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EFTA00014896.pdf
This document is a court order from Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell (20-CR-330), dated November 28, 2021. The order grants the Government's request to file a letter motion under seal to protect the privacy of anticipated witnesses regarding cross-examination limitations. It also orders the Defendant to respond to the motion by 2:00 p.m. on the same day.
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This legal document discusses perjury charges against Maxwell, concluding that they are legally tenable but should be severed and tried separately from Mann Act counts to avoid undue prejudice. It references legal precedents and argues that Maxwell's statements in a civil case about sex trafficking and sexual abuse allegations could have led to the discovery of other evidence or influenced the factfinder, thus supporting the perjury charges.
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This document is a page from the court transcript of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated August 10, 2022. Prosecutors and defense attorneys argue over the admissibility of questions regarding a witness's ('Jane') settlement negotiations, with the defense arguing it proves bias and the prosecution objecting under Rule 408. The Judge intercedes by citing *Manko v. United States*, suggesting that the civil settlement exclusion rule (Rule 408) may not apply in criminal prosecutions.
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This document is a legal filing (page 4 of an internal document, page 11 of the court filing) arguing for the unsealing of grand jury transcripts with specific conditions. The filing argues that while victim identities (such as Ms. Farmer) must be redacted to protect their privacy and psychological wellbeing, the Court should not 'rubber stamp' redactions for third-party affiliates of Epstein and Maxwell who have not been charged, suggesting such broad redactions would resemble a cover-up. It cites multiple legal precedents regarding privacy interests in sexual abuse cases, including *Giuffre v. Maxwell* and *Doe 1 v. JP Morgan Chase Bank*.
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This document appears to be page 22 of a legal filing (likely an opinion or government brief) dated December 2, 2024, related to the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues that there was no prejudicial variance between the evidence presented at trial and the original indictment, citing various legal precedents (Parker, Salmonese, Dove) to support the validity of the conviction under New York law.
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This legal document discusses the application of Rule 33 motions concerning juror responses during voir dire, referencing the McDonough standard. It details the District Court's finding that Juror 50's erroneous responses were not deliberately incorrect and that Maxwell did not challenge other jurors with similar disclosures. The document cites several legal precedents, including United States v. Gambino and McDonough Power Equipment, Inc. v. Greenwood, to support its legal arguments regarding the standard for overturning trial results based on juror honesty.
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This document is page 10 of a legal filing (Case 1:20-cr-00330-PAE) filed on December 2, 2024. It argues that Jeffrey Epstein's Non-Prosecution Agreement (NPA) was limited solely to the Southern District of Florida and does not prevent the USAO-SDNY from prosecuting Ghislaine Maxwell. The text cites the 'Annabi' precedent to support the conclusion that the agreement does not bind other districts.
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This document is page 3 of a legal filing (Case 1:20-cr-00330-PAE) dated December 15, 2021, addressed to Judge Alison J. Nathan. It presents defense arguments supporting the admissibility of testimony from a witness named Mr. Hamilton regarding statements made by 'Kate,' arguing that this evidence proves bias and is not a collateral matter. The text cites various legal precedents to refute the government's objections.
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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.
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This is page 2 of a legal filing (Document 550) from United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 17, 2021. The Government argues regarding the admissibility of extrinsic evidence for impeaching a witness, specifically noting that the prior inconsistent statements come from FBI 302 reports written by agents, not the witness herself. The document cites various legal precedents to argue that if a witness admits to an inconsistency found in '3500 material' (Jencks Act material), no further extrinsic evidence is needed.
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This document is page 2 of a legal filing (Document 545) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 15, 2021. The text argues against a motion by the defendant to compel victims' attorneys to testify, citing Federal Rules of Evidence 402 and 403 and the sanctity of the attorney-client privilege. The argument emphasizes that forcing counsel to testify against their clients, particularly victims of sexual abuse, is legally disfavored and damaging to the attorney-client relationship.
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This legal document is a memorandum of law, likely from the prosecution, arguing for the admission of an exhibit (GX 52) into evidence. It counters a defense objection that the witness, Mr. Alessi, cannot authenticate the exhibit because he has no personal knowledge of its creation. The memorandum cites several legal precedents to support the argument that a document can be authenticated under Rule 901(b)(4) based on its distinctive characteristics or a witness's general familiarity, even without direct observation of its creation.
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This document is page 2 of a court filing (Document 528) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 6, 2021. It is a legal memorandum arguing points regarding attorney-client privilege, specifically focusing on waiver and implied waiver. The text cites various legal precedents (United States v. Krug, In re von Bulow) to establish that privilege belongs to the client and cannot generally be waived by the attorney without consent, unless the client asserts an advice-of-counsel defense.
