DOJ-OGR-00002714.jpg
567 KB
Extraction Summary
5
People
4
Organizations
2
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Court filing / legal motion (defense motion for accelerated disclosure)
File Size:
567 KB
Summary
This document is page 21 of a defense motion filed on February 4, 2021, in the case of USA v. Ghislaine Maxwell. The defense attorneys (Cohen & Gresser LLP) are requesting the Court order the government to disclose 'bad acts' evidence (Rule 404(b)) by March 12, 2021, a request the government previously denied. The document concludes the legal brief and is signed by Mark S. Cohen.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the defense motion; requesting notice of evidence against her.
|
| Mark S. Cohen | Defense Attorney |
Signatory of the motion; representing Ms. Maxwell.
|
| Christian R. Everdell | Defense Attorney |
Listed counsel for Ms. Maxwell.
|
| Jeffrey S. Pagliuca | Defense Attorney |
Listed counsel for Ms. Maxwell.
|
| AJN | Judge (initials) |
Alison J. Nathan (implied by case number suffix), presiding judge addressed in header.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| COHEN & GRESSER LLP |
Law firm representing the defense.
|
|
| The Government |
Prosecution; opposing party in the case.
|
|
| Federal Rules of Evidence |
Legal framework cited (specifically Rule 404(b)).
|
|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR).
|
Timeline (3 events)
2021-01-25
Submission of Motion for Accelerated Disclosure
New York, New York
2021-03-12
Locations (2)
| Location | Context |
|---|---|
|
Location of filing and venue.
|
|
|
Address of Cohen & Gresser LLP.
|
Relationships (2)
Cohen signs the motion on behalf of Maxwell.
Everdell is listed as counsel on the motion.
Key Quotes (2)
"Ms. Maxwell should be put on notice as soon as possible of the exact nature of any 404(b) evidence"Source
DOJ-OGR-00002714.jpg
Quote #1
"We have conferred with the government and requested that all Rule 404(b) evidence be provided by March 12, 2021, but the government has denied this request."Source
DOJ-OGR-00002714.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,496 characters)
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 21 of 23
VII. Motion for Accelerated Disclosure of 404(b) Evidence
The defense requests that the Court direct the government to disclose any and all acts
and any evidence it intends to introduce under Rule 404(b) of the Federal Rules of Evidence
or as background of the conspiracy charged in the Indictment.
and any evidence it intends to introduce under Rule 404(b) of the Federal Rules of Evidence
or as background of the conspiracy charged in the Indictment.
Ms. Maxwell should be put on notice as soon as possible of the exact nature of any
404(b) evidence, the witnesses pertaining thereto, the documents in support thereof and the
theory upon which the government asserts admissibility rests. By providing prompt notification,
the defense can investigate the allegations and file appropriate motions to permit the Court to
make pretrial determinations regarding the admissibility of any potential Rule 404(b) evidence
proffered by the government. We have conferred with the government and requested that all
Rule 404(b) evidence be provided by March 12, 2021, but the government has denied this
request. We therefore request that the Court order the government to produce all Rule
404(b) evidence by that date.
404(b) evidence, the witnesses pertaining thereto, the documents in support thereof and the
theory upon which the government asserts admissibility rests. By providing prompt notification,
the defense can investigate the allegations and file appropriate motions to permit the Court to
make pretrial determinations regarding the admissibility of any potential Rule 404(b) evidence
proffered by the government. We have conferred with the government and requested that all
Rule 404(b) evidence be provided by March 12, 2021, but the government has denied this
request. We therefore request that the Court order the government to produce all Rule
404(b) evidence by that date.
CONCLUSION
For the reasons set forth above, we respectfully request that the Court grant the motions
presented in their entirety.
presented in their entirety.
Dated: January 25, 2021
New York, New York
New York, New York
Respectfully submitted,
/s/ Mark S. Cohen
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
17
DOJ-OGR-00002714
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