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Dr. Rocchio's proposed testimony is silent as to whether she is expected to impute a theory of `grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself," but instead that she "recruited and grooming minors to provide sexualized
K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM OF LAW
K UNITED STATES OF AMERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM
`grooming-by-proxy' to the defendant," and that "Ms. Maxwell is not accused of soliciting or enticing sexualiz
v. Nat'l R.R. Pass. Corp., 303 F.3d 256 (2d Cir. 2002) 7 Barnette v. United States, No. 12 Civ. 327, 2021 WL 949848 (W.D.N.C. March 12, 2021) 17 Boucher v. US. Suzuki Motor Corp., 73 F.3d 18 (2d Cir. 1996) 8, 23 Bourjaior v. United States, 483 U.S. 171 (1987) 6 Daubert v. Merrell Dow Pharm., Inc.,
opinion is irrelevant and should be precluded for lack of fit with the facts of the case. See, e.g., LVL XIII Brands, Inc., 209 F. Supp. 3d at 642; Boucher, 73 F.3d at 21 ("expert testimony should be excluded if it is [inter alia] in essence an apples and oranges comparison" (internal quotation marks a
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
nderhoff "appears to advocate more restrictions." Whitmer Extends Michigan's COVID Restrictions For Another 12 Days. The Detroit Free Press (12/7, Boucher, Shamus, 1.52M) reports Michigan Gov. Gretchen Whitmer (D) on Monday announced "restrictions on indoor dining and in-person classes will remain in e
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
ys. The Detroit Free Press <https://www.freep.corn/story/news/health/2020/12/07/michigan-covid-19-restrictions- extended-12-days/3856325001/> (12/7, Boucher, Shamus, 1.52M) reports Michigan Gov. Gretchen Whitmer (D) on Monday announced "restrictions on indoor dining and in-person classes will remain in e
tein and Celina developed `an especially close relationship' when Celina was 12 and it continued into adulthood, according to the Palm Beach Post." Maxwell Placed In Quarantine After Jail Staffer Tests Positive For Coronavirus. Bloomberg <https://www.bloomberg.corn/news/articles/2020-11-23/ghislaine-max
ected Treasury Pick, Has Broken More Than Gender Bathers <https://www.nytimes.com/2020/11/23/business/economy/janet-yellen-treasury-secretary.html> GM Drops Its Support For Trump Climate Rollbacks And Aligns With Biden <https://www.nytimes.com/2020/11/23/climate/general-motors-trump.html> China Sa
o, 4.73M) reports US prosecutors said Monday that Ghislaine Maxwell "has been placed in quarantine after a s
ell-quarantined-after-jail-staffer-catches- EFTA00137304 covid?smd=premium> (11/23, Bumson, Hurtado, 4.73M) reports US prosecutors said Monday that Ghislaine Maxwell "has been placed in quarantine after a staff member of the jail where she is being held tested positive for the coronavirus." In a letter to the jud
Today <https://www.usatoday.com/story/news/politics/elections/2020/11/23/did-michigan-certify-election- results-board-canvassers/6399753002/> (11/23, Boucher, 10.3IM) reports Biden "earned approximately 154,000 more votes than...Trump in the state," but the President "and supporters have argued, without e
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
nderhoff "appears to advocate more restrictions." Whitmer Extends Michigan's COVID Restrictions For Another 12 Days. The Detroit Free Press (12/7, Boucher, Shamus, 1.52M) reports Michigan Gov. Gretchen Whitmer (D) on Monday announced "restrictions on indoor dining and in-person classes will remain in
n Quarantine After Jail Staffer Tests Positive For Corona virus. Bloomberg (11/23, Burnson, Hurtado, 4.73M) reports US prosecutors said Monday that Ghislaine Maxwell "has been placed in quarantine after a staff member of the jail where she is being held tested positive for the coronavirus." In a letter to the jud
laced in quarantine after a staff member of the jail where she is being held tested positive for the coronavirus." In a letter to the judge handling Maxwell's criminal case, prosecutors said a rapid test found her to be free of COVID-19. Maxwell "will remain in quarantine for 14 days - and will then be
ury And Intelligence, And First Latino To Run Homeland Security Janet Yellen, Biden's Expected Treasury Pick, Has Broken More Than Gender Barriers GM Drops Its Support For Trump Climate Rollbacks And Aligns With Biden China Says It Remains Open To The World, But Wants To Dictate Terms AstraZeneca
, 4.73M) reports US prosecutors said Monday that Ghislaine Maxwell "has been placed in quarantine after a st
ballots were processed, and Michigan Secretary of State Jocelyn Benson (D) has promised to conduct an audit after certification. USA Today (11/23, Boucher, 10.31M) reports Biden "earned approximately 154,000 more votes than...Trump in the state," but the President "and supporters have argued, without
angelo, 5.69M) also reports. Judge Again Denies Ghislaine Maxwell's Bail Request. The New York Times (12/28, Shanahan
nied bail by a federal judge on Monday: The Times says that the ruling "came in response to a $28.5 million bail package, proposed this month by Ms. Maxwell. It would have released her from what her lawyers called the 'intolerable' conditions in jail and into house arrest at a friend's New York City home
angelo, 5.69M) also reports. Judge Again Denies Ghislaine Maxwell's Bail Request. The New York Times (12/28
28.5 million bail package, proposed this month by Ms. Maxwell. It would have released her from what her lawyer
ngly made false statements about the company and voter fraud, describing her mockingly as Giuliani's 'star witness:" The Detroit Free Press (12/28, Boucher, 2.16M) reports that last week, Dominion Voting Systems "sent cease-and-desist letters to a litany of people tied to the campaign of President Donal
one Data. In continuing coverage, Newsweek (1/5, Royston, 2.67M) reports an affidavit indicates that the FBI's Jeffrey Epstein investigation traced Ghislaine Maxwell "using her cell phone data and a fake mobile phone mast." Newsweek adds, "The FBI had already obtained a warrant for her GPS and location data on t
ion. • Continuing Coverage: FBI Traced Ghislaine Maxwell Using Cell Phone Data. • Continuing Coverage: Ba
Distribution. • Continuing Coverage: FBI Traced Ghislaine Maxwell Using Cell Phone Data. • Continuing Cove
for March 10." FBI Says It Was Unaware Agent Was Interrogating Legislative Staffer About Conversation On Legislation. The Detroit Free Press (1/5, Boucher, 2.16M) reports that in a statement, the FBI said that while it interrogated Michigan state Sen. Rosemary Bayer's chief of staff Katie Reiter about
Entities connected to both Ghislaine Maxwell and Boucher

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Newark
LOCATION
Department of Justice
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONFBI
ORGANIZATION
Alison J. Nathan
PERSONEmmy Taylor
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Samantha Power
PERSON
Stephen Hawking
PERSON