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

s v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 13 EFTA00074481 United States v. Garcia, 291 F.3d 127 (2d Cir. 2002) 11 United States v. Mahsffr, 477 F. Supp. 2d 560 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) 9 United States v. McCallum, 584 F.3d 471 (2d Cir. 200

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

s v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 13 EFTA00087776 United States v. Garcia, 291 F.3d 127 (2d Cir. 2002) 11 United States v. Mahsffr, 477 F. Supp. 2d 560 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) 9 United States v. McCallum, 584 F.3d 471 (2d Cir. 200

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

sale of firearms and "narcotics transactions," are "part and parcel of the charged conduct or sufficiently similar to them); United States v. Mahe, 477 F. Supp. 2d 560, 566 (E.D.N.Y. 2007) (stating that, although the facts between two fraud schemes were "quite similar," the other acts were "a separate, disc