Epstein Secrets

Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Chislain

is not "manifestly clear" that evidence is proof of the charged conspiracies, "the proper course is to proceed under Rule 4O4(b)." United States v. Townsend, No. SI 06 CR. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v. Nektalov, 325 F. Supp. 2d 367, 372 (S.D.N.Y. 2004))

51 F.2d 477 (2d Cir.1984) 41 Smalls, No. CR 06-2403 RB, 2008 WL 11361098 (D.N.M. Jan. 24, 2008) 3 Stein, 521 F. Supp. 2d 266 (S.D.N.Y. 2007) 38 Townsend, No. Si 06 CR. 34 (JFK), 2007 WL 1288597 (S.D.N.Y. May I, 2007) 29, 36 Tracy, 12 F.3d 1186 (2d Cir.1993) 5 Velez, No. 3:10CR147 JBA, 2010 WL 49

-TV <https://www.thedenverchannel.cornMews/crime/former-it-director-for-vail-arrested-on- embezzlement-charges-now-fugitive-after-cutting-off-device> Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

governor extended a coronavirus executive order. `I swear to God, if this is true I'm going to Molotov her (expletive) house,' he said, according to Townsend. `I'm so (expletive) done with her. She needs to be dragged to the street and hung!" The AP <https://www.chron.corn/news/article/Bond-greatly-reduc

murder." King had "pleaded guilty to the charges on Feb. 10," and he was sentenced to 97 months in prison. FBI Searching For Colorado Man. KMGH-TV Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

overnor extended a coronavirus executive order. `I swear to God, if this is true I'm going to Molotov her (expletive) house,' he said, according to Townsend. 'I'm so (expletive) done with her. She needs to be dragged to the street and hung." The AP (11/13) reports from Jackson, Michigan, "A judge greatl

murder." King had "pleaded guilty to the charges on Feb. 10," and he was sentenced to 97 months in prison. FBI Searching For Colorado Man. KMGH-TV Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

overnor extended a coronavirus executive order. `I swear to God, if this is true I'm going to Molotov her (expletive) house,' he said, according to Townsend. 'I'm so (expletive) done with her. She needs to be dragged to the street and hung." The AP (11/13) reports from Jackson, Michigan, "A judge greatl

SSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 Phone: Attorneys for Ghislain

6, 8, 9, 10 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 11 United States v. Sliker, 751 F.2d 477 (2d Cir. 1984) 12 United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597 (S.D.N.Y. May 1, 2007) 6, 9, 10 United States v. Walla, No. 14—CR-213 (MKB), 2014 WL 3734522 (S.D.N.Y. J

murder." King had "pleaded guilty to the charges on Feb. 10," and he was sentenced to 97 months in prison. FBI Searching For Colorado Man. KMGH-TV Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

governor extended a coronavirus executive order. `I swear to God, if this is true I'm going to Molotov her (expletive) house; he said, according to Townsend. `I'm so (expletive) done with her. She needs to be dragged to the street and hung." The AP (11/13) reports from Jackson, Michigan, "A judge greatl