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Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 5 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 5
a provision stating that it did not prohibit defense counsel from publicly referenci
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 4 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 4
Moreover, the defendant is able, at any time, to apply to the Court for a modificati
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 2 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 2
The defendant’s demand that she and her counsel be permitted to name any individuals
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 3 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 3
speak—by name on the public record in this case, as one victim has already chosen to
Case 1:20-cr-00330-AJN Document 30 Filed 07/27/20 Page 2 of 2
those materials for any purpose other than preparing for trial in the criminal
case, and may not post those materials on the Internet.
b
Case 1:20-cr-00330-AJN
SO ORDERED:
July , 2020
AGREED AND CONSENTED TO:
Dated: July =, 2020
New York, New York
By:
Dated: July , 2020
New York, New York
By:
Document 29-1 Filed 07/27/20 Page 13
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 11 of 13
c) Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
d) Shall not be possessed outside the presenc
of
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 9 of 13
only to Designat
g) May
videoconference, or via
e) Shall be reviewed by the Defendant solely in
the presence of Defense Counsel or
materials containing Highly Cont
“highly cont
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 10 of 13
themselves.
partially-nude,
13. Highly Confidential
Fidential” stamps on the docum
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 12 of 13
including but not
days of
verdict
captioned case;
pursuant to 28 U.S.C. § 2255;
record in
behalf of
captioned case,
19.
unle
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 6 of 13
including any social media website or other publicly available
medium.
6. The Governmen
their professional obligatio
t (other than
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 5 of 13
not obtain signa
attorneys, exper
support personnel
representation of
tures from any member of the defense team (i.e.,
ts, consult
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 7 of 13
Court.
authorized by the Government in writing or by Order of
Court.
by the Government in
or designated a
electronic
the Governm
In
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 8 of 13
formation.
such documents or materials,
the Court
ma
ma
contrary order of
de
of
De
criminal
terial
S.
fendant,
11.
o
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 4 of 13
advisor,
employed by the
assisting in the defense of
authorized by Order of
their counsel
consultant,
ii.
Defendant and
Expert
Case 1:
20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 3 of 13
WHEREAS the defendant, through her counsel, consents
to the entry of this Order;
T HEREBY IS ORDERED:
The Discovery disclosed to
Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 2 of 4
The Honorable Alison J. Nathan
July 27, 2020
Page 2
referenced in the discovery and guard against prejudicial pretrial publicity, while
Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 3 of 4
The Honorable Alison J. Nathan
July 27, 2020
Page 3
Maxwell with respect to using the criminal discovery material solely for the purpose
Case 1:20-cr-00330-AJN Document 29-1 Filed 07/27/20 Page 1 of 13
Exhibit A
DOJ-OGR-00001647
Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 4 of 4
The Honorable Alison J. Nathan
July 27, 2020
Page 4
For the reasons set forth above, we respectfully submit that the Court should enter
Case 1:20-cr-00330-AJN Document 27 Filed 07/21/20 Page 5 of 7
The Honorable Alison J. Nathan
July 21, 2020
Page 5
So to cooperate in the way that that kind of rumors out there would mean that
she’s
Case 1:20-cr-00330-AJN Document 27 Filed 07/21/20 Page 4 of 7
The Honorable Alison J. Nathan
July 21, 2020
Page 4
Although Ms. Strauss sprinkled her comments with the phrase “as alleged,” she presen
Case 1:20-cr-00330-AJN Document 27 Filed 07/21/20 Page 3 of 7
The Honorable Alison J. Nathan
July 21, 2020
Page 3
Recent Prejudicial Public Statements by the Government, its Agents and Counsel to
Pr
Case 1:20-cr-00330-AJN Document 27 Filed 07/21/20 Page 2 of 7
The Honorable Alison J. Nathan
July 21, 2020
Page 2
In an effort to protect the trial process from “prejudicial outside interferences,”
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 19 of 19
CONCLUSION
As set forth above, the defendant is an extreme risk of flight. The Government respectfully
submits that the defendant cann
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 17 of 19
applications in view of the applicable factors under the Bail Reform Act. This Court should reach
the same conclusion based on the extr
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 18 of 19
at *1 (S.D.N.Y. Apr. 20, 2020) (“Gonzalez fails to demonstrate that temporary release is
‘necessary’ for the preparation of his defense
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 16 of 19
defendant with asthma); United States v. Medina, 19 Cr. 351, ECF No. 68 (S.D.N.Y. Apr. 14,
2020) (Marrero, J.) (denying pre-trial bail
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 15 of 19
than any other inmate at the MDC, and thus she cannot claim any greater need for bail than the
many inmates awaiting trial there.’
The
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 14 of 19
a country that does not extradite its citizens, has access to untold financial resources, and has every
motivation to escape accountabi
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 13 of 19
should raise concerns about the defendant’s access to financial resources that would enable her to
flee.
Moreover, and as set forth in
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 12 of 19
of those individuals, including where they are based or whether the Government would be able to
collect from them. Nor does she provide
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 11 of 19
property, and the multi-million dollar property in the United Kingdom being offered as collateral.
Indeed, it is revealing that the def
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 8 of 19
appear to depend on any job — or to have depended on any employment in the past 30 years — for
the privileged lifestyle she has maintain
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 5 of 19
their client opposes bail for the defendant, and has asked the Government to convey that view to
the Court. The Government also expects
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 4 of 19
Finally, the Government recognizes that the COVID-19 pandemic is — and should be — a
relevant factor for the Court and the parties in th
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 25 of 26
Ms. Maxwell has a number of other family members and friends who, under normal
circumstances, would also co-sign and secure her bond. Sh
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 26 of 26
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her
release on bail pursuant to the condit
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 24 of 26
3. The Proposed Bail Package Is More Than
Adequate to Secure Ms. Maxwell’s Presence
For the reasons stated above, the Court should rele
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 20 of 26
suffered severe professional and reputational damage simply by being associated with her. Ms.
Maxwell therefore did what any responsible
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 19 of 26
take to protect herself, her family members, her friends and colleagues, and their children,
from unrelenting and intrusive media covera
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 15 of 26
2020 WL 3536277, at *4—5 (2d Cir. June 30, 2020). Although the presumption “remains a factor
to be considered” even after the defendant
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 14 of 26
The government bears a dual burden in seeking pre-trial detention. First, the government
must show “by a preponderance of the evidence t
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 12 of 26
Stephens, Ms. Maxwell’s inability to meet with her attorneys while this policy is in effect
constitutes a “compelling reason” requiring
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 13 of 26
documents and other evidence from approximately twenty-five years ago and meaningfully assist
in the preparation of her defense. These r
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 11 of 26
five staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41,
respectively.* The increased spread among prison
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 10 of 26
prior detention order based in part on the risks brought on by COVID-19. At the time, COVID-
19 had only begun to take its devastating t
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 7 of 26
detention. Importantly, in contrast with the bail position it took with Epstein, the government
does not and cannot assert that Ms. Maxwe
Case 1:20-cr-00330-AJN Document18_ Filed 07/10/20 Page 4 of 26
United States v. Epstein,
425 F. Supp. 3d 306 (S.D.N.Y. 2019) o.oo. cccccccenseceeeceseeecseeeseceseeesseessaeensesnseeenseeesseenseen
Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 3 of 26
TABLE OF AUTHORITIES
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Cases
Hung v. United States,
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