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

hat the average juror is not capable of understanding on his or her own." United States v. Mejia, 545 F.3d 179, 194 (2d Cir. 2008); see Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N.Y. 2014) ("Weighing whether the expert testimony assists the trier of fact goes primarily to relevance."). Court

hey're taking a narrow 6 uncontested principle, that her net worth doesn't come in, and 7 are going to try to use it to exclude evidence that Ms. Maxwell 8 is making payments to the girls, that this mansion is a very 9 THE COURT: Well, okay. I don't think so. 10 MR. CASSELL: Let me just make sure

our Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special master and Mr. Dershowitz: "Q. Ghislaine 14 Maxwell was never the target of the investigation, was she?" 15 Confirming and arguing that Dershowitz is wrong about this 16 joint defense

uts. 21 At page 387: I witnessed the same thing -- all the girls 22 did -- the same thing I had to do was go and report to 23 Leslie Groff, and Ghislaine Maxwell. Ghislaine was the 24 main lady. So again, we have an allegation by our client that 25 Ms. Maxwell was a part of a larger conspiracy. That's one

e going to try to use it to exclude evidence that Ms. Maxwell 8 is making payments to the girls, that this ma

s his restraining 14 order, he knew about it, and it showed his willful intent to 15 defraud as part of the bank fraud. So that's that case. 16 Arista Records, LLC v. Lime Group, LLC was another 17 case they rely on. Again, these are emails that are being 18 talked about that were written by the defenda

think they're taking a narrow uncontested principle, that her net worth doesn't come in, and are going to try to use it to exclud vidence that Ms. Maxwell is making payments to the girls, that this mansion is a very -- THE COURT: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I

she takes the Fifth. There are other things as well. For example, Sarah Ransome testified, I witnessed with my own two eyes Sarah Kellen reporting to Ghislaine in front of me, but I can't remember specifics. They weren't talking about girls. I can't remember the specific conversation, but every single perso

uts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Sarah Kellen, Leslie Groff, and Ghislaine Maxwell. Ghislaine was the main lady. So again, we have an allegation by our client that Ms. Maxwell was a part of a larger conspiracy. That's one of SOUT

are going to try to use it to exclud vidence that Ms. Maxwell is making payments to the girls, that this mansio

ecause it was his restraining order, he knew about it, and it showed his willful intent to defraud as part of the bank fraud. So that's that case. Arista Records, LLC v. Lime Group, LLC was another case they rely on. Again, these are emails that are being talked about that were written by the defendant's emp

hink they're taking a narrow uncontested principle, that her net worth doesn't come in, and are going to try to use it to exclude evidence that Ms. Maxwell is making payments to the girls, that this mansion is a very - THE COURT: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I

our Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special master and Mr. Dershowitz: "Q. Ghislaine 14 Maxwell was never the target of the investigation, was she?" 15 Confirming and arguing that Dershowitz is wrong about this 16 joint defense

and thereabouts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Leslie Groff, and Ghislaine Maxwell. Ghislaine was the main lady. So again, we have an allegation by our client that Ms. Maxwell was a part of a larger conspiracy. That's one of SOUT

e going to try to use it to exclude evidence that Ms. Maxwell is making payments to the girls, that this mansi

ecause it was his restraining order, he knew about it, and it showed his willful intent to defraud as part of the bank fraud. So that's that case. Arista Records, LLC v. Lime Group, LLC was another case they rely on. Again, these are emails that are being talked about that were written by the defendant's emp