This document is a Certificate of Service from the legal case 1:20-cr-00330-PAE, filed on October 29, 2021. It certifies that on October 18, 2021, Nicole Simmons electronically filed a motion on behalf of Ghislaine Maxwell to prevent accusers from being referred to as "Victims" or "Minor Victims". The certificate confirms that counsel from the U.S. Attorney's Office for the Southern District of New York were notified of this filing.
This document is the conclusion of a legal filing submitted on October 18, 2021, by the attorneys for Ghislaine Maxwell. The attorneys request that the court issue an order preventing all trial participants from referring to the accusers as "victims" or "minor victims." They argue that using such terms would violate Ms. Maxwell's presumption of innocence and lessen the government's burden of proof.
This document is a Certificate of Service from a legal case, signed by Nicole Simmons. It certifies that on October 18, 2021, a motion on behalf of Ghislaine Maxwell to preclude testimony about alleged rape by Jeffrey Epstein was electronically filed with the court. The certificate lists four individuals at the U.S. Attorney's Office for the Southern District of New York who were served with notification of this filing.
This document is the cover page for a legal motion filed on October 29, 2021, in the case of United States of America v. Ghislaine Maxwell in the U.S. District Court for the Southern District of New York. The motion, submitted by Maxwell's legal team, seeks to preclude law enforcement witnesses from offering expert opinion testimony. The document lists the names and contact information for the four attorneys and their respective law firms representing the defendant, Ghislaine Maxwell.
This document is the cover page for a legal motion filed on October 29, 2021, in the case of United States of America v. Ghislaine Maxwell in the U.S. District Court for the Southern District of New York. The filing, titled 'GHISLAINE MAXWELL’S MOTION TO SUPPRESS IDENTIFICATION', lists the defendant's legal counsel from three different law firms. It serves as the formal introduction to a request for the court to exclude certain identification evidence from the trial.
This document is the signature page from a legal filing in case 1:20-cr-00330-PAE, dated October 29, 2021. It lists the attorneys representing Ghislaine Maxwell: Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim. The document also provides the names and addresses of their respective law firms in Denver and New York.
This document is the cover page for a 'Motion in Limine' filed on October 29, 2021, in the case of United States v. Ghislaine Maxwell (Case 20 Cr. 330). The motion seeks to exclude evidence allegedly seized during a search of 358 El Brillo Way (Jeffrey Epstein's Palm Beach residence) that occurred on October 20, 2005. It lists the legal defense team representing Maxwell, including attorneys from Haddon, Morgan & Foreman P.C., Cohen & Gresser LLP, and the Law Offices of Bobbi C. Sternheim.
This document is the cover page for a legal memorandum filed on February 23, 2021, in the Southern District of New York. It supports Ghislaine Maxwell's third motion for release on bail in case 20 Cr. 330 (AJN). The document lists the defense legal team, including attorneys from three different law firms based in New York and Colorado.
This document is the cover page of a legal memorandum filed on February 4, 2021, in the Southern District of New York (Case 1:20-cr-00330-AJN). It is a filing by Ghislaine Maxwell's defense team supporting a motion for a Bill of Particulars and Pretrial Disclosures. The document lists the defense attorneys representing Maxwell, including Mark S. Cohen, Christian R. Everdell, Jeffrey S. Pagliuca, Laura A. Menninger, and Bobbi C. Sternheim.
This is an email dated August 12, 2019, from Associate Warden Charisma Edge of MCC New York to Ray Ormond. The email provides a chronological log entry for inmate Jeffrey Epstein (Reg. No. 73618-054), stating that an inmate companion took over observation duties from staff on July 23, 2019. It further notes that Epstein was transferred to psychological observation with an inmate companion from July 24 to July 30, 2019.
This document is a letter dated October 18, 2021, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Sternheim argues for the necessity of individual, sequestered, and counsel-conducted voir dire (jury selection), citing the extraordinary public exposure of the case, evidenced by millions of Google search results for Maxwell and Jeffrey Epstein. The letter contends that this special procedure is required to eliminate biased jurors and ensure a fair trial, countering the government's standard opposition to such methods.
This is a letter from Ghislaine Maxwell's attorney, Bobbi C. Sternheim, to Judge Alison J. Nathan, dated October 15, 2021. Sternheim complains that the government's explanation for the severely delayed delivery of Maxwell's legal mail at the Metropolitan Detention Center (MDC) is inadequate and hinders Maxwell's ability to prepare for trial. The letter argues that the MDC is capable of timely delivery, citing the extensive resources used to monitor Maxwell, and criticizes the government's refusal to facilitate special delivery for evidence.
