2d Cir.
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This document appears to be page 5 (labeled Roman numeral iv) of a legal brief or filing related to Case 20-3061, filed on October 2, 2020. It is a Table of Authorities listing various legal precedents (case law) cited in the main document, including United States v. Caparros and United States v. Kerik. The footer indicates it is part of a Department of Justice (DOJ-OGR) release.
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This legal document, part of case 20-3061, argues for the issuance of a writ of mandamus. It outlines the three legal conditions required for such a writ, citing precedents like 'In re Roman Catholic Diocese of Albany, N.Y.'. The document asserts that all three conditions are met, specifically claiming that Judge Nathan abused her discretion regarding a protective order and that the petitioner, Ms. Maxwell, has no other legal recourse, referencing her request to Judge Preska.
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This document is page 6 of a legal filing dated September 28, 2020, concerning Case 20-3061. It presents a legal argument distinguishing the current appeal from *Flanagan v. United States*, asserting that Ghislaine Maxwell's appeal regarding Judge Nathan's order is comparable to a bail reduction motion because the harm (unsealing deposition materials) would be irreversible ("the cat is irretrievably out of the bag") if not addressed immediately. The text argues that Maxwell must be allowed to share information from Judge Nathan with Judge Preska to prevent the unsealing order from going into effect without reconsideration.
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This document is page 3 of a legal brief (Case 20-3061) filed on September 28, 2020, arguing that the appellate court has jurisdiction to review a district court's decision regarding a protective order in the Ghislaine Maxwell case. The text focuses on the 'collateral order doctrine' and cites legal precedents to support the claim that the unsealing order can be appealed immediately without waiting for the criminal trial to conclude. It mentions Ms. Maxwell's intention to stay the unsealing process.
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This is page 2 of a legal filing addressed to Judge Alison J. Nathan dated August 21, 2020, in case 1:20-cr-00330 (United States v. Ghislaine Maxwell). The text presents legal arguments supporting the continued sealing of documents related to grand jury proceedings and ex parte applications, citing various legal precedents regarding the First Amendment right of access versus the necessity of grand jury secrecy. A footnote mentions an April 2019 order that allows for limited exceptions to these sealing orders for discovery purposes.
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This document is a page from a court docket concerning the case of United States v. Ghislaine Maxwell, specifically detailing a Memorandum Opinion & Order dated July 30, 2020. The order resolves disputes regarding a protective order, siding with the Government to restrict Ms. Maxwell from publicly referencing alleged victims not identified in the litigation and rejecting her request to restrict potential witnesses' use of discovery materials. The court emphasizes the need to balance privacy interests of victims and witnesses against the defendant's rights and public interest.
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This document is page 21 (filed as page 26) of a legal brief in Case 20-3061, filed on September 24, 2020. It argues that a writ of mandamus is appropriate because Judge Nathan abused her discretion regarding a protective order and Judge Preska's unsealing order relies on inconsistent decisions within the Southern District of New York. The text discusses the unsealing of deposition materials and claims prejudice against Ms. Maxwell, though specific details are heavily redacted.
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This document is a page from a legal filing in Case 20-3061, dated September 24, 2020. The author, likely representing Ms. Maxwell, argues that a protective order is appealable by citing precedent from cases like *Pappas* and *United States v. Salameh*. The filing refutes the government's argument by clarifying the focus of Ms. Maxwell's appeal.
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This legal document, part of a court filing, argues that an appeal concerning Judge Nathan's order should proceed. The author contends that the appeal is separate from an ongoing criminal case involving Ms. Maxwell, will not cause delays, and that waiting for the criminal trial to conclude would render the issue moot. The document references a stay on Judge Preska's order to unseal deposition material as a reason for the current proceedings.
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This page from a legal brief (filed Sept 24, 2020) argues against the government's stance that the court lacks jurisdiction to hear Ghislaine Maxwell's appeal. The text discusses the 'collateral order doctrine' in criminal cases, citing precedents like Midland Asphalt Corp. and Flanagan, and asserts that Maxwell simply seeks permission to share facts under seal with another judge. A footnote references the Miami Herald's involvement in the related civil case Brown v. Maxwell.
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This legal document, dated September 24, 2020, is a filing in an appeal related to the case 'Giuffre v. Maxwell'. The author argues that appealing Judge Preska's decision to unseal deposition material will be moot after a final judgment. The stated purpose of the appeal is to share redacted information, which Ms. Maxwell learned, with Judge Preska.
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This document is page 14 of a legal filing from September 24, 2020, concerning Ghislaine Maxwell's appeals. It outlines the procedural posture of two related appeals: one regarding Judge Preska's order unsealing deposition materials in the civil case (Giuffre v. Maxwell), and the current appeal regarding Judge Nathan's denial of a motion to modify a criminal protective order. Maxwell has moved to consolidate these two appeals.
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This page is from a legal brief (Document 38, Case 20-3061) dated September 16, 2020. It argues against an immediate appeal by Ghislaine Maxwell regarding the unsealing of civil case documents. The text contends that any potential prejudice to her criminal trial (due to publicity) can be adequately addressed through a standard appeal after a final judgment, rather than an interlocutory appeal.
