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

system of justice is deprived of its fullest potential when the lawyer is denied the right to examine veniremen in an adversary setting. Honorable Donald P. Lay (8th Cir.) "In a Fair Adversary System, the Lawyer Should Conduct the Voir Dire of the Jury." 15 EFTA00065541 Case 1:20-cr-00330-AJN Document 34

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

system of justice is deprived of its fullest potential when the lawyer is denied the right to examine veniremen in an adversary setting. Honorable Donald P. Lay (8th Cir.) "In a Fair Adversary System, the Lawyer Should Conduct the Voir Dire of the Jury." 15 EFTA00011111 --- PAGE BREAK --- Considering th

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

system of justice is deprived of its fullest potential when the lawyer is denied the right to examine veniremen in an adversary setting. Honorable Donald P. Lay (8th Cir.) "In a Fair Adversary System, the Lawyer Should Conduct the Voir Dire of the Jury." 15 EFTA00011130 --- PAGE BREAK --- Case 1:20-cr-0