Epstein Secrets

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

hallenge. "Although the Government did not present 71 EFTA00088873 evidence regarding the circumstances surrounding the seizure of the USB drive, Federal Rule of Evidence 901(b)(4) permits authentication based on Mlle appearance, contents, substance, internal patterns, or other distinctive characteristics of t

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter regarding birth certificates that are marked as Government

, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Gove

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

r materials from prison were self-authenticating under Rules 902(2) and 902(4) and that "Federal Rule of Civil Procedure 44(a)(1), incorporated into Federal Rule of Criminal Procedure 27, accords with our analysis."). EFTA00068497 Page 6 III. Conclusion For the foregoing reasons, the Court should determine t

18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershotvitz v. Giuffre 3n tlje Elute)) i§tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI H

tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOW

ons. In response to the allegations, on January 3, 2015, Maxwell's publicist issued a press statement declaring that Giuffre's allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies. "6 B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against

t court's decision whether to discharge or retain a Receiver); see also FTC. v. Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of Evidence 401's "having any tendency" definition of relevance in determining whether documents were "judicial documents"). 1' As we explain below, th

— ■ Page 151 i i 1 with Mr. Indyke? 2 A No. 3 Q There appear to be a number of 4 corporations. El Zorro Ranch Corporation, New York 5 Strategy Group, Ghislaine, G-HT-S-L-ArEN-E, 6 Corporation, J. Epstein and Company and the 7 Financial Strategy Group. Do you see those? 8 A Ido. 9 Q‘ Do you recall anything, s

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as evidence. See Fed! R. Crim. P. 11(f) (“The admissibility or inadmissibility of a plea, a plea discussion, and any related statement is governed by Federal Rule of Evidence 410.”). In any case, the victims could have been impeached regarding the possibility' of their obtaining monetary damages through either a ci