Epstein Files Search

EFTA00097312Set 9

17p4,078w

Some Overlapping Proof, By Itself, Does Not Make Joinder Proper 5 II. The Perjury Counts Must Be Severed to Prevent the Introduction of Improper, Highly Prejudicial, and Inadmissible Evidence ... EFTA00097315 Counts 5 and 6, "the Perjury Counts," are improperly joined with Counts 1-4, the "Mann Act Counts." For the reasons stated in Ms. Maxwell's original Motion ... this Reply, the Court should sever the Perjury Counts and grant a separate trial on these charges. ARGUMENT I. The Counts Are Improperly Joined. Rule 8(a) of the Federal

https://www.justice.gov/epstein/files/DataSet%209/EFTA00097312.pdf

EFTA00091875Set 9

2008-01-1619p4,850w

through Four (the "Mann Act Counts") 2 B. Counts Five and Six (the "Perjury Counts") 2 APPLICABLE LAW 3 A. Joinder of Offenses 3 B. Severance of Offenses 5 ANALYSIS ... Perjury Counts Are Improperly Joined Under Rule 8(a) and Must Be Severed 6 B. The Perjury Counts Should Be Severed Under Rule 14(a) Because Their Inclusion Will Substantially ... between 1994 and 1997. Id. 9191 13. 19. B. Counts Five and Six (the "Perjury Counts") ' The indictment refers to the accusers as Minor Victim-1, Minor Victim

https://www.justice.gov/epstein/files/DataSet%209/EFTA00091875.pdf

EFTA00103238Set 9

2021-07-1234p11,087w

Court concludes that the charges are specific enough. • Maxwell moves to dismiss the perjury counts because, in her view, her testimony responded to ambiguous questioning and was not material ... that these issues are best left for the jury. • Maxwell moves to sever the perjury counts from the Mann Act counts so that they can proceed in a separate trial ... Court concludes that severance is appropriate and will try the perjury counts separately. • Maxwell moves to strike language from the indictment that she believes is superfluous and to dismiss conspiracy

https://www.justice.gov/epstein/files/DataSet%209/EFTA00103238.pdf

EFTA00085225Set 9

2021-07-1234p11,087w

Court concludes that the charges are specific enough. • Maxwell moves to dismiss the perjury counts because, in her view, her testimony responded to ambiguous questioning and was not material ... that these issues are best left for the jury. • Maxwell moves to sever the perjury counts from the Mann Act counts so that they can proceed in a separate trial ... Court concludes that severance is appropriate and will try the perjury counts separately. • Maxwell moves to strike language from the indictment that she believes is superfluous and to dismiss conspiracy

https://www.justice.gov/epstein/files/DataSet%209/EFTA00085225.pdf

EFTA00103343Set 9

2021-07-1234p11,087w

Court concludes that the charges are specific enough. • Maxwell moves to dismiss the perjury counts because, in her view, her testimony responded to ambiguous questioning and was not material ... that these issues are best left for the jury. • Maxwell moves to sever the perjury counts from the Mann Act counts so that they can proceed in a separate trial ... Court concludes that severance is appropriate and will try the perjury counts separately. • Maxwell moves to strike language from the indictment that she believes is superfluous and to dismiss conspiracy

https://www.justice.gov/epstein/files/DataSet%209/EFTA00103343.pdf

EFTA00105927Set 9

2021-04-225p1,339w

resolution of those motions and that request until after the trial on the non- perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial process ... motions to suppress or hold an evidentiary hearing before the trial on the non-perjury counts because it "does not intend to use these materials"—i.e., any of the materials ... suppression motions—"in its case-in-chief at the trial of the non-perjury counts in this case." (Dkt. No. 227, p I). At the same time, the government purports

https://www.justice.gov/epstein/files/DataSet%209/EFTA00105927.pdf

EFTA00155888Set 9

2022-06-282p262w

parties' joint letter regarding a schedule for sentencing and resolution of the severed perjury counts. Dkt. No. 574. The Court hereby schedules the sentencing in this matter for June ... adopts the parties proposal that the scheduling of any proceedings related to the severed perjury counts be deferred until the post-verdict motions are resolved. By January ... seeking an exclusion of time under the Speedy Trial Act for the perjury counts and the basis for any requested exclusion. In the joint letter, the defense shall indicate EFTA00155888

https://www.justice.gov/epstein/files/DataSet%209/EFTA00155888.pdf

EFTA00094804Set 9

2020-07-299p4,346w

below. 4. The deposition transcripts obtained by the government and the indictment's perjury counts place in a new light plaintiff's earlier litigation conduct—suggesting the planned ... someone to leak the transcripts to the government, which then charged Ms. Maxwell with perjury counts, suggest plaintiff in conjunction with the government sought to circumvent Martindell: they

https://www.justice.gov/epstein/files/DataSet%209/EFTA00094804.pdf

EFTA00090550Set 9

2020-06-121p238w

there is a legally permissi le way to further anonymize the reference toliallin that perjury count, or (b) if not, we will be permitted to cut that specification from

https://www.justice.gov/epstein/files/DataSet%209/EFTA00090550.pdf

EFTA00097378Set 9

2016-04-0716p3,785w

EFTA00097387 The government complains that Ms. Maxwell has not cited any cases where a perjury count was dismissed pretrial for "fundamental ambiguity." Resp. 120. Of course, the government must know

https://www.justice.gov/epstein/files/DataSet%209/EFTA00097378.pdf

EFTA00094121Set 9

2021-07-123p951w

motions in response to the new charges contained in the S2 Indictment. Although the perjury counts were recently severed, the Court cannot conclude that this sufficiently offsets the additional burdens

https://www.justice.gov/epstein/files/DataSet%209/EFTA00094121.pdf

EFTA00026594Set 8

2021-02-211p66w

review is a draft of the opposition to Maxwell's motion to sever the perjury counts, along with a copy of that motion. Thanks, Assistant United States Attorney Southern District

https://www.justice.gov/epstein/files/DataSet%208/EFTA00026594.pdf

EFTA00032666Set 8

2021-04-161p128w

Maxwell's pretrial motions is attached. She granted Maxwell's motion to sever the perjury counts but denied the remaining motions, except for the suppression motions with respect

https://www.justice.gov/epstein/files/DataSet%208/EFTA00032666.pdf

EFTA00094124Set 9

2021-07-123p951w

motions in response to the new charges contained in the S2 Indictment. Although the perjury counts were recently severed, the Court cannot conclude that this sufficiently offsets the additional burdens

https://www.justice.gov/epstein/files/DataSet%209/EFTA00094124.pdf

EFTA00022090Set 8

2021-04-261p86w

Maxwell's pretrial motions is attached. She granted Maxwell's motion to sever the perjury counts but denied the remaining motions, except for the suppression motions with respect

https://www.justice.gov/epstein/files/DataSet%208/EFTA00022090.pdf

EFTA00103812Set 9

2021-07-123p951w

motions in response to the new charges contained in the S2 Indictment. Although the perjury counts were recently severed, the Court cannot conclude that this sufficiently offsets the additional burdens

https://www.justice.gov/epstein/files/DataSet%209/EFTA00103812.pdf

EFTA00151753Set 9

2019-10-081p214w

name. For your reference the initial indictment of GM is attached, which included the perjury counts. Let me know if I missed something you requested or if you want clarification

https://www.justice.gov/epstein/files/DataSet%209/EFTA00151753.pdf