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Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 22 of 24
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that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
es
Epstein have sexual activiti
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 21 of 24
A, I’m not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United S
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 24 of 24
1 LS
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Vv.
GHIS
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 19 of 24
Florida. For example, on one occasion in or about October of
2002, Epstein caused a package to be sent by Federal Express
from an addre
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 20 of 24
individuals who were less than 18 years old, including but not
limited to Minor Victim-4, as described above, and who were then
caused
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page17 of 24
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multipl
Case 1:20-cr-00330-PAE Document187 _ Filed 03/29/21 Page 16 of 24
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
Che Between in or about 1994 and in or about
1995, whe
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page14 of 24
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 13 of 24
New York Residence, in violation of New York Penal Law, Section
130.55.
Gs In or about 1996, when Minor Victim-2 was
under the age of
Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page1of24
ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- eee eee ~----+-+--+-+ x
UNITED STATES OF AMERICA SUPERSEDING INDICT
CaGade20-rr-0028540APAC DOnouraigh2 Fikeda22e21 PaRagsé 18 20 20
from the counties that overlap both courthouses; and (4) the clerical error by which voters who
had registered with an alternate maili
CaGade20-rr-0088540APAC DOnourTaighd Fieedd22e21 PaBagS 5 20 20
the second element under Duren.® 439 U.S. at 364.
B. Systematic Exclusion
Apart from the second Duren element, Schulte’s fair cross-s
CaGasde20-rr-0028540APAC DOnourtaiaa Fikeda22e21 PaBags 68 20 20
the Government had engaged in “prosecutorial gamesmanship” and forum shopping by seeking
the Indictment from White Plains. Commonsense
CaGade20-rr-0088540APAC DOnouraiga Fieeda22e21 PaBadga bf 20 20
been any unlawful or unconstitutional treatment of minorities.” Jd. (emphasis added). And in
applying this principle, the Bahna court c
CaGasde20-rr-0028640APAC DOnourEissd Fieeoa2Z2eP?1 PaRageck8 26 20
trials were not spared. See id. On June 8, 2020, however, the Government sought and obtained a
third superseding Indictment from a g
CaGade20-rr-0038640APAC DOnourEitssd Fieeoa2Z2e?1 Pafagect 26 20
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
oe eran nen nen nenenenenceameneenenenennnenceenee 4
UNITED STATES OF AMER
Case 1:20-cr-00330-PAE Document185 Filed 03/26/21 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 Document185 _ Filed 03/26/21 Page 2of2
Page 2
In particular, in assessing the defendant’s Sixth Amendment claim, Judge Crotty found
that: (1) the relevant jury pool is the Whi
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page6éof7
The Honorable Alison J. Nathan
March 22, 2021
Page 6 of 7
they have not demonstrated the relevance of all of the evidence they seek.”). Th
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page /7of7
The Honorable Alison J. Nathan
March 22, 2021
Page 7 of 7
Material,” which is clearly sought for impeachment purposes, is not a proper su
Case 1:20-cr-00330-PAE Document184 Filed 03/26/21 Pagelof1
BOIES
SCHILLER
—_ LEXNER
Sigrid S. McCawley
Telephone: (954) 377-4223
Email: [email protected]
March 26, 2021
VIA ECF
The Honorable Al
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page5of7
The Honorable Alison J. Nathan
March 22, 2021
Page 5 of 7
than impeachment, many of them are procurable from the Government and are thus im
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page4of7
The Honorable Alison J. Nathan
March 22, 2021
Page 4 of 7
because “the subpoena was not crafted to call for admissible evidence. Rather, it
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page3of7
The Honorable Alison J. Nathan
March 22, 2021
Page 3 of 7
party cannot properly prepare for trial without such production and inspection in
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page2of7
The Honorable Alison J. Nathan
March 22, 2021
Page 2 of 7
Government prior to the arrest was somehow improper and that her accusers, severa
Case 1:20-cr-00330-PAE Document183 Filed 03/26/21 Page1of7
SCHILLER
—_ LEXNER
Sigrid S. McCawley
Telephone: (954) 377-4223
Email: [email protected]
March 22, 2021
VIA EMAIL (FILED UNDER SEAL
Th
Case 1:20-cr-00330-PAE Document172 Filed 03/24/21 Page2of3
by the proposed subpoena. The Court also gave the alleged victims an opportunity to object to or
request modifications of the subpoena as re
Case 1:20-cr-00330-PAE Document172 Filed 03/24/21 Page1of3
Uspc SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT OCs:
SOUTHERN DISTRICT OF NEW YORK DATE FILED: 3/2421 ||
United State
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page9of18
prosecution.
