Epstein Secrets

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 MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3 Christian R. Everdell

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO

not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the

he Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the governmen

437 (quoting Bagaric, 706 F.2d at 64); see also United States v. Benussi, 216 F. Supp. 2d 299, 311 (S.D.N.Y. 2002), affd sub nom. United States v. Sabnonese, 352 F.3d 608 (2d Cir. 2003) (the "scope of the conspiratorial agreement" is the key to determining whether "an overt act may properly be regarded

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 MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3 Christian R. Everdell

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO

not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the

he Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the governmen

437 (quoting Bagaric, 706 F.2d at 64); see also United States v. Benussi, 216 F. Supp. 2d 299, 311 (S.D.N.Y. 2002), affd sub nom. United States v. Sabnonese, 352 F.3d 608 (2d Cir. 2003) (the "scope of the conspiratorial agreement" is the key to determining whether "an overt act may properly be regarded

20-cr-00330-AJN Document 657 Filed 04/29/22 Page 1 of 45 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC //: DATE FILED: 4/29/22 20-CR-330 (MN) OPINION & ORDER ALISON J. NATHAN, Circuit Jud

the Double Jeopardy Clause would prohibit only multiple punishments for the same offense, but not indictments for the same offense. United States v. Maxwell, 534 F. Supp. 3d 299, 322 (S.D.N.Y. 2021) (citing United States v. Josephberg, 459 F.3d 350, 355 (2d Cir. 2006)); United States v. Maxwell, No. 20-

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

ent must establish beyond a reasonable doubt that Ms. Maxwell acted with the intent that the minors would enga

, upon review, it is uncertain whether the defendant was convicted of conduct that was the subject of the grand jury's indictment." United States v. Sabnonese, 352 F.3d 608, 620 (2d Cir. 2003) (quoting United States v. Frank, 156 F.3d 332, 337 (2d Cir. 1998)). In making this determination, the Court first