Epstein Secrets

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

of the crime alleged. United States v. Gross, No. 15-cr-769 (AN), 2017 WL 4685111, at *20 (S.D.N.Y. Oct. 18, 2017), of 'd sub nom. United 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 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (MN) GHISLAINE MAXWELL, Defendant. [PROPOSED] JOINT REQUESTS TO CHARGE EFTA00074500 TABLE OF CONTENTS INTRODUCTORY INSTRUCTIONS 1 Role of the Court 1 Role

d States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 17 Cr. 151 (AJN). 11 EFTA00074514 The Indictment The defendant, GHISLAINE MAXWELL, has been formally charged in what is called an Indictment. An indictment is simply a charge or accusation. It is not evidence. It is not proof of

RK UNITED STATES OF AMERICA S2 20 Cr. 330 (MN) GHISLAINE MAXWELL, Defendant. [PROPOSED] JOINT REQUESTS TO CHARGE

als at the bar of justice. Adapted from the charge of the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 533 (AJN) and in United States v. Lebedev, 15 Cr. 769 (AN). 8 EFTA00074511 Presumption of Innocence and Burden of Proof The law presumes the defendant to be innocent of all charges agai

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

imony is not expert testimony, and therefore its admission is not precluded by Rule 702. 22 EFTA00024977 --- PAGE BREAK --- See United States v. Lebedev, 932 F.3d 40, 50 (2d Cir. 2019) (concluding that "an account and litigation consultant" who "summar[ized] . . . the relevant financial records" was