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Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page5of8
Page 5
amounts—which the defendant cites in her motion. (Def. Mot. at 5). Thus, if these records are
relevant at all, they are “otherwise
Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page3of8
Page 3
Victims];” (3) “[a]ny and all” material “submitted by each [Minor Victim]” to the EVCP; and (4)
“communications” between the EVCP a
Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page2of8
Page 2
The Nixon test is enforced strictly. As the Supreme Court has explained, “[i]t was not
intended by Rule 16 to give a limited right
Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page1of8
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New
__ Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 1of2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 4of16
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure 1
Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 2 of 16
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
South
Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page 3of16
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No. 20CR330 (AJN)
PROOF OF SERV
Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page9of9
Certificate of Service
I hereby certify that on November 14, 2021, I electronically filed the foregoing Ms.
Maxwell’s Motion for an Order
Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page6éof9
the government has provided statements form the Accusers indicating yy
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The Protocol for receiving compensation is at
Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page4of9
and obtain by any means" individuals who were under the age of 18, including Accuser-4, "who
were then caused to engage in at least one com
Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page2of9
Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her
counsel to issue a subpoena under Federal Rule of Crimin
Case 1:20-cr-00330-PAE Document479 Filed 11/21/21 Pagelof1
Smith Villazor LLP
250 West 55th Street, 30th Floor
SMITH | VILLAZOR vewucsmithvllazorc
www.smithvillazor.com
PATRICK J. SMITH
T 212 582 4
Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page1of9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
S2 20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defendan
Case 1:20-cr-00330-PAE Document473 Filed 11/19/21 Pagelof1
UNITED STATES DISTRICT COURT | USDC SDNY
SOUTHERN DISTRICT OF NEW YORK DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/19/21
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Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 22 of 127 22
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substantially confuse and delay the trial. The evide
Case 1:20-cr-00330-PAE
Document 465
Filed 11/15/21
Page 20 of 127
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1 did not have an alibi and suggested that a photo lineup was
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Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 15of127 15
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to rehabil
Case 1:20-cr-00330-PAE Document 462 Filed 11/15/21 Page 13 of 32
Juror ID:
21. If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this
Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page8of10
Page 8
one coconspirator identifying another is in furtherance of conspiracy). Accordingly, this statement
is admissible as a co-conspira
Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page /7of10
Page 7
that is specifically charged in the indictment” or that is the subject of the relevant trial. Gigante,
166 F.3d at 82; see also
Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page6of10
Page 6
1. First Exemplar
The first exemplar to which the defense objects involved a statement Epstein made to
Employee-1 in order to pro
Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page4of10
Page 4
With respect to the first prong of this rule, “[t]he conspiracy between the declarant and the
defendant need not be identical to a
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travel from New Jersey to the Bronx, New York, where he held her
against her will inside his apartment.
(Title 18, United States
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
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CLAUDIUS ENGLISH,
a/k/a “Jay Barnes,“
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 44 of 52
United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292, at *1 (S.D.N.Y. Oct. 20,
2015) (same).
Finally, whatever minimal prob
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 43 of 52
(S.D.N.Y. May 1, 2007) (defendant’s prior narcotics and firearm transactions with the same
confidential informant not “inextricably in
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 42 of 52
As evidenced by their recently disclosed interviews, the government lawyers, despite its
protests about the defense's ability to call
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 34 of 52
U.S. where she claims to have engaged in sex acts with Epstein. See id. at 49-50. According to
the government, “all that is required”
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 32 of 52
The very case the government cites in support of their position, United States v. Curley,
639 F.3d 50 (2d Cir. 2011), affirmed the dis
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 31 of 52
404(b) (id. at 46-47), (3) her evidence is “intrinsic” proof of the charged conspiracies and
necessary to “complete the story” of the
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 21 of 52
C. Ms. Maxwell reiterates her request to defer briefing and ruling on the
admissibility 0f tt ES and exhibits for two
weeks.
For the
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 20 of 52
amendment to, and an impermissible variance of, the Indictment. As this Court previously has
ruled:
"To prevail on a constructive ame
Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page14 of 52
reference their status positions, and the government has no evidence that she was not already
well-established friends of many years wi
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 83 of 84
such evidence in its case-in-chief, unless the defendant opens the door to this evidence or otherwise
puts it at issue at trial. Furth
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 55 of 84
the elements of the crimes the Court provides them, so any assumptions the jury might make about
United Kingdom law are irrelevant.!4
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 52 of 84
and knew that Epstein used massage to initiate sexual contact with minor girls. Minor Victim-3’s
testimony shows the defendant’s inten
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 49 of 84
previous plans with Ferro to import narcotics ... was evidence of ‘other crimes’... . [I]t
corroborated the charge that Ferro and Rome
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 50 of 84
massages were sexualized, evidence that she did so in the case of Minor Victim-3—at roughly the
same time as Epstein was abusing Minor
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 47 of 84
corroborative of the accounts of the other Minor Victims. It is also direct evidence of the operation
of the conspiracy that is probat
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 45 of 84
undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as
Maxwell’s state of mind.” (id. at 26-27).
B
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 46 of 84
No. S1 06 Cr. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v.
Concepcion, 983 F.2d 369, 392 (2d Cir.
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 42 of 84
in their ability to investigate or move in limine. The Government’s Rule 404(b) notice—and this
brief—have been provided far in advanc
Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 39 of 84
conduct between adults! only highlights that this evidence does “not involve conduct any more
sensational or disturbing than the crime