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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

t understand why the Minor Victims continued to 3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), Judge Garaufis questioned whether an expert on grooming with experience focused on victims may have been able to testify reliably about how "perpetrators often use

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

ng. The government implicitly concedes as much. In a footnote, the government acknowledges the decision in United States v. Raniere, in which Judge Garaufis ordered a Daubert hearing on the government's proposed expert testimony on grooming. 2019 WL 2212639, at *7-8. In that case, however, the government

set. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: At the Nove

reviously set. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: At

es may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding p

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter r

usly set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Nathan: A

as previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Na

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter r

usly set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Nathan: A

as previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Na

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) AI 11/11/21 Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint lett

usly set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) AI 11/11/21 Dear Judge Nathan

as previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) AI 11/11/21 Dear Judg

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding p

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

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

formation. III. Limiting Instruction The Government requests that the Court give the July an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding p

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

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

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes