2d Cir.
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This legal document is a court opinion from Case 1:20-cr-00330-PAE, filed on April 1, 2022. The court analyzes and rejects the Defendant's (Maxwell's) argument that Juror 50 was biased due to dishonest answers on a jury questionnaire. The court distinguishes this case from precedents involving deliberate deception, crediting Juror 50's explanation that his nondisclosure was an 'inadvertent mistake' resulting from personal distractions and 'skimming' the form.
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This document is page 24 of a court ruling (Document 653) filed on April 1, 2022, in the case United States v. Maxwell. The text addresses the legal standard for 'Actual Bias' and specifically rules that the record does not support a finding that 'Juror 50' was biased. The Court found Juror 50's testimony credible, noting that he affirmed his personal history of sexual abuse would not impact his impartiality or ability to assess witness credibility, rejecting the Defendant's (Maxwell) argument that his responses were merely self-serving.
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This document is page 26 of a legal filing from March 11, 2022, in the case of United States v. Ghislaine Maxwell. The text argues that the Court must conduct a broad inquiry into Juror No. 50's potential bias and intent, asserting that the juror has a history of giving false answers. It contrasts Juror No. 50 with Jurors 189 and 239, who properly disclosed details of past sexual abuse in written questionnaires, though the specific details of that abuse are redacted in this document.
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This page is from a legal filing (Case 1:20-cr-00330-PAE) dated March 11, 2022. It contains legal arguments citing case law (Gagnon, Moten, Calbas) regarding the standards for post-verdict jury inquiries. The Government argues that the standard for a hearing has been met specifically regarding 'Juror 50' due to inconsistencies between the juror's public statements about being a sexual abuse victim and their answer to Question 48 on the juror questionnaire. The Government consents to a hearing to determine if Juror 50 deliberately lied.
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This legal document argues against the defendant's assertion that a juror's similar life experiences should automatically presume bias, requiring their removal. It cites multiple legal precedents (from the Second, First, Seventh, and other circuits) to support the position that only "extreme situations" warrant such a presumption. The document contends that similarity of experience is just one of many factors to be considered and is often insufficient on its own to justify a juror's dismissal for cause.
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This page from a legal filing (Case 1:20-cr-00330-PAE) argues against a defense motion claiming Juror 50 was biased. The Government asserts that Juror 50's post-trial statements and negative attitude toward the defendant reflect the evidence presented during the trial, not pre-existing bias. It cites legal precedents including *United States v. Stewart* to support the argument that jurors bring subjective lived experiences to deliberations.
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This document is page 36 of a legal filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on March 11, 2022. It presents a legal argument specifically concerning 'Juror No. 50,' asserting that had the juror answered Questions 25 and 48 truthfully, they would have been challenged for cause. The text relies heavily on case law citations (McDonough, Wainwright, Stewart) to define legal standards for juror impartiality and materiality of false answers.
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This legal document outlines the Second Circuit's stringent standard for pre-indictment delay, which requires a defendant to prove both improper government purpose and serious, actual prejudice to their defense. It cites numerous legal precedents to emphasize the heavy burden on the defendant and to define substantial prejudice, noting that the mere loss of evidence or witnesses is typically insufficient. The document establishes that claims of pre-indictment delay are rarely successful.
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This document is page 21 of a legal filing (Document 621) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on February 25, 2022. The text contains legal analysis rejecting the defendant's argument that the Court's response to a jury note constructively amended the indictment. It cites various legal precedents (Jones, Lebedev, Muraca) to support the Court's discretion in handling jury inquiries and instructions.
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Page 5 of 51 from a court filing (Document 621) in the case of United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on Feb 25, 2022. The text argues that no 'constructive amendment' of the indictment occurred regarding the charges of enticing and transporting victim 'Jane' and other minor victims to New York. The remainder of the page outlines applicable law regarding the Fifth Amendment's Grand Jury Clause, citing precedents like U.S. v. Khalupsky and U.S. v. Dove to define the legal standard for constructive amendments.
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This document is page 14 of a court order filed on February 25, 2022, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The court is rejecting the Defense's argument that Federal Rule of Evidence 606 (regarding juror competency as a witness) violates Maxwell's constitutional rights to due process and confrontation. The judge rules that Juror 50 was a factfinder, not a witness against the defendant, and cites Supreme Court precedents (Crawford, Tanner) to uphold the limitations on using juror affidavits to impeach a verdict.
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This court order page denies the Defendant's (Maxwell) request to investigate Juror 50's social media and to examine other jurors regarding a 'second juror' allegedly abused as a minor. The court rules that Juror 50's Instagram posts were personal and do not warrant a 'fishing expedition,' and that the theory regarding a second juror is unfounded speculation based on a New York Times article. Footnote 5 details a timeline of communications between the court and jurors regarding media harassment, noting that these communications will be shared with the parties under seal with redactions to protect juror privacy.
