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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 6of 93
comment, question, or instruction of mine. Nor should you infer that I have any views as to the
credibility of any witness, as to the
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 4of 93
Contact with Others/Social Media
During your deliberations, you must not communicate with or provide any information to
anyone by any
Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21
INTRODUCTORY INSTRUCTIONS
Role of the Court
You have now heard all of the evidence in the case, as well as the final arguments of the
lawyers for
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page6éof7
LAW OFFICES OF BOBBI C. STERNHEIA\
approximately 5:30 a.m. and was placed in a cold cellblock without the opportunity to retain and
revi
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page/7of7
LAW OFFICES OF BOBBI C. STERNHEIA\
It is incumbent on the Court to address these concerns and ensure that Ms. Maxwell’s
health and well-
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page4of7
LAW OFFICES OF BOBBI C. STERNHEIA\
the effects of sleep deprivation on cognitive functioning, “sleep deprivation result[s] in a loss of
c
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page3of7
LAW OFFICES OF BOBBI C. STERNHEIA\
Maxwell. At that time, Attorney General William Barr said he initially had his own suspicions
about Ep
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page2of7
LAW OFFICES OF BOBBI C. STERNHEIA\
openly hostile toward her and have mentioned having read the press and seen various television
shows w
Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Pagelof7
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fax
Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Page5of7
EXHIBIT A
DOJ-OGR-00006053
Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Pagelof7
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fax b
Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page2of6
Page 2
It is not clear whether the defendant intends to call one or both of these experts at the
Daubert hearing on Dr. Rocchio’s testimon
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Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page4of6
there is something that would be too difficult or embarrassing for you to say on the public record,
please let me know. A
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Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page5of6
of this case at all. If you see something in the paper or online, you're just going to have to turn
the page or close the
Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page6of6
I do want to thank all of you for the time you've invested already in this process. Our
system cannot function unless we have good people
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Case 1:20-cr-00330-PAE Document 404 _ Filed 11/02/21 Page3of6
impartial in one kind of case, but for various reasons, related to their own life experiences or views,
can't be fair in
Case 1:20-cr-00330-PAE Document 401 Filed 11/01/21 Page2of2
SO ORDERED.
Dated: November 1, 2021 MM \) iit
New York, New York
ALISON J. NATHAN
United States District Judge
DOJ-OGR-00006030
Case 1:20-cr-00330-PAE Document 400 Filed 10/31/21 Page2of2
heard at the Rule 412 Motion hearing. After doing so, the parties shall confer with each other as
to availability. On or before November 2,
Cas@€ds20icr0880422P GCG Bofiovemsaes Fileday MGA 2 Pageagefaof 11
the fact that Minor Victim-6 had not attained the age of 14 years,
and knowing that Minor Victim-6 would be caused to engage in
comm
Cas@ds@0Lcr0880492PG Bodoneisass Filéday MGAs2 Pagebayefa Of 11
York, where ENGLISH attempted to take photographs of her, harbor
her, and cause her to engage in sexual acts with at least one man
in e
Cas@€ds20kcr0680422P GCG Bofiovemsaes Filtday MGAd2 Pageagef 210f 11
interstate and foreign commerce, attempted to recruit, entice,
harbor, transport, provide, obtain, advertise, Maintain,
patronize,
Cas@€ds20kcr0680422P G Bo fionemsaes Fileday MGAd2 Pageagef@of 11
COUNT FIVE
(Attempted Sex Trafficking of Minor Victim-4)
The Grand Jury further charges:
Be At least in or about September 2013, in
Cas@€ds20icr0680422P GCG Bofionemsaes Fileday MGA 2 PagPayefiLof 11
COUNT FOUR
(Sex Trafficking of Minor Victim-3)
The Grand Jury further charges:
4, At least in or about November 2013, in the Sout
Cas@€ds20kcr0680422EPG Bo fiovemsaes Fileday MGAad2 Pageagef4of 11
COUNT THREE
(Sex Trafficking of Minor Victim-2)
The Grand Jury further charges:
3. Between at least in or about March 2013 and at
Cas@€ds20kcr0680422P GCG Bofiovemsaes Fileday MGA 2 Pageagefaof 11
COUNT TWO
(Sex Trafficking of Minor Victim-1)
The Grand Jury further charges:
2. Between at least in or about March 2013 and at le
Case 1:20-cr-00330-PAE Document 398-5 Filed 10/29/21 Page1of11
EXHIBIT E
DOJ-OGR-00006012
E Document 398-4 Filed 10/29/21 Pagelof1
EXHIBIT D
FILED UNDER SEAL
E Document 398-3 Filed 10/29/21 Pagelof1
EXHIBIT C
FILED UNDER SEAL
E Document 398-2 Filed 10/29/21 Pagelof1
EXHIBIT B
FILED UNDER SEAL
DOJ-OGR-00006009
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 52 of 52
Certificate of Service
I hereby certify that on October 27, 2021, I electronically filed the foregoing Ghislaine
Maxwell’s Reply In
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 51 of 52
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th
E Document 398-1 Filed 10/29/21 Pagelof1
EXHIBIT A
FILED UNDER SEAL
DOJ-OGR-00006008
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 46 of 52
speculating that the accusers have already been found credible by someone, or that their decision
is a foregone conclusion. On the ot
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 45 of 52
argument are flawed, and the Court should enter the order proposed by Ms. Maxwell that all
parties, witnesses, and the Court should
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 41 of 52
criminal, (4) the certainty with which the witness first identified the suspect, and (5) the time
lapse between the crime and the id
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 40 of 52
The facts about J interaction with Ms. Maxwell are hotly disputed. Ms.
Maxwell rejects the government’s unsupported conclusory state
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 37 of 52
jury.” Resp. at 53-54. Apparently, the government believes the jury would be “confused” if the
Court told the jurors what the law ac
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 36 of 52
alleged scheme to cause minors to travel to engage in illegal sex acts, or her knowledge of the
same. See Mot. at 11. Nor is the evid
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 35 of 52
victim’s age, you must find that the defendant knew that the victim was less than seventeen years
old.”) (emphasis added).
It is un
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 33 of 52
for the purpose of engaging in unlawful sexual activity (it was not). Moreover, allowing the
government to circumvent Rule 404(b) by
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 30 of 52
Thus currently it appears that grooming is not a construct that ought to be used in
forensic settings as it does not meet some of th
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 29 of 52
along these lines, that will open the door to other sexual behavior evidence. That
door can remain at least partially closed if Rocch
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 25 of 52
Recognizing that Rocchio’s opinions are thus unreliable, the government says: “Tf the
victim experienced attachment and grooming, it
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 24 of 52
But that’s not what the government does. Instead, right after claiming that “[c]linical
psychologists are not so credulous,” the gove
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page 23 of 52
B. Rocchio’s proposed testimony is inadmissible.
According to the government, Ms. Maxwell “does not contest that Dr. Rocchio is a
qu
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page 18 of 52
L,
a
SS A
Re Mot. at 7. Defense counsel had insufficient time to
review, investigate or rebut the admissibility of the materials as
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 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 i
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page16 of 52
SM .
Maxwell strongly disputes that suggestion. Notably, as the Court can tell, the government did
not offer any evidence (or any of
Case 1:20-cr-00330-PAE Document398 _ Filed 10/29/21 Page13 of 52
"In assessing whether a district court properly admitted other act evidence, we consider
whether (1) it was offered for a proper purpo
Case 1:20-cr-00330-PAE Document 398 _ Filed 10/29/21 Page14 of 52
The government contends that gg reveal "defendant's intent and motive," but
their argument is defies logic.
This is exactly the
ty