EFTA00016720Set 8
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trial.'
In any event, Ms. Maxwell should not be required to file her Rule 412 motion any time
before November 15, since it was just three days ago (October ... adequately consult with her about the defense. Allowing Ms. Maxwell to file
her Rule 412 motion 14 days before trial, as the Rule itself provides, is essential for counsel ... Rule.
Accordingly, unless this Court orders otherwise, Ms. Maxwell will file her Rule 412
motion on or before November 15, 2021, as provided in Rule 412(c)(1)(B).
Respectfully
https://www.justice.gov/epstein/files/DataSet%208/EFTA00016720.pdf
EFTA00011157Set 8
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time, not necessarily a "later" time, to require the defense to file a Rule 412
motion. See, e.g., Order, United States v. Andrews, No. 19 Cr. 131 (PAE) (S.D.N.Y ... Additionally, a deadline of 14 days before trial for the defense's Rule 412 motion is not
practical in light of the trial schedule. Under the defense schedule, the defense ... will file their Rule
412 motion on November 15, 2021, and give notice to both the Government and victims. See Fed.
R. Evid. 412(c)(1)(D). At some point
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011157.pdf
EFTA00065522Set 9
2021-10-154p1,265w
time, not necessarily a "later" time, to require the defense to file a Rule 412
motion. See, e.g., Order, United States v. Andrews, No. 19 Cr. 131 (PAE) (S.D.N.Y ... Additionally, a deadline of 14 days before trial for the defense's Rule 412 motion is not
practical in light of the trial schedule. Under the defense schedule, the defense ... will file their Rule
412 motion on November 15, 2021, and give notice to both the Government and victims. See Fed.
R. Evid. 412(c)(1)(D). At some point
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065522.pdf
EFTA00090721Set 9
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government says Ms. Maxwell did.
As detailed today is Ms. Maxwell's Rule 412 motion, the Indictment alleges "grooming"
or "normalization" of sexual behavior by Ms. Maxwell over a dozen ... unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412
motion today, if offers testimony and the government presents argument
22
EFTA00090748
along these lines, that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090721.pdf
EFTA00019057Set 8
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Subject: US v. Maxwell - Government Opposition to Rule 412 Motion
Date: Tue, 02 Nov 2021 03:52:07 +0000
Attachments: Government 412 Opp [final].pdf
Dear
Attached please find ... Government's opposition to the defendant's Rule 412 motion.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York
https://www.justice.gov/epstein/files/DataSet%208/EFTA00019057.pdf