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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 exclude evidence based on Federal Rule of Evidence 702 and the precedent set by Daubert v. Merrell Dow Pharmaceuticals, and requests a hearing on the matter. The document lists the names and contact information for Maxwell's attorneys from three different law firms.
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This document is the signature page (Page 11 of 12) of a legal filing submitted on October 18, 2021, by the defense team for Ghislaine Maxwell. The attorneys argue that the Government failed to comply with Rule 404(b) notice deadlines (originally May 28, extended to October 11), depriving Maxwell of the chance to litigate properly, and they request the Court exclude this belated evidence. The document lists the contact information for defense attorneys from three different law firms.
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This document is the cover page for a legal motion filed on October 29, 2021, in the U.S. District Court for the Southern District of New York for the case of United States v. Ghislaine Maxwell. The motion, submitted by Maxwell's legal team, seeks to prevent the prosecution from introducing statements from alleged co-conspirators. This request is framed as a sanction for the prosecution's purported failure to adhere to a court order issued on September 3, 2021.
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This document is a signature page from a court filing (Document 382) in Case 1:20-cr-00330-PAE, filed on October 29, 2021. It lists the legal counsel representing Ghislaine Maxwell, including Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim, along with their respective law firms and contact information. The document is respectfully submitted on behalf of their client, Ghislaine Maxwell.
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This document is a legal letter dated October 26, 2021, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The defense accepts the Court's draft preliminary remarks for jurors but strongly objects to the government's request to delay providing the names of prospective jurors until the start of oral voir dire on November 16, 2021. Sternheim argues that the Court previously determined names would be provided with questionnaires and requests the Court deny the government's attempt to delay disclosure.
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This document is the cover page for a legal motion filed on October 29, 2021, in the case of United States 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 the introduction of specific government exhibits (251, 288, 294, 313, and 606) in her trial. The document lists the names and contact information for her attorneys from three different law firms.
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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.
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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.
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This is a page from a legal motion filed on October 29, 2021, by Ghislaine Maxwell's defense team (Case 1:20-cr-00330-PAE). The attorneys argue that a redacted individual's identification of Maxwell should be suppressed because the individual never previously identified Maxwell as an abuser in interviews or under oath. The document asserts that the identification procedure was suggestive and occurred too long after the alleged events.
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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.
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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.
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This document is the signature page (page 10 of 11) of a legal filing in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated October 18, 2021, and filed on October 29, 2021. The visible text concludes a legal argument regarding hearsay evidence, asserting that a specific record does not meet the business records exception. It lists the defense legal team representing Maxwell, including attorneys from Haddon, Morgan & Foreman, Cohen & Gresser, and the Law Offices of Bobbi C. Sternheim.
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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.
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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.
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A letter dated October 14, 2021, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan requesting a court order to compel the Metropolitan Detention Center (MDC) to deliver legal mail to Ghislaine Maxwell within 24 hours of receipt. Sternheim details specific incidents of delay, including a hard drive withheld for two days and legal mail deposited on October 2 that was not discovered until October 7. The letter also alleges potential evidence tampering, noting a 'questionable bar code sticker' found on legal mail that the MDC Unit Manager eventually returned to counsel.
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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.
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This legal document, dated January 5, 2022, is a filing in Case 1:20-cr-00330-PAE, addressed to The Honorable Alison J. Nathan. It indicates that Ms. Maxwell (Ghislaine Maxwell) suggests examining deliberating jurors to evaluate their conduct and is in the process of drafting a Rule 33 motion. The document lists several attorneys and their respective law firms representing Ghislaine Maxwell.
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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.
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