This legal document argues that the 'Annabi' court decision is an outlier and inconsistent with the Circuit's established law regarding the interpretation of plea agreements. The author contends that contrary to the District Court's opinion, the Circuit has been reluctant to rely on Annabi's reasoning, which construes ambiguities against the defendant, and has instead consistently held that such ambiguities should be resolved against the Government.
This document is a page from a legal filing that discusses the legal precedent set in the Annabi case concerning the scope of plea agreements. It explains the "Annabi rule," which holds that a plea agreement only binds the U.S. Attorney's office in the district where it was made, unless explicitly stated otherwise. The document also highlights that this rule has been sharply criticized by other courts, such as in U.S. v. Gebbie, for lacking a sound analytical basis.
This document is a 'Statement of the Issues Presented for Review' from an appellate brief (Case 22-1426, dated Feb 28, 2023). It outlines four main legal arguments for appeal: the misapplication of a non-prosecution agreement, errors regarding statutes of limitations, juror misconduct involving concealed history of sexual abuse, and a constructive amendment of the indictment regarding venue (New Mexico vs. New York) and state law.
This document is page 12 of 113 from a legal filing (Case 22-1426, Document 59), dated February 28, 2023. It contains a 'Table of Authorities' listing various legal precedents (U.S. v. [Defendant]) cited in the main brief, along with their corresponding page numbers. The document bears a Department of Justice Bates stamp (DOJ-OGR-00021059).
This document is page 11 of a legal filing from Case 22-1426, dated February 28, 2023. It is a table of authorities listing numerous U.S. court cases, dating from 1926 to 2022, which are cited within the main document. Each citation includes the case name, legal reporter information, and the page numbers where the case is referenced.
A page from a court transcript (Case 22-1426, related to the Ghislaine Maxwell appeal) documenting a judge's ruling during sentencing. The judge finds the defendant engaged in a pattern of prohibited sexual conduct with a minor on at least two occasions. The judge overrules a defense objection that argued the sentencing enhancement should only apply if the defendant posed a continuing danger to the public, citing that the text of the Guidelines is unambiguous.
This document is a page from a legal filing (Document 657 in Case 1:20-cr-00330-AJN) addressing the Defendant's (Ghislaine Maxwell) claim that delay in prosecution caused prejudice to her defense. The text argues the defendant failed to prove substantial prejudice but outlines her specific claims regarding lost evidence, including flight records, financial documents, phone records, and property records. It specifically names deceased witnesses the defense claims were unavailable: architects Albert Pinto and Roger Salhi, and property manager Sally Markham.
This document is a page from a legal filing (likely a Government brief or Court Opinion) in the case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It discusses the Court's rejection of the Defendant's requests regarding jury instructions, specifically concerning 'travel to New York' and the age of consent laws in New Mexico, the UK, and Florida. The text argues that the Court's instructions were legally sound and that the Defendant's proposals would have confused the jury.
This page from a legal filing (Case 1:20-cr-00330-AJN, likely the Ghislaine Maxwell trial) discusses a dispute over a jury note regarding 'Count Four.' The argument centers on whether the jury could convict based solely on conduct in New Mexico versus the required New York law violation. The text details a debate over the placement of a comma in the jury's note and the Court's subsequent instruction to the jury to focus on New York law.
This document is page 24 of a court ruling (filed April 29, 2022) in the case against Ghislaine Maxwell (referred to as the Defendant). It addresses a defense motion regarding a 'constructive amendment,' specifically discussing whether the jury improperly convicted the Defendant based on intent for sexual activity in New Mexico (involving a victim named 'Jane') rather than New York, as charged in the indictment involving a scheme with Jeffrey Epstein.
This document is a page from a legal filing (likely an appeal brief) arguing that certain counts against the Defendant are 'multiplicitous' (charging the same offense multiple times). It cites legal precedents regarding conspiracy charges and argues that because the participants (specifically the Defendant and Epstein) and the objectives (acquiring underage girls for Epstein to abuse) overlapped substantially, the counts should be considered the same conspiracy. It explicitly describes the Defendant's role as procuring girls for Epstein.
This legal document is a court's analysis regarding a challenge to the credibility of a juror, identified as Juror 50. The defendant, Maxwell, argued the juror's testimony was "self-serving" and "rehearsed," and that his explanation for an incorrect answer on a questionnaire was not plausible. The Court rejects these arguments, finding the juror's preparation for testimony to be reasonable and his explanation for the questionnaire error credible, ultimately expressing satisfaction with his answers.
This document is page 14 of a court order (Document 653) filed on April 1, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The text analyzes legal standards for investigating juror misconduct, specifically whether a juror lied during voir dire and the limitations imposed by Federal Rule of Evidence 606 regarding inquiring into jury deliberations. It cites various precedents (McCoy, Nix, Tanner) to establish the boundaries of a 'McDonough inquiry' into juror bias.
