Epstein Secrets

-cr-00330-AJN Document 342 Filed 10/13/21 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. • • • • x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JURO

20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIR

trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t

Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of

but not so great as to make mandatory a presumption of bias." United States v. Quinones, 511 F.3d 289, 301 (2d Cir. 2007) (quoting United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) and United States v. Torres, 128 F.3d 38, 45 (2d Cir. 1997)). All types of bias can properly form the basis to ex

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

Cir. 1979) 30 United States v. French, 904 F.3d 111 (1st Cir. 2018) 47 United States v. Greer, 285 F.3d 158 (2d Cir. 2002) 36 United States v. Haynes, 398 F.2d 980 (2d Cir. 1968) 29, 38 United States v. Langford, 990 F.2d 65(2d Cir. 1993) 23, 26 United States v. Martinez-Salazar, 528 U.S. 304 (

re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest

criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. EFTA00040364 Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste

stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.

prosecute FCPA and types of conduct that are violative of the FCPA—and this does nothing to rein that in," said Emily Westridge Black, a partner at Haynes and Boone in Austin, Texas, and Dallas, who specializes in FCPA litigation. She added, "We can expect that this will not curb and will likely incre

re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest

e grip of the criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste

stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.

prosecute FCPA and types of conduct that are violative of the FCPA—and this does nothing to rein that in," said Emily Westridge Black, a partner at Haynes and Boone in Austin, Texas, and Dallas, who specializes in FCPA litigation. She added, "We can expect that this will not curb and will likely incre

stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.

re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest

e grip of the criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste

prosecute FCPA and types of conduct that are violative of the FCPA—and this does nothing to rein that in," said Emily Westridge Black, a partner at Haynes and Boone in Austin, Texas, and Dallas, who specializes in FCPA litigation. She added, "We can expect that this will not curb and will likely incre

Wyatt Maxwell earn thousands of dollars on OnlyFans before federal investigators discovered he had been exploiting a boy. According to the article, Maxwell, a cabaret singer, repeatedly filmed himself and a 16-year-old Kansas boy having sex at Maxwell's home and a local park in 2020 and 2021. He posted

throughout the city, police have installed drone detectors that can spot an unauthorized device and even take control over it. WCVB (ABC-5) (07/02, Haynes) also reported on the story. U.S. Military Heightens Security Alert Level at European Bases in Response to Threats CBS News (07/02, Staff Writer)

UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av

New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011096 --- PAGE BREAK --- INTRO

trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t

Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of

but not so great as to make mandatory a presumption of bias." United States v. Quinones, 511 F.3d 289, 301 (2d Cir. 2007) (quoting United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) and United States v. Torres, 128 F.3d 38, 45 (2d Cir. 1997)). All types of bias can properly form the basis to ex

New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011115 --- PAGE BREAK --- Case

UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av

Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of

trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t

but not so great as to make mandatory a presumption of bias." United States v. Quinones, 511 F.3d 289, 301 (2d Cir. 2007) (quoting United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) and United States v. Torres, 128 F.3d 38, 45 (2d Cir. 1997)). All types of bias can properly form the basis to ex