This document is the cover page of a legal filing, specifically a Memorandum of Law, submitted to the U.S. District Court for the Southern District of New York on October 13, 2021. It is filed by the legal team for defendant Ghislaine Maxwell in the case of United States of America v. Ghislaine Maxwell. The motion seeks an individual and sequestered jury selection process (voir dire) to be partially conducted by the defense counsel.
This is a Notice of Motion filed on October 13, 2021, in the U.S. District Court for the Southern District of New York for the case of United States v. Ghislaine Maxwell. The defense attorneys for Maxwell are formally notifying the court and prosecution of their intent to request a specific jury selection process, namely 'individual sequestered juror voir dire and limited counsel-conducted voir dire'. The motion is to be brought before Judge Alison J. Nathan.
This document is an envelope from inmate David A. Dieki, incarcerated at USP Coleman II in Florida, addressed to the Clerk of Court for the Southern District of New York. The envelope is marked 'Legal Mail' and 'pro se', signifying a legal filing from an individual representing himself. Court stamps indicate it was received on September 22, 2021, and is associated with case 1:20-cr-00330-PAE.
This legal letter, dated January 25, 2022, from Nathan Siegel of Davis Wright Tremaine LLP, on behalf of ABC News and NBCUniversal News Group, is addressed to Judge Alison J. Nathan of the U.S. District Court, Southern District of New York. It requests to join other news organizations in opposing the sealing of the Defendant's motion for a new trial and supporting exhibits, and specifically asks for Juror 50's motion to be unsealed, citing its relevance as a "judicial document" to the judicial process.
This is a legal letter dated January 19, 2022, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter serves to inform the court that Maxwell's counsel has filed a Motion for a New Trial and requests that all materials concerning Juror No. 50 be kept under seal until the court rules on the motion.
This document is an 'Appearance of Counsel' filed in the Southern District of New York on January 5, 2022, in the case of USA v. Ghislaine Maxwell. Attorney Todd A. Spodek of Spodek Law Group, P.C. formally notifies the court that he is representing 'Jury Number 50,' rather than the defendant or prosecution. This filing occurred post-trial.
This document is a letter dated January 5, 2022, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Pagliuca argues against the government's request for a hearing concerning a juror who revealed post-trial that they were a victim of sexual assault. He contends the request is premature and that, based on publicly available information and legal precedent, the court should order a new trial without an evidentiary hearing.
This document is a page from a legal filing in Case 1:20-cr-00330-AJN, filed on February 4, 2021. It identifies Laura A. Menninger and Bobbi C. Sternheim as the attorneys representing Ghislaine Maxwell. The document provides the names, law firms, addresses, and phone numbers for both attorneys.
This document is page 29 of 35 from a court filing (Case 1:20-cr-00330-PAE, U.S. v. Ghislaine Maxwell), filed on 10/29/21. It appears to be the end matter (Funding, Notes, References) of an academic paper or expert witness report by 'Dietz' regarding child sexual abuse and the terminology of 'grooming.' The page lists numerous psychological and psychiatric references ranging from 1907 to 2018.
This document is the cover page for a Motion in Limine filed on October 29, 2021, in the case of USA v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The motion, submitted by Maxwell's defense team, seeks to preclude the prosecution from referring to accusers as 'victims' or 'minor victims' during the trial. It lists the defense attorneys representing Maxwell from three different law firms.
This document is the signature page of a legal filing (Document 394) from the court case 1:20-cr-00330-PAE, filed on October 29, 2021. It lists the names and contact information for the attorneys representing Ghislaine Maxwell from three law firms: Haddon, Morgan & Foreman, P.C.; Cohen & Gresser LLP; and the Law Offices of Bobbi C. Sternheim. The document is electronically signed by attorney Jeffrey S. Pagliuca.
This document is an email chain from August 2016 originating from Michael Keough at Steptoe & Johnson LLP. The email circulates media articles (USA Today, Al Arabiya) regarding the extradition of Fethullah Gulen and comments made by attorney Reid Weingarten defending Gulen against accusations from Turkish President Erdogan. While Reid Weingarten famously represented Jeffrey Epstein, this specific document pertains to his representation of Gulen regarding the Turkish coup attempt.
This document is an email chain from August 5, 2016, involving attorneys from Steptoe & Johnson LLP and other individuals monitoring news coverage of Fethullah Gulen following the failed Turkish coup attempt. The emails circulate articles from the BBC, USA Today, and Al Arabiya regarding Turkey's extradition requests and fears for Gulen's safety. The document appears to be part of a House Oversight Committee production (likely related to foreign lobbying or the Flynn investigation), and while the user prompt mentions 'Epstein-related,' the content strictly concerns Turkish political affairs and Fethullah Gulen.
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