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person
Juror 50
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Cynthia Hopkins
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This is the final page of a legal filing from the U.S. Attorney's office for the Southern District of New York, dated December 19, 2021. The letter, submitted by U.S. Attorney Damian Williams and his assistants, informs the Court of the submission of exhibits GX 603-A and GX 604-A under a temporary seal. It also states that copies of other referenced exhibits will be provided the following morning.
This document is page 3 of a court filing, so-ordered by a judge on December 19, 2021. In it, the Government outlines agreements with the defense regarding redactions for trial exhibits and requests the court's permission to submit certain exhibits into evidence and release others to the public before the jury begins deliberations. The filing details specific exhibit numbers and the rationale for their handling, such as protecting the privacy of third parties.
This legal document is a filing from the U.S. Attorney for the Southern District of New York, arguing against a defense position regarding witness availability. The prosecution cites the precedent of *United States v. Jones*, where a judge rejected a similar defense attempt to compel the government to immunize a witness. The filing concludes that since the defense had the opportunity to call numerous witnesses, including Virginia Roberts, there is no reason to deviate from the standard jury instruction on the equal availability of witnesses.
This legal document is a filing by the Government in case 1:20-cr-00330-PAE, arguing against two jury instructions proposed by the defense. The Government opposes a specific instruction on witness convictions, fearing it would overemphasize them, and argues against modifying the standard instruction for uncalled witnesses. It cites case law to assert that a witness invoking the Fifth Amendment is 'equally unavailable' to both the prosecution and the defense.
This legal document, filed on December 17, 2021, is a page from a court proceeding in the case against Ms. Maxwell. The judge is providing guidance on the admissibility of evidence, citing the 2013 case 'United States v. Borrero' as precedent. The court will permit the defense to cross-examine government witnesses about their prior statements that did not implicate Ms. Maxwell in order to impeach their credibility.
This document is a page from a legal transcript or filing, dated December 17, 2021, arguing against the admissibility of a prior 2008 decision not to indict Ms. Maxwell. The speaker contends that the reasons for the 2008 decision by officials in the Southern District of Florida are not relevant to the current case, would be prejudicial, and could cause juror confusion. This is contrasted with the 'White' case, where a prior charging decision was deemed admissible because it directly related to a witness's credibility.
This legal document is a page from a court filing, specifically page 5 of 6 from Document 548 in case 1:20-cr-00330-PAE, filed on December 15, 2021. The Court denies the Defense's request for a witness to testify under a pseudonym, arguing that the witness does not qualify as a victim under the Crime Victims' Rights Act because her anticipated testimony is that she was not a target of sexual misconduct by Epstein or Ms. Maxwell. The Court distinguishes this situation from a prior ruling where pseudonyms were allowed to protect the identities of other, actual victims.
This legal document, page 4 of a court filing dated December 15, 2021, details the Court's rejection of the Defense's request to allow a witness to testify under a pseudonym. The Court finds the request untimely, notes that other legal tools like a letter rogatory were available to compel testimony, and distinguishes the case from precedents involving undercover officers whose safety or operational effectiveness would be compromised by revealing their identity.
This legal document, filed on December 15, 2021, is a court filing arguing against the Defense's request for witness anonymity for Ms. Maxwell's trial. The filing contends that the Defense's concerns about publicity are common in high-profile cases and do not meet the standard for granting pseudonyms, unlike the alleged victims who have a statutory right to privacy. It heavily cites the precedent of *United States v. Rainiere*, where a similar request for anonymity for supporters was denied because the public's interest in access prevailed over privacy concerns for matters not traditionally considered private.
This legal document presents an argument to the Court to preclude the testimony of Jack Scarola, Brad Edwards, and Robert Glassman. The core argument is that Glassman's settlement negotiations with an entity called EVCP cannot be used to impeach a witness named Jane, because she testified she was unaware of these negotiations. Allowing this testimony would be improper impeachment and more prejudicial than probative.
This legal document, dated December 13, 2021, is a filing on behalf of Ms. Maxwell addressed to Judge Alison J. Nathan. The defense argues that the Court should permit the testimony of three witnesses—Mr. Scarola, Mr. Edwards, and Mr. Glassman—to establish motive and bias of Maxwell's accusers, after the government refused to stipulate. The document details the proposed testimony of attorney Jack Scarola, including his prior representation of an accuser named 'Carolyn' in a civil suit against Jeffrey Epstein and his communications with the government.
This legal document is a filing arguing against the government's attempt to admit 'Exhibit 52' as evidence in a trial involving Ms. Maxwell. The author contends that the government has failed to authenticate the exhibit, has abandoned its original premise that it was Ms. Maxwell's book, and that admitting it at this late stage would be unfair. The argument is bolstered by the government's decision not to call a key witness, 'Employee-1', who was supposed to link the exhibit to Ms. Maxwell.
This legal document is a filing on behalf of Ms. Maxwell arguing against the government's attempt to use her April 2016 deposition testimony. The core argument is that "Deposition Exhibit 13" is an unauthenticated photocopy and is fundamentally different from "Exhibit 52." This claim is supported by testimony from Mr. Alessi, who noted a significant physical discrepancy between Exhibit 52 and books he saw while employed by Mr. Epstein.
