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Absent protection from the Court, her testimony will entail a further loss of privacy and dignity.
See 18 U.S.C. § 3771(a)(8).’ Accordingly, the Government requests relief narrowly tailored to the
par
> Indeed, in entering the Government’s requested protective order in this case, the Court noted that
“Tals a general matter, it is undisputed that there is a strong and specific interest in protecting
Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page /7 of 40
(E.D.N.Y. Apr. 26, 2011), Dkt. No. 231; United States v. Paris, No. 06 Cr. 64 (CFD), 2007 WL
1484974, at *2 (D. Conn. May 18, 2007).
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DOJ-OGR-00006525
B. The Minor Victims Retain Significant Privacy Interests
The bulk of the defense’s brief focuses on publicity surrounding this case
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in greater detail below, that
Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page5of40
ee. That misses the point entirely. The Court must decide whether to protect the
privacy of four victims who will testify in a criminal tr
Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page 3 of 40
G. Evidence or Argument About the Minor Victims’ Consent is Categorically
Telit S81 secs carasws cecsrennastosens csrinanas cont da ARt
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page 6of7
e AK did not express any concerns about anything to the attorneys. AK may have asked
something like whether the attorneys are asking SDN
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page 7 of 7
When the Topic of Epstein Came Back up with the Miami Herald Article
e Arose when AK was in Securities. AK was no longer the Human Tr
E Document 439-9 Filed 11/12/21 Pagelof1
EXHIBIT I
FILED UNDER SEAL
E Document 439-8 Filed 11/12/21 Pagelof1
EXHIBIT H
FILED UNDER SEAL
DOJ-OGR-00006515
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page5of7
Sean to call AK back and let her know if the Florida agents had concerns. Sean never
called AK back. AK doesn’t recall ever affirmatively
Events
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page4of7
AK’s recollection is that the attorneys did not make any suggestions regarding what
investigative steps SDNY should take. The att
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page3of7
e LP directed AK to “they will send me affidavits and depositions” on page 8 of AK’s
notes and asked if AK recalls what that line refers
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page1of7
February 11, 2021 Call with Amanda Kramer
Present on Conference Call:
AUSAs Lara Pomerantz & Maurene Comey
FBI Special Agent Amanda Yo
Case 1:20-cr-00330-PAE Document 439-7 Filed 11/12/21 Page 2of7
EXHIBIT G
DOJ-OGR-00006509
Case 1: 1OASP EBEABE SOA mer awmenicted én FESR BébkePd5/1 aged > Padé 14 of 15
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and ag
Case 1:1GASP A126 GAGS SHBARerPacemenictee-6n FEBS BaGe2d5/1 7aee 6-6 PAGS 15 of 15
ann
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DeceO7=07 9 Da BE pe From-Fowler-White Burnatt SHSTRQUZEf Tones oP.ooa/and =F
Affirmation
I, Jefize
E Document 439-6 Filed 11/12/21 Pagelof1
EXHIBIT F
FILED UNDER SEAL
DOJ-OGR-00006507
Case 1:1GaSP A126 GAGS SHBARerPacemenictee-6n FEBS BGeed5/1 Naeed-3 PAGS 12 of 15
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to Him. Epstein he
Case 1:1GA8P A126 GAGS SHBARerPacemenictee-6n FERS BaGeed5/1 Naee 6-4 PAGS 13 of 15
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein
Case 1:168SP- A128 CASS 3HBARnerPacementeteea-6n FEBS béGe2d5/1 aged 1 PAgé 10 of 15
By signing this agreement, Epstein asserts and certifies that the above has been read
and explamed to him. Epstein
Case 1:£889-b PORE ASEZOERAEmeROLUINENtGRN Dn FIGS DYER 5/17 AELOO PlaY~ 9 of 15
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein he
Case 1:1Ga8P A126 GAGS SHBARerPacemenictee-6n FERS B6Ge/2d5/1a08P AbdGe 8 of 15
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him, Epstein her
Case 1:20-cr-00330-PAE Document 439-5 Filed 11/12/21 Page1of16
EXHIBIT E
DOJ-OGR-00006491
E Document 439-4 Filed 11/12/21 Page1lof1
EXHIBIT D
FILED UNDER SEAL
E Document 439-3 Filed 11/12/21 Pagelof1
EXHIBIT C
FILED UNDER SEAL
E Document 439-2 Filed 11/12/21 Pagelof1
EXHIBIT B
FILED UNDER SEAL
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 69 of 69
Certificate of Service
I hereby certify that on October 25, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Response
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 68 of 69
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10t
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 67 of 69
The same is true for
The bias and motive for these witnesses to testify against Ms. Maxwell at the criminal
trial must be explored
E Document 439-1 Filed 11/12/21 Pagelof1
EXHIBIT A
FILED UNDER SEAL
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 65 of 69
government should re-read the many thousands of pages of witness statements before asserting
that it would be “baseless” to claim th
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 64 of 69
examples were given, the Court finds that this is too vague a category to grant the relief
requested.").
The government has not exp
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 66 of 69
DOJ-OGR-00006483
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 63 of 69
The parties should follow the Rules. Ms. Maxwell intends to do so and will object to
evidence she believes is inadmissible at trial.
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 61 of 69
evidence during trial; none stands for the specific relief requested by the government: that
"before the Court permits the defense t
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 59 of 69
Because nothing requires Ms. Maxwell to advise the government in advance of the
evidence she intends to admit at trial or why that e
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 56 of 69
appropriate and viable defense. While the age of consent for Counts Five and Six is 18, at the
time of the alleged offense, individu
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 5/7 of 69
admissible to demonstrate the lack of any intent or knowledge on the part of Ms. Maxwell. As
with the other in /imine requests, thi
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 55 of 69
solely on the age of the participant, the generic federal definition of minor requires that the age
of the alleged victim be the the
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 54 of 69
VI. CERTAIN EVIDENCE OR ARGUMENT THAT MINOR VICTIMS
CONSENTED TO SEXUAL ABUSE MAY BE ADMISSIBLE.
The government seeks blanket precl
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 52 of 69
1. Ee (Accuser 4) will testify that ag (Accuser 5)
"recruited" her. Mot. at 38. How? What will TE: that TE ai to her?
Is it, "I am
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 51 of 69
612-13; Lindsey, 769 F.2d at 1042. Accordingly, this evidence does not impermissibly question
the government’s motives and should no
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 49 of 69
particular “investigative technique” to prepare its case. See United States v. Saldarriaga, 204
F.3d 50, 52-53 (2d Cir. 2000); Unite
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 43 of 69
inconsistencies,” revealed a “remarkably uncritical attitude” on the part of the police which
“undermined the ... integrity of the i
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 44 of 69
C. Evidence and Argument About the Fact that Ms. Maxwell Was Not Charged by
the USAO-SDFL Is Relevant to gg Credibility
1. Applicab
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 41 of 69
and "good faith” of the New York investigation leading to the charges against her. Kyles, 514
USS. at 445.
It is clear from the doc
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 40 of 69
B. Evidence and Argument About the NPA, Prior Charging Decisions, and the
Death of Jeffrey Epstein Is Admissible to Challenge the Th
Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 35 of 69
Finally, admissibility of the number and type of prior consistent statements still is guided
by Rules 401 and 403, including whether