Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) GIIISLAINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN & FOR

eys for Ghislain Maxwell 58 EFTA00155965 Certificate of Service I hereby certify that on January 19, 2022, I electronically filed the foregoing Ohislaine Maxwell's Motion for a New Trial, with the Court and counsel for the government: U.S. Attorney's Office SDNY One Saint Andrew's Plaza New York. NY 10007 s

w.dailymail.co.uk/news/article-10379445/Ghislaine-Maxwells- lawyers-fought-ask-jurors-detailed-questions-sex

e Law 21 I. Juror No. 50's misconduct deprived Ms. Maxwell of her constitutional right to a fair trial by a

es Cases Adams v. Texas, 448 U.S. 38 (1980) 28 Arizona v. Fultninante, 499 U.S. 279 (1991) 22 Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019) 54 Burton v. Johnson, 948 F.2d 1150 (10th Cir. 1991) 29, 30 Clark v. United States, 289 U.S. 1 (1933) 27 Cunningham v. Shoop, F.4th 2022 WL 92594 (6th Ci

d Of Child Sexual Assault. • Wisconsin Police Arrest Suspect For Shooting At Kenosha Bar • Florida Nurse Charged For Threatening To Kill Harris. • Maxwell Has To Stand Trial After Judge Turns Down Dismissal Request. • Family Of Tamir Rice Asks Garland To Reopen Probe Into Rice's Killing. • Medical Exp

elt horrible' after learning of Epstein's abuse of the criminal justice system in Florida. The disclosure...came in a 212-page filing responding to Ghislaine Maxwell's legal challenges to an indictment charging her with grooming underage Epstein victims in the mid-1990s and lying under oath." The Daily News "exclus

equest. flImmherg (4/16, Hurtado, 3.57M) reports Ghislaine Maxwell "must stand trial on sex-trafficking cha

at the FDA could decide to limit the vaccine to older Americans, who are less likely to suffer from the side effect. The Wall Street Journal (4/18, Burton, McKay, Subscription Publication, 8.41M) and The Hilt (4/18, Choi, 5.69M) provide additional coverage of the Johnson & Johnson vaccine delay. Fauci

d Of Child Sexual Assault. • Wisconsin Police Arrest Suspect For Shooting At Kenosha Bar • Florida Nurse Charged For Threatening To Kill Harris. • Maxwell Has To Stand Trial After Judge Turns Down Dismissal Request. • Family Of Tamir Rice Asks Garland To Reopen Probe Into Rice's Killing. • Medical Exp

elt horrible' after learning of Epstein's abuse of the criminal justice system in Florida. The disclosure...came in a 212-page filing responding to Ghislaine Maxwell's legal challenges to an indictment charging her with grooming underage Epstein victims in the mid-1990s and lying under oath." The Daily News "exclu

equest. Bloomberg (4/16, Hurtado, 3.57M) reports Ghislaine Maxwell "must stand trial on sex- trafficking cha

at the FDA could decide to limit the vaccine to older Americans, who are less likely to suffer from the side effect. The Wall Street Journal (4/18, Burton, McKay, Subscription Publication, 8.41M) and The Hill (4/18, Choi, 5.69M) provide additional coverage of the Johnson & Johnson vaccine delay. Fauci

43R-ficsarnecobalrgefiFiW044136§fgheatmbefilth 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS INTERVENORS' JULIE BROWN AND MIAMI HERALD MEDIA CO.'S RESPONSE TO MAXWELL'S OBJECTIONS TO UNSEALING Sanfor

F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS

rotocol for Unsealing Decided Motions, Intervenors Julie Brown and Miami Herald Media Co. ("Miami Herald") respectfully submit this response to Ms. Maxwell's Memorandum Brief in Support of Her Objections to Unsealing Sealed Materials (Dkt. 1057) ("the Objections")} ARGUMENT Ms. Maxwell's objections to

mi Herald") respectfully submit this response to Ms. Maxwell's Memorandum Brief in Support of Her Objections t

n hearsay requirements found in the Federal Rules of Evidence.4 This argument conflates the admissibility requirements and sealing requirements. See Burton v. Zwicker & Assocs., No. CV 10-227-WOB-JGW, 2012 WL 12925759, at *1 (E.D. Ky. Sept. 24, 2012) ("[D]efendant cites no authority—nor has the Court i

erg’s former investors rekindled the lawsuit against Epstein, but the case was dropped in October. Epstein and his associate, British-born socialite Ghislaine Maxwell, were also accused in a 2015 federal civil suit of organizing underage sex parties on his private plane, nicknamed “The Lolita Express,” and at Epste

in a 2015 federal civil suit of organizing underage sex parties on his private plane, nicknamed “The Lolita Express,” and at Epstein’s various homes. Maxwell, who has never been charged with wrongdoing, has denied allegations made in the lawsuit that she was Epstein’s “madam.” The suit, filed by victim Vir

Epstein and his associate, British-born socialite Ghislaine Maxwell, were also accused in a 2015 federal civi

e ieee eee rere oe wel rare otanelv ene Ccenias ees 13 Nixon v. Warner Commc’ns, Inc., OS CUBR tay OLY.) En a a ee en eee ee ene ae eee 13 People v. Burton, 189 A.Dd 532, 397 N.Y S 2d 48 (id Dept 1993) crsncncasuceeuuessummeansceeracerveumuameneess 13, 16 People v. Epstein, 89 A.D.3d 570, 933 N.Y.S.2d