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

to a finding that a defendant's constitutional right to a fair and impartial jury have been violated. McDonough, 464 U.S. at 553-56; id. at 556-57 (Blackmun, J., concurring); id. at 557-59 (Brennan, J., concurring in judgment). So long as a truthful answer would have subjected the juror to a challenge f

th 12 whoever was his entourage at any given point in 13 time. 14 BY MR. SCAROLA: 12:47:41 15 Q. And that usually was? 12:47:42 16 A. , Maxwell and sometimes 12:47:43 17 another one or two people. 18 Q. How old was when she was part 12:47:49 19 of Jeffrey Epstein's entourage? 20 A

e asked to critique and she 24 would take notes and arrange transportation and do 25 things of that kind. EFTA00601290 138 1 Q. How old was Ghislaine Maxwell? 12:49:40 2 A. Ghislaine, Ghislaine Maxwell. I would 12:49:45 3 estimate -- 4 MR. SCOTT: Your French isn't real high. 12:49:48 5 A. I wou

nd say, Jeffrey 14 would like to meet with you at 4:10, and then she 15 would call back and say, could you make it at 4:30? 16 I would say that Ghislaine was the senior 12:50:19 17 person organizing his kind of academic contacts and 18 was the junior person. They worked in 19 overlapping roles.

ading hoping to get judicial immunity, yes, at 4 that point the appropriate response is in the court 5 of public opinion. 6 That's what Justice Blackmun said in a 15:46:00 7 concurring opinion in the Supreme Court, that the 8 duty of a lawyer does not stop at the courtroom door 9 but it continu

:10,13 506:6 Hawking (1) 579:19 588:7 602:17 615:16 546:3,6 547:2 guard (1) 574:1 594:12 630:10 616:15 637:1 556:3 559:25 607:8 head (2) Ghislaine (35) 640:2,17 641:7 560:1,17 561:3 guess (4) 489:8 597:25 508:22 509:4 given (7) 562:7 563:7 467:15 499:1 headed (1) 510:11 519:21 537:10 5

, who is a young 4 woman. I saw Giselle [sic] Maxwell, who is a young 5 woman. I saw women in their l

talk about my client being presumed 14 innocent, my client being innocent. That's part of 15 the role of a criminal defense lawyer. Justice 16 Blackmun has said that the criminal defense lawyer's 17 role does not end in a courtroom, it continues to 18 the courthouse steps. 19 And so when my cli