Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR

ted States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017), and the District of Massachusetts in Doe ex rel. Pike v. Pike, 405 F. Supp. 3d 243, 249 (D. Mass. 2019). Here, Dr. Rocchio has extensive experience treating minors who have been sexually abused, and those decades of relevant experience, combined

mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi

ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as

r-00330-AJN Document 18 Filed 07/10/20 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian

olorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00018515 --- PAGE BREAK --- Case

f 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. 9 A. Applicable Law 9 B. Ms. Maxwell Has Rebutted the Presumption T

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

11 United States v Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United S

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 17, 2020 (t

, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th

ective order so he could use certain discovery materials in a FOIA suit); United States v. DeNunzio, --- F. Supp. 3d ---, 2020 WL 1495880, at *2-.3 (D. Mass. March 27, 2020) (denying a defendant's motion to modify two protective orders in his criminal case for the purpose of pursuing claims in a civil ac