Epstein Secrets

S DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Plaintiff, v. GHISLAINE MAXWELL, Defendant. Before: 15 Civ. 7433 (RWS) Oral Argument New York, N.Y. March 31, 2017 12:08 p.m. HON. ROBERT W. SWEET, District Judge

provision? We're going to present to the jury it's Maxwell who got the benefit of the immunity provision. S

your Honor -- the first line, second sentence. "The allegations made by," and then it says Victoria , which is inaccurate by the drafter, "against Ghislaine Maxwell are untrue." And then it follows. But that is the backdrop to this. And she's responding to things about herself, not about anybody else that are

, advocacy statements by Kliman, such as calling Ms. Maxwell a perpetrator, someone he's never met before, bu

y. THE COURT: So problems enough I've got. MR. EDWARDS: I understand. I understand, your Honor. So at a time when Jeffrey Epstein is investigated, Ghislaine Maxwell is flying on his plane, she's vacationing with him. We have flight logs, we have photographs that were taken during that time. THE COURT: So what

22 23 24 25 problem. Well, no, it isn't. No, it isn't. Okay. So let's do 675. MS. MENNINGER: Your Honor, I will say that it is my reading of Rule 412 that any hearing that is based upon in part Rule 412 is supposed to be conducted in a in camera setting. MS. SCHULTZ: Counsel for Ms. has no objec

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

inor probative value the evidence has is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412 motion today, if offers testimony and the government presents argument 22 EFTA00090748 along these lines, that will open the door to other sexu

51 H3ulgiva 1 in 2015, which is, all of these allegations that deal with 2 Jeffrey Epstein and Ghislaine Maxwell, all of those allegations 3 are untrue, she has the ability to know all of the public 4 information that would tell her this is factually true.

at's fully briefed. 12 THE COURT: Yes. Okay. It's Maxwell's motion. 13 MS. McCAWLEY: Yes, your Honor. 14

llegations that deal with 2 Jeffrey Epstein and Ghislaine Maxwell, all of those allegations 3 are untrue,

he Churcher articles, which is 15 referenced by Ms. Maxwell's first public statement about 16 Ms. in 2011.

same 2 problem. Well, no, it isn't. No, it isn't. 3 Okay. So let's do 675. 4 MS. MENNINGER: Your Honor, I will say that it is my 5 reading of Rule 412 that any hearing that is based upon in part 6 Rule 412 is supposed to be conducted in a in camera setting. 7 MS. SCHULTZ: Counsel for Ms. has no

tively be scheduled for November 5, 2021. Additional details will be provided if and when any motions are filed. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated October 14, 2021 (Dkt.

led. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

ns are filed. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th

)(2). EFTA00065523 Case 1:20-cr-00330-AJN Document 351 Filed 10/15/21 Page 3 of 4 Page 3 "Given that the hearing provides an opportunity for the Rule 412 movant to detail the evidence he seeks to admit and for the parties to discuss the propriety of its admission, the notice requirement should be see

g notice under Rule 12.2. You seemed to take the position on our call yesterday that notice under Rule 12.2 is required if we plan to argue that Ms. Maxwell "was a victim in any way." We do not understand Rule 12.2 to be that broad. If you have any authority to substantiate your interpretation, we'd be

er Rule 12.2 is required if we plan to argue that Ms. Maxwell "was a victim in any way." We do not understand

iven serious consideration to your request to set a briefing schedule for the Rule 412 motion. After reflection, we believe the timeline provided in Rule 412 is appropriate and we do not agree that any earlier briefing schedule makes sense here in light of the fact that we just received the voluminous 350

g notice under Rule 12.2. You seemed to take the position on our call yesterday that notice under Rule 12.2 is required if we plan to argue that Ms. Maxwell "was a victim in any way." We do not understand Rule 12.2 to be that broad. If you have any authority to substantiate your interpretation, we'd be

er Rule 12.2 is required if we plan to argue that Ms. Maxwell "was a victim in any way." We do not understand

iven serious consideration to your request to set a briefing schedule for the Rule 412 motion. After reflection, we believe the timeline provided in Rule 412 is appropriate and we do not agree that any earlier briefing schedule makes sense here in light of the fact that we just received the voluminous 350