Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN,

the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA00068504 The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's

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

the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA0006

on inadmissible evidence, including hearsay, if `experts in the field reasonably rely on such evidence in forming their opinions!" United States v. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). But Rule 703 does not permit an expert to "simply transmit that hearsay to the jury." Id. Rather, those underlyin

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN,

the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA00087206 The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's

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

the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA0008

on inadmissible evidence, including hearsay, if `experts in the field reasonably rely on such evidence in forming their opinions!" United States v. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). But Rule 703 does not permit an expert to "simply transmit that hearsay to the jury." Id. Rather, those underlyin

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

). In this context, the testimony must "concern matters that the average juror is not capable of understanding on his or her own." United States v. Mejia, 545 F.3d 179, 194 (2d Cir. 2008); see Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N.Y. 2014) ("Weighing whether the expert testimo

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:i 102121 20-CR-330 (AJN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN,

the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA00089907 The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's

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

the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. 4 EFTA0008

on inadmissible evidence, including hearsay, if `experts in the field reasonably rely on such evidence in forming their opinions!" United States v. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). But Rule 703 does not permit an expert to "simply transmit that hearsay to the jury." Id. Rather, those underlyin

industry, consult with our allies, and make an assessment as to what's best for American national and economic security." INTERNATIONAL RELATIONS Ghislaine Maxwell Seeks Dismissal Of Case. Reuters (1/26, Stempel) reports Ghislaine Maxwell requested the dismissal of the case accusing her of recruiting teenage girls f

for American national and economic security." INTERNATIONAL RELATIONS Ghislaine Maxwell Seeks Dismissal Of Case. Reuters (1/26, Stempel) reports Ghislaine Maxwell requested the dismissal of the case accusing her of recruiting teenage girls for Jeffrey Epstein to sexually abuse. Her attorneys argued that Flori

Blacklist. INTERNATIONAL RELATIONS • Ghislaine Maxwell Seeks Dismissal Of Case. LAWFUL ACCESS • Nonpro

awei On US Blacklist. INTERNATIONAL RELATIONS • Ghislaine Maxwell Seeks Dismissal Of Case. LAWFUL ACCESS

eynoso saying, "it wouldn't be fair in any way, shape or form to link" the explosion and demonstrators. Now members of the movement are "upset that Mejia is now playing the martyr, and that their activism against a proud hatemonger needs to lay low for a while." Appeals Court Considers Constitutional

06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to C

Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S.

ent With Her Own Attorneys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as foll

ys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as follows: INTRODUC

xwell prove otherwise. Not so: "[t]tre party asserting the privilege ... bears the burden of establishing its essential elements." United States v. Mejia, 655 F.3d 126, 132 (2d Cir. 2011). As pointed out, particularly in light of Edwards's position as a director and founder of VRS, communications II

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. RYAN HALL, BENNETT GERSHMAN

ugh an expert may rely on hearsay in forming his opinion, the "expert may not, however, simply transmit that hearsay to the jury." United States v. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). Instead, "if facts or data would otherwise be inadmissible, the proponent of the opinion may disclose them to the