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This document is page 4 of a legal filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 25, 2022. It discusses a motion for a new trial based on 'Juror 50' allegedly failing to disclose information (specifically regarding childhood sexual abuse) during voir dire. The text outlines the legal standards for such a motion, citing Federal Rule of Criminal Procedure 33 and the Supreme Court case *McDonough Power Equipment, Inc. v. Greenwood*.
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This document is page 2 of a legal filing (Document 617) in Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on February 24, 2022. The text argues against the defendant's claim that 'Juror 50's' motion to intervene constitutes a discovery request, clarifying that the juror is seeking access to his own questionnaire which he swore under penalty of perjury. The filing argues that the motion is a judicial document that should not remain sealed, noting the defendant's arguments regarding privacy and potential prejudice lack merit.
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This document is a page from a legal filing (Case 1:20-cr-00330-PAE, US v. Ghislaine Maxwell) arguing for the admissibility of evidence under Rule 404(b). It details the defendant's 'modus operandi' of befriending minors (specifically Minor Victim-3), normalizing sexual topics, and arranging travel to facilitate sexual acts with Epstein. A footnote addresses the defense's anticipated argument regarding lack of knowledge or intent.
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This document is page 175 (labeled 148 internally) of a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It argues legal points regarding perjury counts, specifically discussing materiality standards for false statements in civil depositions and citing case law (Kross, Gaudin, Kungys). The text argues that a jury can follow limiting instructions to separate the substance of Giuffre's allegations from the determination of whether the defendant committed perjury.
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This document is page 152 of a legal filing (Document 204) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against dismissing a perjury count, stating that the defendant's denial of knowledge regarding Epstein's scheme to recruit underage girls for sexual massages was not due to fundamental ambiguity in the questioning. It includes a transcript excerpt from a deposition where Giuffre's counsel asks the defendant to list girls under 18 she brought to Epstein's house, to which Mr. Pagliuca objects.
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This document is a page from a legal filing, specifically a memorandum of law, discussing the legal standards for perjury. The author argues against dismissing a perjury count before trial based on 'fundamental ambiguity,' citing numerous court cases to establish that such challenges are typically evaluated after a trial. The text distinguishes between answers that are literally true but misleading (which may not be perjury) and answers that are outright false, regardless of responsiveness (which can be perjury).
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This document is page 147 of a court filing (Document 204) from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal analysis regarding perjury charges, specifically discussing the legal standard for 'fundamental ambiguity' in questioning. The text cites various precedents to argue that a perjury count stands unless a question is so ambiguous that people of ordinary intellect cannot agree on its meaning, noting that simple amenability to multiple meanings is not a sufficient defense.
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This legal document is a page from a court filing, dated April 16, 2021, concerning a defendant's motion to dismiss two counts of perjury. The charges stem from depositions in April and July 2016, where the defendant was ordered to answer questions about her involvement with Epstein and Giuffre in a prior defamation case. The document outlines the court's previous orders and introduces the applicable law for perjury, citing legal standards for determining if a statement is knowingly false.
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This legal document, a page from a court filing dated April 16, 2021, discusses the legal standard for challenging an affidavit based on alleged omissions of fact. It cites numerous precedents, primarily from the Second Circuit and the Southern District of New York, to argue that a motion to suppress evidence should be denied unless the omissions were intentional, deliberate, or made with reckless disregard for the truth. The document emphasizes that this is a high standard to meet, as courts recognize that all affidavits will inevitably omit some facts that may seem significant in retrospect.
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This legal document, page 140 of a court filing from April 16, 2021, outlines the legal standard for a defendant to obtain a "Franks hearing" to challenge the validity of an affidavit used for probable cause. It details the three-part test a defendant must meet, requiring a "substantial preliminary showing" of inaccuracies or omissions in the affidavit that were material and made with deliberate falsehood or reckless disregard for the truth. The document explains that a court must then determine the materiality of these errors by revising the affidavit to see if it still supports a finding of probable cause.
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This legal document argues that a district court's supervisory authority to suppress evidence is limited and should only be used when there is a clear violation of constitutional, statutory, or procedural law. Citing multiple legal precedents, the author contends that this power must be 'sparingly exercised' and that the defendant in this case has not established such a violation, and is therefore not entitled to an evidentiary hearing to challenge the government's actions.
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This legal document, page 125 of a court filing from April 16, 2021, discusses the application of the Fifth Amendment privilege against self-incrimination to the act of producing documents. It cites several legal precedents to argue that the privilege only applies when the act of production itself is testimonial and incriminating, not merely because the documents' contents are incriminating. The document further asserts that the Fifth Amendment is primarily concerned with protecting individuals from governmental coercion, not from other moral or psychological pressures.
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This document is page 115 of a legal filing (Document 204) from United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. It outlines legal arguments regarding the 'good faith exception' to the exclusionary rule, citing precedents like United States v. Leon and United States v. Moore. The text argues that suppression of evidence is not warranted because the Government acted in good faith by obtaining a grand jury subpoena and applying to the court to modify a civil protective order.
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