2d Cir.
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This document is a page from a legal filing (Document 613) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 24, 2022. The text argues against 'Juror No. 50's' request to intervene and obtain discovery, citing that the juror has no legal standing and is currently under criminal investigation. The prosecution argues that releasing information would allow the juror to tailor their testimony and prejudice the ongoing investigation into their conduct.
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This document is page 23 (filed page 30) of a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), dated February 24, 2022. The text presents legal arguments regarding juror misconduct during voir dire, citing precedents to argue that a false answer by a juror—whether intentional or inadvertent—that hides bias constitutes structural error requiring a new trial. It references key cases such as United States v. Barnes, United States v. Stewart, and McDonough.
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This document is page 4 of a legal filing (Document 613) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. It is a 'Table of Authorities' listing various legal precedents (cases) cited in the main document, ranging from 1933 to 2022. Notably, it cites 'Brown v. Maxwell' (2019), a case directly involving the defendant.
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This document is page 8 of a court filing (Document 609) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 24, 2022. It presents legal arguments citing various precedents to establish that jurors retain privacy interests after a trial concludes and that jurors face criminal exposure for perjury on questionnaires. It also argues that third parties may intervene in criminal trials to protect their constitutional rights.
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This document is the second page of a Court Order filed on February 24, 2022, in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). Judge Alison J. Nathan orders that following the resolution of the Defendant's motion, redactions will be unsealed, with exceptions made to protect juror anonymity and privacy.
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This document is page 'iii' (Table of Authorities) from a legal filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It lists legal precedents cited within the brief, including 'United States v. Epstein' (2019) and 'United States v. Salerno' (1987), along with a citation to 18 U.S.C. § 3142 regarding bail/detention. The page bears a Bates stamp DOJ-OGR-00019878.
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This document is the 'Table of Authorities' (page ii) from a court filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), originally filed on July 10, 2020. It lists various legal precedents (case law) cited within the main brief, including cases such as Hung v. United States, United States v. Boustani, and United States v. Dreier. The page bears a Department of Justice Bates stamp (DOJ-OGR-00019877).
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This document is a court docket sheet and memorandum opinion from July 2020 regarding the case against Ghislaine Maxwell. It details the legal dispute over a protective order, specifically regarding Maxwell's ability to publicly name alleged victims and witnesses. Judge Alison J. Nathan ruled in favor of the Government, adopting their proposed protective order to restrict Maxwell from referencing alleged victims, citing the need to protect their privacy and safety despite previous public statements.
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This legal document, part of an appeal, argues against the government's position that Ms. Maxwell must wait until after her criminal trial to challenge certain judicial decisions. The filing asserts that the current appeal is the correct and only time to review Judge Preska's unsealing order from a related civil case, as a panel in the criminal case would lack jurisdiction. It also refutes the government's claim that a post-judgment appeal would be an effective remedy for premature unsealing of materials.
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Page 17 of a legal filing (Case 20-3061, dated Oct 2, 2020) produced by the DOJ. The text contains legal arguments citing various precedents (Punn, Mohawk Indus., Hitchcock) to argue that appellate review should generally wait until a final judgment is entered, rather than allowing immediate interlocutory appeals, particularly regarding pre-trial discovery or evidence rulings.
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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 the Judge, Ms. Sternheim (Defense), and Mr. Rohrbach (Government) regarding the admissibility of evidence (exhibits 823 and 824, identified as insurance cards). The Judge cites *United States v. Lieberman* as relevant case law while the court waits for a delayed juror.
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This page is from a court order filed on June 24, 2022, in case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The judge denies the Defendant's request to redact statements related to victims Annie Farmer, Kate, and Giuffre, ruling that the documents are judicial records subject to public access under the First Amendment. The court argues that the Defendant's concerns do not outweigh the presumption of public access, noting that the Court (as decision-maker) can evaluate the submissions without prejudice.
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This document is a court order from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330). The Judge rules that while the Defendant challenges whether Maria Farmer, Sarah Ransome, Teresa Helm, and Juliette Bryant meet the statutory definition of 'crime victims' under the CVRA, the Court has broad discretion under 18 U.S.C. § 3661 to consider information at sentencing. Consequently, the Court permits these four women to provide written submissions for the sentencing record but denies their requests to make in-person statements.
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This document is page 2 of a government filing in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on June 24, 2022. The Government argues that victims have a right to be heard at sentencing and opposes the defendant's request to redact victim impact statements, citing that privacy interests belong to the victims, not the defendant. The filing cites legal precedents (Eberhard, Lugosch) regarding the Court's discretion to accept information and the standards for sealing documents.
