Epstein Secrets

ourt Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.736

rado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "prior investigative files from another investigation in the Southern District of Florida," which it

nment's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Had

conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "

witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min

Dr. Rocchio's proposed testimony is silent as to whether she is expected to impute a theory of `grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself," but instead that she "recruited and grooming minors to provide sexualized

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW

K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM

`grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualiz

29 United States v. Labansat, 94 F.3d 527 (9th Cir. 1996) 26, 30 United States v. Libby, 461 F. Supp. 2d 3 (D.D.C. 2006) passim United States v. Lumpkin, 192 F.3d 280 (2d Cir. 1999) 20,21,22,31 United States v. Mathis, 264 F.3d 321 (3d Cir. 2001) 29 United States v. Moore, 798 F.2d 1308 (5th Cir.

ourt Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.736

rado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "prior investigative files from another investigation in the Southern District of Florida," which it

nment's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Had

conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "

witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min

ourt Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.736

rado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "prior investigative files from another investigation in the Southern District of Florida," which it

nment's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Had

conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "

witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min

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

nce of 50 feet under "streetlight illumination" but was familiar with defendant from seeing him previously in neighborhood); accord United States v. Lumpkin, 192 F.3d 280, 288 (2d Cir. 1999) (officers' in-court identifications reliable where officers had unobstructed views of the defendant selling narco

ourt Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, P.0 Jeffrey PagIluca Denver. Colorado www.hmtlaw.com At the initial conference

don, Morgan and Foreman, P.0 Jeffrey PagIluca Denver. Colorado www.hmtlaw.com At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "prior investigative files from another investigation in the Southern District of Florida," which it

nment's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Had

conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "

witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min

ourt Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.736

rado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "prior investigative files from another investigation in the Southern District of Florida," which it

nment's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Had

conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "

witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min

l" despite testimony that about 40 women had come forward with abuse allegations. According to the article, Acosta insisted he never met Epstein or Ghislaine Maxwell and denied ever seeing President Donald Trump's name in any related documents, while committee chairman Rep. James Comer said Acosta was cooperative

costa insisted he never met Epstein or Ghislaine Maxwell and denied ever seeing President Donald Trump's n

article, Acosta insisted he never met Epstein or Ghislaine Maxwell and denied ever seeing President Donald T

nd investigation by the Palm Beach County Sheriff's Office. One Hundred Seventy Seven Fugitives Arrested in Massive Georgia Operation Patch (09/19, Lumpkin) reported that a large-scale federal operation in Georgia, named Operation No Escape, resulted in the arrest of 177 fugitives. According to the arti