Epstein Secrets

elf pointed out, the characteristics of the modus operandi must be "sufficiently idiosyncratic to permit a fair inference of a pattern's existence." United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984)); see also United States v. Walla, No. 14—CR- 213 (MICE), 2014 WL 3734522, at *13 (S.D.N.Y. July 25, 2014

n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag

ns the admissibility of evidence of prior or subsequent tad acts'—evidence of `crimes, wrongs, or acts' other than those charged in the indictment." United States v. Curley, 639 F.3d 50, 56 (2d Cir. 2011) (quoting Fed. R. Evid. 404(b)). "The rule prohibits the admission of such evidence if it `prove[s] the cha

g), 108 Stat. 1796 6 iii EFTA00086739 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Strike Surplusage from the Indictment ("Motion"). Although Ms. Maxwell is charged with conspiring to cause individuals to travel in interstate or foreign commerce to

elf pointed out, the characteristics of the modus operandi must be "sufficiently idiosyncratic to permit a fair inference of a pattern's existence." United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984)); see also United States v. Walla, No. 14—CR- 213 (MICE), 2014 WL 3734522, at *13 (S.D.N.Y. July 25, 2014

n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag