Epstein Secrets

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS ME

exual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth GM 7 The defendant also argues that Dr. is not an expert in "the human brain or memory generally." (Def. Mot. 3 at 17). The overnment agrees. But Dr.

m-3's allegations "may reflect conduct 43 EFTA00088845 undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (id. at 26-27). B. Applicable Law It is axiomatic that the Government may offer proof of acts included within the indictment. Th

onspiracy is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." (alterations and citation omitted)); Quinones, 511 F.3d at 308 ("While Rule 404(b) identifies various rationales ... for which evidence of bad acts other than those charged in the indictment ma

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

granting the trial judge discretion to excuse the juror for cause, 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 (2

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

granting the trial judge discretion to excuse the juror for cause, 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 (2