The ongoing review of discovery confirms the lack of evidence in support of the
stale allegations in the indictment. Further,
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page 8of18
Conceded Problems Undermine the Strength of the Government’s Case
As Ms. Maxwell’s period of detention passes the nine-month mark, the go
Case 1:20-cr-00330-PAE Document170 Filed 03/22/21 Page2of2
Page 2
that is contained in the publicly-filed Indictment in this case. In particular, the additional redactions
proposed by the defense to
Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 6 of 12
Court’s view has not changed. The Court again concludes that the Government has shown by a
preponderance of the evidence that the Defen
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 3of5
Defendant’s objections relate to her contention that some of the information contained in the
redactions has been made public by other mea
Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 2 of 2
The Honorable Alison J. Nathan
March 15, 2021
Page 2
11. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell,
Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 1 of 2
800 Third Avenue
New York, NY 10022
COHEN & GRESSER LLP +1 212.957 7600 phone
www.cohengresser.com
Mark S. Cohen
Christian R. Everdel
Case 1:20-cr-00330-AJN Document 160 Filed 02/23/21 Page 7 of 9
accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her
spouse, as described above.
Restraining
Case 1:20-cr-00330-AJN Document 160 Filed 02/23/21 Page 2 of 9
INTRODUCTION
Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third
Motion for Release on Bail.
As Ms. Maxwell
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 20 of 23
Court may order the disclosure when a balancing of the defendant’s need for disclosure and the
government's need for concealment indic
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 18 of 23
statements they already heard. Rather than risk a mistrial, the Court should require a proffer
from the government or conduct a pretri
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 15 of 23
C. Documents Related to Ms. Maxwell’s Motions
Along with this motion, Ms. Maxwell has filed a motion to dismiss the indictment for
br
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 14 of 23
(Dkt. 68) (emphasis added). Accordingly, the Court should order the government to produce
unredacted copies of these reports.
B. The
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 8 of 23
the district court. /d. “In deciding whether a bill of particulars is needed, the court must
determine whether the information sought h
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 9 of 23
government, but have not been able to agree on a disclosure schedule and therefore renew this
request as part of this motion for a bill
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 11 of 23
government should be required, at a minimum, to remove this shroud of mystery and file a bill of
particulars to permit Ms. Maxwell to
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 7 of 23
the defense can adequately prepare for trial”)). For the very same reasons, the Jencks Act and
404(b) evidence should be produced to th
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 5 of 23
PRELIMINARY STATEMENT
This Memorandum of Law is submitted in support of Ghislaine Maxwell’s Motion for a
Bill of Particulars and Pretr
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 13 of 16
or Accuser-2, or that there is any causal relationship between the alleged incidents involving
Accuser-3 in England and those involvin
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 12 of 16
(quoting Grunewald v. United States, 353 U.S. 391, 397 (1957)). Thus, whether Ms. Maxwell’s
alleged conduct with respect to Minor Vict
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 11 of 16
involving the sexual or physical abuse of a child under the age of 18 years” could be brought
until the victim reached age 25. 18 U.S.
Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 9 of 16
§ 2422(a) and § 2423(a) conspiracies to cause individuals to travel in interstate or foreign
commerce to engage in unlawful sexual acti