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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) GIIISLAINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN & FOR
eys for Ghislain Maxwell 58 EFTA00155965 Certificate of Service I hereby certify that on January 19, 2022, I electronically filed the foregoing Ohislaine Maxwell's Motion for a New Trial, with the Court and counsel for the government: U.S. Attorney's Office SDNY One Saint Andrew's Plaza New York. NY 10007 s
w.dailymail.co.uk/news/article-10379445/Ghislaine-Maxwells- lawyers-fought-ask-jurors-detailed-questions-sex
e Law 21 I. Juror No. 50's misconduct deprived Ms. Maxwell of her constitutional right to a fair trial by a
(Brennan, J., concurring in judgment)). The seminal case addressing a juror's false answers during voir dire is McDonough Power Equipment, Inc. v. Greenwood. McDonough was a products liability action in which Juror Payton remained silent when the district court asked, "how many of you [potential jurors]
54 Mazzeo v. Gibbons, No. 2:08-CV-01387-RLH-PA, 2010 WL 3910072 (D. Nev. Sept. 30, 2010) 53 iv EFTA00155904 McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984) passim Metzger v. Hussman, 682 F. Supp. 1109 (D. Nev. 1988) 53 Murphy v. Admit- E. Jersey State Prison, No. 18-2825, 2021 WL
rt because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was public
the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publicly filed on Monday. 'Ms. Maxwell remains in good health,' the lawyers wrote in the letter as they defended her treatment as by-the-book following of rules to ensure the safety of al
ild Pandering Charges. • Attorneys Seek Bail For Ghislaine Maxwell. • FBI Seizes 40 Pounds Of Meth, Two Pou
riday letter that was publicly filed on Monday. 'Ms. Maxwell remains in good health,' the lawyers wrote in the
ican politicians he once endorsed." The Wall Street Journal. (12/7, Corse, Subscription Publication, 7.57M), &jai (12/7, 521K), and The Hill (12/7, Greenwood, 2.98M) also cover the certification, while other outlets examine EFTA00135835 the impact of the fight between Trump and his party's leaders in Ge
ana Reservation. • FBI Joins Search For Missing Florida Teacher. • Ohio Firefighter Arrested On Child Pandering Charges. • Attorneys Seek Bail For Ghislaine Maxwell. • FBI Seizes 40 Pounds Of Meth, Two Pounds Of Heroin In New Mexico. • Resident Of State Of New York Sentenced To Decade In Prison For Selling Crac
part because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Stemheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that
e Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Stemheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publ
Friday letter that was publicly filed on Monday. `Ms. Maxwell remains in good health,' the lawyers wrote in th
521K), and The Hill <https://thehill.corn/homenews/campaign/529028-georgia-secretaty-of-state-says-he-will-recertify-election- results-after> (12/7, Greenwood, 2.98M) also cover the certification, while other outlets examine the impact of the fight between Trump and his party's leaders in Georgia on the tw
rt because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publi
the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publicly filed on Monday. `Ms. Maxwell remains in good health; the lawyers wrote in the letter as they defended her treatment as by-the-book following of rules to ensure the safety of al
ild Pandering Charges. • Attorneys Seek Bail For Ghislaine Maxwell. • FBI Seizes 40 Pounds Of Meth, Two Pou
riday letter that was publicly filed on Monday. `Ms. Maxwell remains in good health; the lawyers wrote in the
ican politicians he once endorsed." The Wall Street Journal (12/7, Corse, Subscription Publication, 7.57M), Axios (12/7, 521K), and The Hill (12/7, Greenwood, 2.98M) also cover the certification, while other outlets examine the impact of the fight between Trump and his party's leaders in Georgia on the tw
art because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell's behalf after lawyers for the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was public
the Metropolitan Detention Center warden in Brooklyn defended conditions at the facility in a Friday letter that was publicly filed on Monday. 'Ms. Maxwell remains in good health,' the lawyers wrote in the letter as they defended her treatment as by-the-book following of rules to ensure the safety of al
the request of the FBI." Attorneys Seek Bail For Ghislaine Maxwell. The AP (12/7, Neumeister) reports from N
riday letter that was publicly filed on Monday. 'Ms. Maxwell remains in good health,' the lawyers wrote in the
lican politicians he once endorsed." The Wall Street Journal (12/7, Corse, Subscription Publication, 7.57M), Axios (12/7, 521K), and The Hill (12/7, Greenwood, 2.98M) also cover the certification, while other outlets examine the impact of the fight between Trump and his party's leaders in Georgia on the t
Entities connected to both Ghislaine Maxwell and Greenwood

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONFBI
ORGANIZATION
Alison J. Nathan
PERSON
Denver
LOCATIONEmmy Taylor
PERSON