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

za New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00088802 Table of Contents PRELIMINARY STATEMENT 1 ARGUMENT 4 I. The Court Should Admit the Testimony of Dr. 4 A. Applicable Law 5 B. Discussion 9 1. Dr. )pinions on Coercion and Attachment are Admissible 10 2.

d Jury Subpoena to Amazon.com, Inc., dated June 12, 2020) A. Please provide records for all accounts associated with the following identifiers: • Ghislaine Maxwell • Ghislaine Borgerson • Records should include, but are not limited to, the following: 1. All subscriber identifying information, including, bu

ted with the following identifiers: • Ghislaine Maxwell • Ghislaine Borgerson • Records should includ

ts associated with the following identifiers: • Ghislaine Maxwell • Ghislaine Borgerson • Records shoul

0 MAG 6216 § 2705(b) Non-Disclosure Order to Service Provider SEALED Upon the application of the United States pursuant to 18 U.S.C. § 2705(b): I. The Court hereby determines that there is reason to believe that notification of the existence of the attached subpoena will result in one or more of the foll

all records for any Instragram accounts registered to or associated with the following identifiers: • Phone number: • • Possible account name: ghislainemaxwell6 All records should include, but are not limited to, the following: 1. All subscriber identifying information, including, but not limited to: a.

0 MAG 6375 § 2705(b) Non-Disclosure Order to Service Provider SEALED Upon the application of the United States pursuant to 18 U.S.C. § 2705(b): I. The Court hereby determines that there is reason to believe that notification of the existence of the attached subpoena will result in one or more of the foll