This document is a court transcript from case 1:20-cr-00330-PAE, filed on December 8, 2021. In it, a speaker, presumably the judge, details the procedure for voir dire, explaining how a list of witnesses and entities will be presented to prospective jurors. The judge outlines special measures for witnesses testifying under pseudonyms, including discussing them at sidebar and preventing a specific employer's name from being mentioned in open court to protect a witness's identity.
This document, a court transcript filed on December 8, 2021, details a discussion about jury selection in Case 1:20-cr-00330-PAE. The speaker, a court official, outlines the process of reviewing prospective juror lists, noting the government's and defense's differing views on excusing jurors. The document also mentions a communication from the defense requesting to modify its previous juror strikes.
This legal document, filed on December 5, 2021, is a request from the U.S. Government to the Court in case 1:20-cr-00330-PAE. The Government proposes a specific limiting instruction for the jury to be read before a witness, identified as "Witness-3," testifies. The instruction aims to prevent prejudice by clarifying that any testimony about sexual conduct between Witness-3 and Mr. Epstein is not part of the charged crimes and cannot be used to judge the character or propensity of either Mr. Epstein or Ms. Maxwell.
This legal document, part of Case 1:20-cr-00330-PAE, discusses the testimony of a witness named Jane regarding a massage room where she was allegedly sexually abused. The Government argues that photographs presented as exhibits corroborate Jane's detailed descriptions of the room's size, features, and the house's artwork, thereby establishing their relevance to the case. The document acknowledges the Court's concern about the lack of testimony directly comparing the photos to the room's state during the conspiracy but asserts that most of Jane's testimony concerns non-movable features.
This legal document, dated November 25, 2020, is a letter to Judge Alison J. Nathan arguing for the sealing of information related to Ms. Maxwell's bail application. The author contends that the privacy of Ms. Maxwell's sureties (co-signers) and other third parties outweighs the public's right to access, citing fears of harassment and legal precedent from cases like U.S. v. Amodeo and U.S. v. Nejad. The filing requests an in-camera conference to discuss the redaction of the sureties' names and other confidential materials.
This court order, dated December 2, 2020, addresses the individualized detention conditions of Ms. Maxwell, noting concerns about the lack of redress for serious conditions. It directs Warden Tellez to provide a first-hand accounting to the Court and counsel regarding these conditions. Additionally, MDC legal counsel is ordered to submit a letter to the Court by December 4, 2020, for review to determine if further information is needed.
This document is page 3 of a court filing (Case 1:20-cr-00330-AJN) filed on November 6, 2020, likely in the prosecution of Ghislaine Maxwell. The Government argues regarding discovery deadlines, agreeing to a laptop for the defendant to review evidence at the MDC but refusing early disclosure of witness lists (Giglio/Jencks material) seven months before trial. The text details upcoming discovery productions, specifically mentioning thousands of images/videos from Epstein's electronic devices, portions of seized iPads and an iPhone, and documents from the FBI's Florida files.
This is page 2 of a court order dated November 5, 2020, in case 1:20-cr-00330-AJN, signed by United States District Judge Alison J. Nathan. The order outlines the procedure for the Government to request modification of its disclosure obligations if there are concerns about witness safety, national security, or other interests. It also lists six potential sanctions the Court may impose if the Government fails to comply with the disclosure order, ranging from specifying production terms to dismissing charges.
This document is page 6 of a legal filing dated October 23, 2020, addressed to Judge Alison J. Nathan from Ghislaine Maxwell's defense team. The text details significant ongoing technical failures at the Metropolitan Detention Center (MDC) regarding Maxwell's ability to access discovery materials on provided hard drives. Despite multiple letters and conference calls between August and October 2020, the Government and MDC IT staff failed to provide a functional computer or readable files, severely impairing Maxwell's ability to prepare her defense.
This legal document is a letter dated October 14, 2020, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell argues against the government's request to delay the disclosure of evidence to his client, Ms. Maxwell, in case 1:20-cr-00330-AJN. He asserts the government has not provided sufficient legal justification, such as risks to an ongoing investigation or witness safety, and asks the court to order the immediate production of the materials to the defense.
This document is the final page of a letter motion dated August 17, 2020, from Jeffrey S. Pagliuca to Judge Alison J. Nathan. The motion, filed on September 2, 2020, formally requests on behalf of Ms. Maxwell that the court modify an existing Protective Order. The modification would permit Ms. Maxwell to refer to and file specific, redacted material under seal.
This legal document is page 5 of a filing on behalf of Ms. Maxwell to Judge Alison J. Nathan, dated August 17, 2020. The filing argues that the government has violated the spirit of a Protective Order by its handling of discovery materials, particularly in relation to their potential use in civil litigation and a grand jury investigation. The defense cites previous assurances from the government and a letter from Alex Rossmiller, which the Court relied upon, to argue that a new request should be granted by the Court.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2009-09-17 | Received | Burman, Critton, ... | Court | $138.80 | Invoice for cancelled deposition services (Appe... | View |
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