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This page is from a legal filing (Case 1:20-cr-00330-PAE) dated December 4, 2021. It discusses legal standards for the relevance and admissibility of evidence, citing case law regarding remote evidence and continuity of conduct (specifically regarding sexual interest in minors). The discussion section argues that 'photographs in the 900 series' corroborate statements made by a witness identified as 'Jane.'
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This document is Page 2 of a court filing (likely from United States v. Maxwell based on the case number) dated October 7, 2020, addressed to Judge Alison J. Nathan. The Government updates the court on discovery progress, committing to a November 9, 2020 deadline for electronic discovery and outlining schedules for producing witness statements (Brady/Giglio materials) 4 to 8 weeks before trial. The document also argues the legal scope of the prosecution's obligations, citing case law (Avellino, Quinn) to assert that the prosecution is not responsible for knowledge held by other government agencies (like the FBI) not directly involved in the investigation.
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This legal document is a letter dated August 24, 2020, from Jeffrey S. Pagliuca to Judge Alison J. Nathan. Pagliuca argues on behalf of his client, Ms. Maxwell, for a limited request to present sealed materials to other judicial officers, asserting that the materials are judicial documents and that disclosure would not compromise grand jury secrecy. The letter contends that the government has failed to provide a sufficient reason to prevent this limited disclosure.
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This document is page 25 of a bail application filed on July 10, 2020, for Ghislaine Maxwell. The defense argues that Maxwell is concealing the identities of potential bond co-signers to protect their safety and privacy. The filing cites legal precedents involving high-profile defendants like Bernie Madoff and Marc Dreier to argue that Maxwell should be granted release subject to conditions, including the potential use of private security guards.
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This document is page 4 (labeled 'iii') of a legal filing, specifically a Table of Authorities listing case law citations. It was filed on July 10, 2020, in Case 1:20-cr-00330-AJN (the criminal case against Ghislaine Maxwell). The page lists various legal precedents cited in the brief, including 'United States v. Epstein' (2019) and 'United States v. Kashoggi', referencing rulings from the S.D.N.Y., 2nd Circuit, and other jurisdictions regarding bail or detention issues (inferred from the statute 18 U.S.C. § 3142).
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This document is a Table of Authorities from a legal filing in case 1:20-cr-00330-AJN, filed on July 10, 2020. It lists numerous U.S. court cases that are cited as legal precedent within the main document, providing the case names, citations, and the page numbers where they are referenced. The cases listed involve the United States as a party against various individuals and span from 1978 to 2020.
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This document is a page from a legal filing (Case 1:20-cr-00330-AJN) arguing for the pre-trial detention of a defendant. The prosecution (Government) asserts that the defendant is an extreme flight risk and cannot overcome the statutory presumption for detention, citing the nature of the alleged crimes involving the sexual exploitation of minors. The document references specific U.S. statutes and case law to support its argument that detention is warranted.
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This legal document is a court opinion denying a renewed motion for temporary release by an individual named Maxwell. The Court bases its decision on the 'law of the case' doctrine, stating that Maxwell has not provided any compelling new reasons, such as new evidence or a change in law, to warrant a reversal of its prior decision. The document dismisses Maxwell's arguments regarding a recent letter briefing and a prior order by Judge Nathan, concluding that there was no error in the original determination that Maxwell is a flight risk.
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This legal document, page 14 of a court filing dated May 27, 2021, outlines the legal standards for reviewing a district court's detention order and for considering a defendant's temporary release. It cites U.S. statutes and several legal precedents, including United States v. Watkins and United States v. Scarborough, to establish that the court applies a 'deferential review' and that a defendant bears the burden of proving temporary release is necessary for their defense or for other compelling reasons.
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This document is a page from a legal filing dated April 12, 2021, arguing against Ghislaine Maxwell's request for temporary release. It asserts that Judge Nathan did not abuse discretion in denying release because Maxwell has ample resources, including 'highly qualified' counsel and extensive access to computers (13 hours/day) to review discovery at the MDC. Footnotes clarify legal precedents and note that in-person attorney visitation at the MDC resumed in February 2021.
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This document is page 15 of a legal filing (likely an appellate brief by the government) dated April 12, 2021. It argues that Judge Nathan properly denied Ghislaine Maxwell's motions for bail and temporary release because she is a flight risk. The text outlines the applicable law regarding pretrial detention and the statutory presumption against release for offenses involving minor victims.
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This page is from a court order filed on December 30, 2020, in Case 20-cr-00330-AJN (United States v. Ghislaine Maxwell). The text discusses the legal standards for bail and detention, specifically addressing 'flight risk' and the burden of production. While the court acknowledges the defendant met a limited burden regarding family ties and finances, section B explicitly states that 'The new information does not alter the Court’s initial determination,' implying a denial of the renewed motion for bail based on factors including the nature of the offense (involving a minor victim).
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