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

55 EFTA00155905 United States v. Collins, 2013 WL 4780927 (ED. Wis. 2013) United States v. Colombo, 869 F.2d 149 (2d Cir. 1989) United States v. Daugerdas, 867 F. Supp. 2d 445 (S.D.N.Y. 2012) 51 27 passim United States v. Eubanks, 591 F.2d 513 (9th Cir. 1979) 30 United States v. French, 904 F.3d 1

imply bias. First, "[c]ourts imply bias `when there are similarities between the personal experiences of the juror and the issues being litigated.' Daugerdas, 867 F. Supp. 2d at 472 (quoting Sampson, 820 F. Supp. 2d at 163-64); see also Skaggs v. Otis Elevator Co., 164 F.3d 511, 517 (10th Cir. 1998) (col

, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: Counsel for Ghislaine Maxwell renew our request that the Court release the names of potential jurors, for

Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan:

lso the subject of extensive ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a procedure that would violate due process in this particular case.' "An impartial jur

ors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial

free of interest and bias." United States v. Parse, 789 F.3d 83, 111 (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86. After trial,

, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: Counsel for Ghislaine Maxwell renew our request that the Court release the names of potential jurors, for

lso the subject of extensive ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a procedure that would violate due process in this particular case.' "An impartial jur

Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan:

ors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial

free of interest and bias." United States v. Parse, 789 F.3d 83, III (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86. After trial,

20-cr-00330-AJN Document 657 Filed 04/29/22 Page 1 of 45 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC //: DATE FILED: 4/29/22 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, Circuit Jud

the Double Jeopardy Clause would prohibit only multiple punishments for the same offense, but not indictments for the same offense. United States v. Maxwell, 534 F. Supp. 3d 299, 322 (S.D.N.Y. 2021) (citing United States v. Josephberg, 459 F.3d 350, 355 (2d Cir. 2006)); United States v. Maxwell, No. 20-

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

ent must establish beyond a reasonable doubt that Ms. Maxwell acted with the intent that the minors would enga

ted States v. Lebedev, 932 F.3d 40 (2d Cir. 2019). The "core of criminality ... involves the essence of a crime, in general terms." United States v. Daugerdas, 837 F.3d 212, 225 (2d Cir. 2016) (alteration in original) (quoting United States v. D'Amelio, 683 F.3d 412, 418 (2d Cir. 2012)). The Court then de