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This page is from a legal filing (Document 670) in the case United States v. Ghislaine Maxwell, filed on June 22, 2022. It presents legal arguments regarding sentencing guidelines, specifically U.S.S.G. § 4B1.5 and the Protection of Children from Sexual Predators Act of 1998, arguing that penalties should be increased for patterns of sexual abuse involving minors. The prosecution argues that specific 'background commentary' cited by the defense is not binding and should not override the text of the relevant guidelines intended to ensure severe punishment for such crimes.
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This legal document, part of case 1:20-cr-00330-PAE filed on June 22, 2022, argues for a five-level sentencing enhancement under Section 4B1.5. The prosecution contends the enhancement applies because the defendant engaged in a pattern of prohibited sexual conduct, refuting the defense's claim of double-counting. The document cites testimony from victims Jane and Annie, who received money and a trip to Thailand respectively, as evidence of a 'commercial sex act' to support the enhancement.
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This legal document is a court filing that refutes two arguments made by the defendant. First, it argues that the standard for the victim's (Carolyn's) behavior is 'undue influence,' not complete lack of voluntary action. Second, it dismisses the defendant's claim of 'double-counting' in sentencing enhancements by citing legal precedents (Watkins, Kohlmeier, Arbaugh) which establish that different guideline provisions can address different harms from the same conduct.
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This document is page 31 of a legal filing (Document 670) from the case US v. Ghislaine Maxwell, dated June 22, 2022. The text argues for a sentencing enhancement based on 'undue influence' exerted over a victim named Carolyn. It details how the defendant (Maxwell) groomed Carolyn by exploiting her drug addiction with money, discussing her personal trauma, and directing Virginia (Giuffre) to teach Carolyn how to sexually gratify Jeffrey Epstein.
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This document is Page 27 of a court filing (Document 670) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on June 22, 2022. It contains legal arguments regarding sentencing guidelines, specifically the 'otherwise extensive' prong of criminal organization. The text cites Second Circuit precedents (*Carrozzella* and *Rubenstein*) to argue that a defendant does not need to supervise another *knowing* participant to qualify for an enhancement, drawing a parallel to a 'right-hand man' scenario involving unknowing participants.
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This document is page 21 of a sentencing memorandum filed by the defense for Ghislaine Maxwell on June 15, 2022. The defense argues for a 'non-guidelines sentence' (downward variance), contending that Maxwell should not be treated as harshly as Jeffrey Epstein (who they argue was more culpable) or Harvey Weinstein (who received 23 years for forcible rape). The text highlights that the Probation Department recommended 240 months, while the Guidelines range was 292-365 months, which the defense claims is unjust given her age (60), the age of the offenses (18-28 years prior), and her lack of criminal history.
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This legal document, part of a court filing, argues that Ms. Maxwell must be sentenced under the 2003 Guidelines rather than the harsher 2004 Guidelines. It asserts that applying the 2004 Guidelines would violate the Ex Post Facto Clause unless a jury, not the judge, found that her criminal conduct continued past November 1, 2004. Since the jury made no such finding, the court is bound to use the earlier guidelines.
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This legal document is a court ruling denying a motion from the Defendant, Maxwell. The Defendant argued that the Government's delay in bringing charges prejudiced her ability to prepare a defense, but the Court found no evidence that the delay was intentional or for tactical advantage. The Court reaffirms its previous rulings and notes that trial testimony provided legitimate explanations for the timing of the indictment.
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This legal document is a portion of a court filing, likely a response or motion, dated April 29, 2022. It defends the Court's decisions regarding jury instructions against objections from the Defendant (Maxwell). The Court rejected the Defendant's requests to limit the charges to specific travel routes (e.g., from Florida to New York) and to instruct the jury on the age of consent laws in New Mexico, the United Kingdom, and Florida, arguing these requests were unnecessary, inaccurate, and would confuse the jury.
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This document page is from a court filing (Case 1:20-cr-00330-PAE) dated April 29, 2022, concerning the trial of Ghislaine Maxwell. It discusses a dispute over the interpretation of a jury note regarding 'Count Four,' specifically whether the jury was considering conduct in New Mexico versus New York state law. The text details arguments about a missing comma in the note and the Court's instruction that New York law was the governing statute, even if New Mexico events were relevant to intent.
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This document is page 16 of a court order filed on April 29, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The page details the Court's denial of the Defendant's Rule 29 motion for a judgment of acquittal, citing various legal precedents regarding the sufficiency of evidence required to sustain a conviction. The text outlines the legal standard that evidence must be viewed in the light most favorable to the government.
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