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Case 1:20-cr-00330-PAE Document 380-1 Filed 10/29/21 Page3of3
U.S. Department of Justice
August 30, 2021
Page 2
(AJN)). We request testimony from i and i concerning the
scope, timeline, and resoluti
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 45 of54
testimony by a case agent, is inadmissible hearsay. While the defendant has no burden to put on
a defense case, she can only introduc
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 44 of 54
defendant has emphasized these witness statements, and claimed that they are exculpatory. (See,
e.g., Mem. of Law, Dkt. 138 at 7-11;
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 41 of 54
Cir. 1986) (“[C]onsent is a defense to kidnapping but not to a Mann Act charge . . . .”); United
States v. Rivera, No. 13 Cr. 149 (K
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 40 of 54
the evidence in support of such a defense would be legally insufficient.” (citation and internal
quotation marks omitted)); United S
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 37 of54
reasons for the prosecution have no bearing whatsoever on the jury’s proper function. If the
facts gave rise to a viable claim of imp
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 36 of 54
v. Armstrong, 517 U.S. 456, 463 (1996) (“[S]o long as the prosecutor has probable cause to
believe that the accused committed an off
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 34 of 54
about numerous witness interviews they conducted, physical evidence they reviewed, documents
they obtained by subpoena,” and their a
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 28 of 54
Second, even if the decision of whether to charge the defendant in 2008 or 2019 had
some minimal relevance, it would be substantiall
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 26 of 54
after 2019, including testimony from two of the Minor Victims, any connection between the
evidentiary background of the USAO-SDFL’s
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 25 of 54
2. Discussion
The defense should be precluded from offering evidence or making arguments about (1)
the fact that the USAO-SDFL ente
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 23 of 54
A. The Court Should Not Permit the Defense to Elicit Evidence About Charging
Decisions or Possible Reasons for Them
1. Applicable L
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 22 of 54
investigation into Epstein and his co-conspirators, leading to a 2019 indictment against Epstein
and a 2020 indictment against the d
Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 21 of 54
recently fabricated their allegations about the defendant. See Tome, 513 U.S. at 159, 167
(holding that the Rule “permits the introd
Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21
32. For those of you who have described prior jury service, is there anything about your
prior experiences as a juror that would prevent you from
Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21
10. Based on the nature of the charges, might it be difficult for your to be a fair and
impartial juror in this case? [If Yes/Unsure question pri
Case 1:20-cr-00330-PAE Document 366 Filed 10/22/21 Page3of6
to have to come back at all for the in-person questioning in this case and exactly what date and
time you would be obliged to be here.
Onc
Case 1:20-cr-00330-PAE Document365_ Filed 10/22/21 Page 13 of 40
Juror ID:
20a-2| If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in
Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 Page1of2
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 358 _ Filed 10/18/21 Page1of4
My) Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
HADDON
MOOR CN 150 East 10th Avenue
FOREMAN Denver, Colorado 80203
PH 303.831.7364
Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page /7of17
" Ghislaine Maxwell: The Rise and Fall of Manhattan’s Most Famous Socialite
(Nigel Cawthorne)
e The Spider: Insider the Criminal Web of
Case 1:20-cr-00330-PAE Document 336-4 Filed 09/07/21 Page 7 of 22
3. Communications between You and J between 2015 and the date of this
subpoena about or referencing Ghislaine Maxwell, Jeffrey Epstei
Case 1:20-cr-00330-PAE Document 336-4 Filed 09/07/21 Page 5 of 22
ATTACHMENT A
DEFINITIONS
“You” or “Your” means J. Stanley Pottinger and any owner, shareholder, partner, employee
or independent con
10.
11.
Case 1:20-cr-00330-PAE Document 336-4 Filed 09/07/21 Page 6 of 22
. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and
Case 1:20-cr-00330-PAE Document 336-4 Filed 09/07/21 Page 4 of 22
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure
Case 1:20-cr-00330-PAE Document 336-4 Filed 09/07/21 Page 2 of 22
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southe
Case 1:20-cr-00330-PAE Document 336-4 Filed 09/07/21 Page 3 of 22
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No, 20CR330 (AJN)
PROOF OF SER
Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 7 of 22
3. Communications between You and J between 2015 and the date of this
subpoena about or referencing Ghislaine Maxwell, Jeffrey Epstei
10.
11.
Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 6 of 22
. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and
Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 5 of 22
ATTACHMENT A
DEFINITIONS
“You” or “Your” means Brad Edwards and any owner, shareholder, partner, employee or
independent contractor
Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 2 of 22
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southe
Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 4 of 22
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure
Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 3 of 22
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No, 20CR330 (AJN)
PROOF OF SER
Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page5of21
ATTACHMENT A
DEFINITIONS
“You” or “Your” means Maria Farmer.
“Envelopes” means the envelopes that You described in a podcast with Whit
Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page 4of 21
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure
Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page 2 of 21
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southe
Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page 3of 21
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No. 20CR330 (AJN)
PROOF OF SER
Case 1:20-cr-00330-PAE Document 336-1 Filed 09/07/21 Page 5 of 60
ATTACHMENT A
DEFINITIONS
“You” or “Your” means Annie Farmer.
“Journal” means the spiral notebook depicted in Exhibit A to this Attac
Case 1:20-cr-00330-PAE Document 336-1 Filed 09/07/21 Page 4 of 60
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure
Case 1:20-cr-00330-PAE Document 336-1 Filed 09/07/21 Page 2 of 60
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southe
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page9of10
that the items turn out to have been altered or do not exist the absence of this evidence is also
relevant and admissible at trial as excu
Case 1:20-cr-00330-PAE Document 336-1 Filed 09/07/21 Page 3 of 60
AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects ina Criminal Case (Page 2)
Case No, 20CR330 (AJN)
PROOF OF SERV
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page10 of 10
requirements of a Fed. R. Crim. P. 17 subpoena. United States v. Reyes, 162 F.R.D. 468, 470
(S.D.N.Y. 1995).
WHEREFORE, Ms. Maxwell re
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page /7 of 10
Re =3Now BE claims she was abused by Epstein and Maxwell,
1 es Sec Indictment { 7(0):
ee e—CSCSCSC‘B
ES. Ms. Maxwell seeks any
notes
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page5of10
Nixon Factors:
Each of the items specified in the Annie and Maria Farmer proposed subpoenas is
relevant, specific and admissible. These t
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page4of10
under Rule 404(b) or as res gestae evidence in conjunction with her sister’s allegations. See
First Motion at 11, 15-16. Maria Farmer is t
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page3of10
As previously detailed, Annie Farmer is believed to be the alleged victim referred to in
the superseding indictment as “Minor Victim 2.” S
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page 2of10
Defendant Ghislaine Maxwell makes this second ex parte and in camera motion for the
Court to enter an Order authorizing her counsel to is
Case 1:20-cr-00330-PAE Document 335 Filed 09/03/21 Page2of3
must balance the risk of surprise to the defendant, which is enhanced if ‘there are a large number
of co-conspirators and a long-running co
Case 1:20-cr-00330-PAE Document 335 Filed 09/03/21 Page3of3
Government from restricting its proof at trial.’ Dkt. No. 320 at 3. The Government provides no
explanation for this purported harm and none