EFTA00024954.pdf

"GHISLAINE MAXWELL, Defendant. S2 20 Cr. 330 (AJN)"

"DAMIAN WILLIAMS United States Attorney for the Southern District of New York"

"UNITED STATES OF AMERICA ... DAMIAN WILLIAMS United States Attorney for the Southern District of New York"

"Bennett Gershman, a professor of law at Pace University"

"an FBI computer forensic examiner who will testify as a fact witness"

"Another, Bennett Gershman, is a purported expert on prosecutorial misconduct. Neither of these issues is relevant at trial. and both experts should be"

"The Government moves to redact portions of this brief and seal Exhibit B, which is Dr. Hall's evaluation of Minor Victim-4"

"the defendant's involvement in Epstein's scheme"

"Minor Victim-4 described to Dr. Hall certain aspects of Epstein's abuse that did not involve the defendant"

"Minor Victim-4's expected testimony about the defendant's involvement in Epstein's scheme"

"Minor Victim-4 also failed to mention the full extent of the defendant's role during her first FBI interview."

"after Minor Victim-4 testifies the defendant will be able to argue"

"The defense proposes to call Bennett Gershman... to provide testimony on best practices to ensure the integrity of any prosecution"

"The defense provided brief notice of four additional experts: Robert Kelso, who would testify about computer forensics"

"DAMIAN WILLIAMS United States Attorney for the Southern District of New York"

"The Government respectfully requests that the Court preclude the testimony of Dr. Ryan Hall and Bennett Gershman"

"the defendant has identified two forensic document specialists who she may call as expert witnesses"

"the notice for Kelso states that he will testify generally about computer forensic principles associated with the creation of documents"

"REDACTED-001 will discuss various transfers of funds that are reflected in the financial records and explain the information contained in the financia"

"the defendant has identified two forensic document specialists who she may call as expert witnesses. Gerald LaPorte is a Forensic Chemist"

"Jennifer Naso is a Forensic Document Examiner"

"journal pages by witness Minor Victim-2"

"journal pages by witness Minor Victim-2"

"preclude the testimony of Dr. Ryan Hall and Bennett Gershman"

"preclude the testimony of Dr. Ryan Hall and Bennett Gershman"

"Dated: November 15, 2021 New York, New York"

"none bears on the facts of this case or Minor Victim-4's credibility."

"Minor Victim-4 has not always disclosed the defendant's role in Epstein's abuse."

"the defendant anticipates == a financial investigator, to testify about: his review of certain financial records"

"an FBI computer forensic examiner who will testify as a fact witness about his extraction of devices seized pursuant to court authorized search warran"

"four other cases in this District and the Eastern District in which REDACTED-001 testified, including United States v. Kelly"

"Jennifer L. Mnookin, Scripting Expertise: The History of Handwriting Identification Evidence and the Judicial Construction of Reliability, 87 Va. L. R"