judge, but w
be
NO
Ww
ws
Oo
OY
~]
oO
Ke)
a
oO
he
be
No
(ee)
=
Hs
Oo
_
OY
a
~]
a
oO
a
Ke}
20
21
22
23
24
25
Case 1:20-cr-00330-PAE
Document 459
Filed 11/15/21 Page 1 of 43 1
LalWmaxC
UNI
Case 1:20-cr-00330-PAE Document 458 Filed 11/12/21 Pagelof2
UNITED STATES DISTRICT COURT USDC SDNY
SOUTHERN DISTRICT OF NEW YORK DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/12/21
United St
Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page7of8
Page 7
conspiracy. By its very nature, a contact book that collects phone numbers for many people is not
the sort of thing that is generat
Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page6of8
Page 6
B. Relevance
Federal Rule of Evidence 401 defines “relevant evidence” as evidence that “has any
tendency to make a fact more or le
Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page8sof8
Page 8
relevant, evidence need not be sufficient by itself to prove a fact in issue, much less prove it beyond
a reasonable doubt.”).
IH.
Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page4of8
Page 4
(2d Cir. 2007)). To meet this burden, the Government need only introduce “sufficient proof. . .
so that a reasonable juror could fi
Case 1:20-cr-00330-PAE Document 457 _ Filed 11/13/21 Page3of8
Page 3
Guestrooms).” See Government Exhibit 606 at 7; see also id. at 10 (“JE and GM telephone
directories [are] placed to the right of
Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page2of8
Page 2
Government anticipates offering only specific excerpts from the book that relate to the conduct
charged in the Superseding Indictme
_ Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page1of8
pace U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Pla
Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page10of10
Page 10
D. Conclusion
For the forgoing reasons, the Government respectfully submits that the proffered
statements should be admitted a
Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page1of10
: U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
N
Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Page3of3
Page 3
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: ___s/
Maurene Comey
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Page1of3
: U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
Ne
Case 1:20-cr-00330-PAE Document 454 Filed 11/12/21 Pagelof2
USpc SDNY
DOCUMENT |
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
DOC #;
DATE FILED: 11/12/21 |]
Unit
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 49 of 52
knowledge. The government does not provide any clues about who may have touched the
evidence after it was seized in October 2005, ten
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 50 of 52
F. Government Exhibit 313
GX 313 was seized in 2019. It was not seized from Ms. Maxwell. No one will testify
about where it was taken
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 48 of 52
a pre-trial hearing at which the government must demonstrate that the proposed evidence is both
authentic, admissible, relevant and no
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 47 of 52
prejudice because the [witness's] choice of language implied that he and the prosecution believed
the complainant's testimony." Jd.
F
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 39 of 52
It was not until 2020, after making a multi-million dollar claim to the Epstein Victim
Compensation fund, that the SDNY interviewed J
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 38 of 52
activity for which the defendant could be charged with specific New Jersey, Pennsylvania, New
York, and Canadian criminal offenses” (e
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 28 of 52
The government denies Ms. Maxwell’s argument that “a lay jury will be unable to
apply Dr. Rocchio’s analyses to the facts of this case
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 26 of 52
situation here, in which the alleged “groomer” was not the person who perpetrated
the alleged abuse.
e Even where the “groomer” and “
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 27 of 52
as well as [her] experience conducting forensic psychological evaluations of
people who have experienced sexual abuse and trauma.” Mot
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 22 of 52
In any case, the newly discovered material doesn’t help the government’s cause. Exhibit
A (literally) to the government’s response is
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page19 of 52
2. The government has apparently abandoned efforts to introduce her
testimony as Rule 404(b) evidence.
In their response, the governme
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page17 of 52
drafted by Ms. Maxwell. Compare GX 417-B, 418-B, 420-B, 420-B (all purporting to represent
metadata of other emails with the author ide
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page9of52
In United States v. Velez, No. 3:10CR147 JBA, 2010 WL 4929266, at *7 (D. Conn. Nov.
30, 2010), the defendant moved for disclosure of any c
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page3of52
VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS.
MAXWELL’S ALLEGED FALSE STATEMENTS AND AGREES TO MS.
MAXWELL’S PROPOSED
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page1of52
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
S2 20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defend
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 84 of 84
enforcement officers identified by the defense as experts and will not elicit expert testimony from
them. Those witnesses are being ca
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 77 of 84
consistent with the rules in this exhibit.'? The relevance of the document is self-evident: among
other things, it directs employees t
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 76 of 84
Fourth, the defendant argues that Government Exhibit 294 is irrelevant. (Def. Mot. 13 at
2-3). Government Exhibit 294 displays a box c
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 74 of 84
First, the defendant moves to exclude Government Exhibit 52, which it says was obtained
by the Government “as part of discovery in Gui
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 75 of 84
maintained a contact book containing what purports to be this list of names and associated contact
information.
Second, the defendant
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 73 of 84
evidence regarding the circumstances surrounding the seizure of the USB drive, Federal Rule of
Evidence 901(b)(4) permits authenticati
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 70 of 84
there are several similar quality photos in the book. (See Ex. A, photos a). In any event,
these highly conclusory statements fall wel
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 71 of 84
prior to the incident,” or alternatively, if “if a witness gets a good look at the defendant during the
course of a crime”); United St
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 63 of 84
Even if the Government has misread the Court’s order, the defense’s claims of prejudice
are exaggerated. Although the defense complain
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 61 of 84
as the defense might like the Government to create such an index, that is simply not how the
litigation of co-conspirator statements i
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 59 of 84
On September 3, 2021, the Court ordered the Government to “disclose to the Defendant
the identities of all unnamed co-conspirators all
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 58 of 84
notice, co-conspirator statements, and Government witness list,” as well as the “Defendant’s
proposal” that the Government disclose it
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 5/7 of 84
Government planned to offer at trial as admissions of a defendant” under Fed. R. Evid. 801).
Accordingly, the Government argued that
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 53 of 84
because evidence was “pertinent to whether he used the internet in an attempt to engage in sexual
conduct with” putative victim).
The
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 48 of 84
Maxwell’s state of mind.” (Op. & Order at 26-27, Dkt. No. 207 (“Courts in this district generally
delay ruling on any motion to strike
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 41 of 84
Government’s notice is remediated by this brief. This is ample notice of the possible Rule 404(b)
evidence in this case. Indeed, the R