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

29, Jan. 10, 2022) 50 Davis v. Bombardier Recreational Prod., Inc., No. 3:11CV236-TSL-MTP, 2012 WL 112202 (S.D. Miss. Jan. 12, 2012) 52 Dyer v. Calderon, 151 F.3d 970 (9th Cir.1998) 27, 30 Gonzales v. Thomas, 99 F.3d 978 (10th Cir. 1996) 36 Hunley v. Godinez, 975 F.2d 316 (7th Cir. 1992) 29 In r

2Tfir3N33(IDACIDMEEDdillibiligQ911031200309101528% ef15of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED noC 0: un rr. FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHA

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

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

nd Circuit have applied the standard for modification of protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3: I5-CR-25 (JCR), 2017 WL 6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a

ase 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED noC *: Dn FF. FILED: 9/2/20 20-CR-330 (AJN) MEMORANDUM OPINION AND ORDER ALISON J. NATH

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

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

nd Circuit have applied the standard for modification of protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3: I5-CR-25 (J0-1), 2017 WL 6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Chislaine 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. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

are of any. Though precedent on this issue appears to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to

obinson's birthday, as National Tap Dance Day. Robinson was born in Richmond, Virginia an= raised in its Jackson Ward neighborhood. His parents were Maxwell, a machine-shop worker,=and Maria Robinson, a choir singer. His grandmother raised him after both parents died in 1885 when he was 7 years =Id — hi

g and cut health bills fr=m pollution. "It is possible to tackle climate change and it is possible to have economic growth at the same time," Feli=e Calderon, a former Mexican president and head of the Global Commission on t=e Economy and Climate, told a news conference. Many governments and businesses w

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

decisions that do exist have rejected the kind of blurring of the line between criminal and civil proceedings that the defendant attempts here. See Calderon, 2017 WL 6453344, at 5-6 (denying a defendant's application for modification of a criminal protective order so he could use certain discovery materi

are of any. Though precedent on this issue appears to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to

ase 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN,

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY

DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

nd Circuit have applied the standard for modification of protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3:15-CR-25 (JCR), 2017 WL 6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a

as212-6r310193MACINnEEIVANN95202QIERVON0:37217a Fab efi5of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 9/2/20 20-CR-330 (AJN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN,

OF NEW YORK United States of America, Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY

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

nd Circuit have applied the standard for modification of protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3:15-CR-25 (JCH), 2017 WL 6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a