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This document is page 11 of a legal filing (Case 20-3061) dated September 16, 2020. It presents legal arguments regarding the 'collateral-order doctrine' and protective orders in criminal cases, arguing that such orders are generally not subject to interlocutory appeal. The text cites various precedents (Firestone, Caparros, Pappas) to support the argument that restricting the dissemination of discovery materials does not violate First Amendment rights and that challenges to such orders should await final judgment.
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Page 10 of a legal filing (Case 20-3061) dated September 16, 2020. The text contains legal arguments regarding the timing of appellate reviews, specifically citing precedents (Punn, Mohawk Indus., Hitchcock) to argue that immediate appeals are generally not granted if post-judgment relief (like a reversal after a trial) can adequately protect the defendant's rights. The document bears a DOJ Bates stamp.
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This document is page 9 of a legal brief filed on September 16, 2020, in Case 20-3061 (United States v. Maxwell). The text outlines legal arguments regarding the 'collateral-order doctrine' and 'interlocutory appeals' in criminal cases. It cites numerous precedents (Cohen, Stack, Abney, Sell) to demonstrate that the Supreme Court rarely permits appeals before a trial concludes, arguing that an order is only immediately reviewable if rights would be 'effectively unreviewable' later.
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This document is a page from a legal filing, specifically Case 20-3061, dated September 16, 2020. It argues against the immediate appeal of a district court's pretrial decision, asserting that any potential harm to the defendant, Punn, can be adequately remedied through the standard appellate process after a final judgment. The text cites several legal precedents, including Mohawk Indus. and United States v. Hitchcock, to support the principle that post-conviction review is sufficient to protect a defendant's rights, even in cases involving purportedly ill-gotten evidence.
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This document is page 10 of a legal filing (Case 20-3061, dated September 16, 2020) related to United States v. Ghislaine Maxwell in the Second Circuit. The text consists of legal arguments regarding the 'collateral-order doctrine' and cites multiple Supreme Court precedents (such as Stack v. Boyle and Sell v. United States) to define when pretrial orders in criminal cases can be appealed immediately. The document argues that exceptions allowing for interlocutory appeals are rare.
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This document is page 33 of a court transcript from Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on August 10, 2022. The dialogue captures a legal argument between the Judge ('The Court') and defense attorney Mr. Everdell regarding jury instructions for a charge under 18 U.S.C. § 2421 (Mann Act). The Judge cites *United States v. An Soon Kim*, arguing that the word 'dominant' is not required in the statutory language for proving the purpose of transportation, while Everdell attempts to distinguish the case.
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This document is page 29 of a defense filing (Document 616) in the case of United States v. Ghislaine Maxwell, filed on February 24, 2022. The text argues for a hearing and discovery regarding potential juror misconduct, specifically alleging that a second juror (in addition to Juror No. 50) failed to disclose a history of childhood sexual abuse during voir dire. The defense cites a New York Times article and statements by Juror No. 50 as evidence, while rebutting the government's objections to post-trial discovery.
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This document is page 48 of a court filing from the Ghislaine Maxwell case (1:20-cr-00330-PAE), dated February 24, 2022. The text argues against the defendant's request to seal Juror 50's motion to intervene, asserting it is a judicial document that should be public. It also defends the Government's previous decision to publicly file a letter regarding Juror 50's public statements, noting that defense counsel failed to respond to attempts to confer prior to that filing.
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This document is page 35 of a legal filing (Document 615) from the Ghislaine Maxwell trial (Case 1:20-cr-00330), filed on February 24, 2022. It is a Government argument requesting that the Court limit the scope of an upcoming hearing regarding potential misconduct by 'Juror 50' regarding undisclosed history of sexual abuse. The Government argues the Court should conduct the questioning to protect the juror from harassment and that inquiries must be strictly limited to whether the juror lied on Question 48 or Question 25 of the jury questionnaire.
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This page from a legal filing (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) discusses the legal standard for 'Inferred Bias' in jurors. It argues that even if 'Juror 50' had disclosed a history of sexual abuse during voir dire, the Court would not have automatically dismissed him for cause without further questioning to establish actual partiality. The text cites precedents like *Torres* and *Greer* to support the trial court's discretion in these matters.
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This legal document, filed on February 24, 2022, is part of the Government's response to a defendant's motion. The Government argues that the defendant has failed to satisfy the 'Second Prong of McDonough,' a legal test, regarding Juror 50, who allegedly gave a false answer on a questionnaire about being a victim of sexual abuse. While finding the defendant's argument unpersuasive, the Government agrees a limited hearing is warranted to determine if the juror's answer was deliberately false and argues the court must decide if it would have granted a challenge for cause, a standard the defendant allegedly omitted.
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This document is page 7 of a legal filing (Document 614) from February 24, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). It argues that 'Juror 50' provided untrue answers during jury selection (voir dire) by denying past sexual abuse and claiming impartiality, facts which were later contradicted by the juror's own press statements. The text cites the 'McDonough test' to argue that these false answers prevented the defense from challenging the juror for cause.
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