Epstein Secrets

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

10 (2d Cir. 2008) United States v. Farmer, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys 212 EFTA00103237

ndicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s Assistant United States Attorneys (212) 637-2225 212 EFTA00100179

ndicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

10 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00077844

ndicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(6)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

10 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00039659

ndicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(6)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

ited States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) 120, 121 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 6, 18, 22 United States v. Fennell, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 192, 194 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 167 United States v. Fiumano, No. 14 Cr.

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 211 EFTA00095303

ndicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends