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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
probative value. These arguments rely heavily on a district court opinion from outside this circuit, United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court concludes that Dr. Rocchio's antici
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
st this weight of authority, the defendant relies principally on one case from the District of Maine. United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). The proposed 13 EFTA00088815 testimony in this case is readily distinguishable from that in Raymond. There, the government gave notice o
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger
ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Eve
INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffr
ruling on the admissibility for two weeks. 15 Ms. Maxwell reiterates her re, uest to defer III. THIS COUR
(S.D.N.Y. 2020) 37 United States v. Golyansky, 291 F.3d 1245 (10th Cir. 2002) 4 United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020 (D. Me. July 24, 2012)20 United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292 (S.D.N.Y. Oct. 20, 2015) 38 United States v. United States v. Un
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
probative value. These arguments rely heavily on a district court opinion from outside this circuit, United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court concludes that Dr. Rocchio's antici
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/11/21 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Ju
mental state when performing the behaviors. Second, the Court finds that Dr. Rocchio's opinions are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as the Second Circuit has explained, expert testimony cannot "constitute evaluations of witness credi
TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTR
ns are relevant to the Government's case against Ms. Maxwell. Two points of law bear mention here. For one, as
probative value. These arguments rely heavily on a district court opinion from outside this circuit, United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court concludes that Dr. Rocchio's antici
rto Rico 787-725-2611 or 1.866.690-2511 USVI and BVI 1.866.695-2511 THESE DISCLOSURES ARE NOT APPLICABLE TO COMMERCIAL ACCOUNTS CONFIDENTIAL SDNY GM 00014652 3:10~5.:418 OW/ COGI MF SPrrTI, 71.314)237130, 01 L CONFIDENTIAL FirstBankPR001815 EFTA_00 I 25295 EFTA01269898 STATEMENT OF ACCOUNT
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Entities connected to both Ghislaine Maxwell and D. Me

Jeffrey Epstein
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Prince Andrew
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United States
LOCATION
George W. Bush
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Department of Justice
ORGANIZATIONLeon Black
PERSONthe Southern District
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Julie K. Brown
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New York
LOCATIONMaria Farmer
PERSONDoug Band
PERSONFBI
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Joi Ito
PERSONEmmy Taylor
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Joe Biden
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Prince Charles
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John F. Kennedy
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Kenneth Marra
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Scarlett Johansson
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Bloomberg L.P.
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