This document is a page from a court order in the case of United States v. Ghislaine Maxwell (part of appeal record Case 22-1426). The Judge denies Maxwell's motion to compel the immediate disclosure of prior statements by 'Minor Victim-4' in which the victim allegedly did not mention Maxwell. The Court rules that the Government's deadline of October 11, 2021, for Jencks Act and Giglio material is sufficient and that the Government understands its Brady obligations regarding exculpatory evidence.
This document is page 31 of a court order filed on April 16, 2021, in the case against Ghislaine Maxwell. The court discusses the timeline for the Government to produce a witness list, noting that while Maxwell faces challenges due to the 'decades-old allegations,' the Government's proposal to provide information six weeks in advance is reasonable. The text also notes that on April 13, 2021, the Government produced over 20,000 pages of discovery materials related to non-testifying witnesses.
This page is from a court order in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court addresses discovery disputes, specifically ruling that the Government's agreement to produce 'Giglio' and 'Jencks Act' materials six weeks prior to trial is sufficient for Maxwell to prepare, noting the Court lacks authority to force earlier disclosure of Jencks material. The Court also denies Maxwell's request for a pretrial hearing regarding the admissibility of co-conspirator statements, opting instead for conditional admission at trial.
This document is page 28 of a court order filed on April 16, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The court denies Maxwell's motion to dismiss multiplicitous counts without prejudice and addresses discovery disputes, specifically accepting the Government's representation that it has already disclosed all required Brady and Giglio material. The court orders the parties to negotiate a schedule for any remaining pretrial disclosures.
This document is page 22 of a court ruling (Document 207) filed on April 16, 2021, in the case United States v. Maxwell. The court is denying Maxwell's motion to dismiss perjury counts, arguing that the ambiguity of questions and the materiality of her statements are issues of fact for a jury to decide, not grounds for pretrial dismissal. The text cites legal precedents regarding perjury, materiality in civil depositions, and the role of the jury.
This page is from a court order (Case 1:20-cr-00330-AJN) dated April 16, 2021, addressing Ghislaine Maxwell's motion to dismiss perjury charges. The Court denied the motion, stating that the charges are legally tenable and that arguments regarding the ambiguity of questions asked during her civil deposition are matters for a jury to decide. The document cites several legal precedents (Lighte, Wolfson) regarding perjury and 'knowing falsity'.
This legal document is a page from a court filing in the case against Maxwell, dated April 16, 2021. The court addresses and rejects several of Maxwell's arguments that the indictment is impermissibly vague, specifically concerning the lack of precise dates for the alleged abuse, the inclusion of noncriminal conduct, and the omission of victims' names. The court cites legal precedents to affirm that the indictment is sufficient, particularly in cases involving the sexual abuse of children where victims may struggle to recall exact dates.
This document is a court docket log from June 24-26, 2022, relating to the sentencing of Ghislaine Maxwell (Case 22-1426). It details Judge Alison J. Nathan's orders permitting victims Annie Farmer, Kate, and Virginia Giuffre to make in-person statements at sentencing. The docket also records communications regarding Maxwell's access to legal materials at the MDC, defense motions regarding victim impact statements from Sarah Ransome and Elizabeth Stein, and the denial of Maxwell's request to redact victim statements.
This document is a page from a court docket covering filings and orders from November 24, 2021, to November 30, 2021, in the case against Ghislaine Maxwell. It includes motions regarding expert testimony and jury instructions, orders concerning the production of materials from the Epstein Victims Compensation Program, and a minute entry noting the beginning of jury selection and the trial.
This document is a court docket from the case of USA v. Ghislaine Maxwell, detailing filings and orders from October 20-22, 2021. It records efforts by media organizations, including the Reporters Committee for Freedom of the Press, to oppose the sealing of jury selection materials, ensuring public access. The central entry is a detailed order by Judge Alison J. Nathan denying the request to seal the materials and outlining the specific procedures and a comprehensive schedule for the upcoming jury selection process, including questionnaires, voir dire, and deadlines for counsel.
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It details a discussion between Ms. Sternheim, Mr. Rohrbach, and the Judge regarding the admission of exhibits 823 and 824, followed by a recess due to a juror's train delay. The Judge cites the case 'United States v. Lieberman' in relation to arguments about insurance cards and employer verification of employee information.
This page from a court filing argues that the court has the inherent authority to suppress evidence obtained through government misrepresentation. It cites multiple legal precedents to support the claim that sanctions can be applied even if the misconduct occurred in a different venue, provided it is related to the current case.
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