2d Cir.
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This document is a page from a legal filing, dated April 16, 2021, that discusses the application of the Fourth Amendment's exclusionary rule. It cites numerous federal court cases, including from the Supreme Court, to argue that suppressing evidence is a 'last resort' intended to deter deliberate, reckless, or grossly negligent police misconduct. The text emphasizes the 'good-faith' exception, particularly when law enforcement acts in reasonable reliance on a search warrant, suggesting that suppression is generally not warranted in such cases.
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This court document outlines the procedural history of the civil litigation between Virginia Giuffre and Ghislaine Maxwell, including deposition dates in 2016 and a settlement in 2017. It details how the USAO-SDNY formally opened its investigation into Jeffrey Epstein and co-conspirators in late November 2018, explicitly crediting Julie K. Brown's reporting in the Miami Herald as the catalyst. The document also clarifies that a specific prosecutor, 'AUSA-1', was not involved in opening this 2018 investigation.
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This document is page 35 (pacer page 62) of a legal filing in the case United States v. Ghislaine Maxwell. The text is a legal analysis rejecting Maxwell's arguments to dismiss the indictment based on the statute of limitations. The court distinguishes the precedents cited by Maxwell (specifically Thom v. Ashcroft and Toussie v. United States), arguing that they do not prevent the retroactive application of the relevant statute of limitations.
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This page is from a government filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), arguing against the defendant's motion to dismiss based on the statute of limitations. The text asserts that the Ex Post Facto Clause is not violated because the limitations period had not expired for Counts One through Four when it was extended in 2003. Footnotes address the specific ages of Minor Victims 1, 2, and 3 in relation to the 2003 extension and discuss the 'Landgraf' Supreme Court precedent regarding legislative retroactivity.
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This document is page 26 of 239 from a legal filing (Document 204) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It is a 'Table of Authorities' listing legal precedents (case law starting with W and Z) and a comprehensive list of Federal Statutes (18 U.S.C. and 28 U.S.C.) referenced in the filing. The statutes cited include laws regarding sex trafficking (§ 1591), coercion/enticement (§ 2422), transportation of minors (§ 2423), and child victims' rights (§ 3509), which are central charges in the Maxwell/Epstein proceedings.
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This document is page 21 of a Table of Authorities from a legal filing (Document 204) in Case 1:20-cr-00330-PAE, which corresponds to the trial of United States v. Ghislaine Maxwell. The page lists various legal precedents (case law citations) ranging from 'United States v. Rahimi' to 'United States v. Rosa' used to support legal arguments in the main brief. The document bears the Bates stamp DOJ-OGR-00002955.
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This document is page xvi from a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It serves as a table of authorities, listing numerous 'United States v.' court cases with defendants ranging from Israel to Laurenti. Each entry provides the legal citation for the case and the page numbers where it is referenced within the main document.
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This document is page xiii from a legal filing, specifically a Table of Authorities from Document 204 in case 1:20-cr-00330-PAE, filed on April 16, 2021. It lists numerous U.S. federal court cases cited within the larger document, providing the case name, legal citation, and the page numbers where each case is referenced. The cases listed involve the United States as the plaintiff against various individual defendants.
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This is page 13 of a court filing (Doc 307) from the Ghislaine Maxwell criminal trial (Case 1:20-cr-00330-PAE), filed on June 25, 2021. The text denies Maxwell's request to suppress evidence, stating she failed to prove a due process violation or justify the use of the Court's supervisory authority. The Court argues that the Government's omission of information regarding past communications with BSF (Boies Schiller Flexner) does not constitute the 'extreme misconduct' or 'willful disobedience of law' required for suppression.
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This legal document is a filing by the Government arguing against the defense's motion for early disclosure of impeachment material related to a witness, Minor Victim-4. The Government contends that Minor Victim-4's prior consistent statement from a deposition, made over a decade before the defendant's 2020 indictment, confirms the defendant's role in scheduling her massages with Epstein, thereby undermining the defense's claim of recent fabrication. The Government affirms its intent to provide this material ten days before trial, in line with customary practice.
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This document is page 17 of a Government filing (Document 295) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on May 25, 2021. The text argues that the Defendant's motion to dismiss the S2 Indictment based on improper pre-trial delay should be denied, citing that the Court has already rejected similar arguments and that the defendant failed to prove actual prejudice or intentional delay by the Government. It references case law standards for due process violations regarding pre-indictment delays.
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This document is page 12 (internal page 8) of a legal filing (Document 295) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on May 25, 2021. The text presents legal arguments regarding 'Double Jeopardy' and 'jeopardy attachment,' specifically analyzing when a defendant is considered to be at risk of conviction during pretrial dispositions and plea agreements. It heavily cites Second Circuit case law (Dionisio, Vanhoesen, Morris v. Reynolds) to argue that jeopardy does not attach to counts dismissed merely due to an agreement between parties without fact-based resolution.
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This document is a legal filing that refutes the defense's arguments against the admissibility of expert testimony from Dr. Rocchio. The author argues that the defense misinterprets legal precedent, specifically the Raymond case, and that Dr. Rocchio's testimony, based on qualitative social science, is valid under the standards established by cases like Daubert and United States v. Ferguson. The filing defends the expert's methodology against claims that it is unreliable, uncorroborated, and lacks statistical precision.
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This document is a page from a legal filing (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) dated October 29, 2021. The text argues for the admissibility of expert testimony regarding 'grooming' and the psychological relationship between sexual abuse victims and perpetrators, citing numerous appellate court precedents (9th, 8th, 10th, 5th, and 2nd Circuits) to support the validity/relevance of such testimony. The filing notes that the defendant is attempting to rely on a single contrary case from the District of Maine.
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This legal document, a page from a court filing, discusses the standards for admitting expert testimony in court. It argues that a district court has broad discretion in determining the reliability of such testimony and that it must also be relevant, concerning matters beyond the understanding of an average juror. The document cites several precedents, focusing on cases where courts admitted expert testimony on the psychological dynamics between perpetrators and victims of sex crimes, such as the 'pimp-prostitute relationship' and 'trauma bonding'.
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This legal document, filed on March 22, 2021, is a portion of a court filing discussing the legal standards for a defendant's bail motion. It outlines the rebuttable presumption of detention under 18 U.S.C. § 3142(e)(3), detailing the defendant's burden of production and the government's ultimate burden of persuasion. The document notes that the defendant has filed a third motion for bail, arguing for reconsideration based on new conditions and a purportedly weakened government case.
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This document is page 4 of a court order filed on March 18, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Government's broad requests to redact pages 1–128 and seal Exhibits 8 and 9, citing a lack of non-conclusory basis for how disclosure would imperil the investigation. The Court sets a deadline of March 22, 2021, for the Government to submit a letter justifying more tailored redactions and agrees with the Defendant regarding objections to redactions on pages 187–188.
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This document is Page 3 of a legal filing entitled 'Table of Authorities' from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on June 18, 2020. It lists numerous legal precedents cited in the filing, primarily 'United States v. [Defendant]' cases. Notably, the list includes two citations for 'United States v. Epstein' (one from 2001 in E.D. Pa. and one from 2019 in S.D.N.Y.) and one for 'United States v. Madoff'.
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This document is a page from a court transcript dated April 1, 2021, regarding United States v. Ghislaine Maxwell. The court is addressing defense arguments for release, comparing her situation to United States v. Friedman, but distinguishing it because Maxwell allegedly did not provide her whereabouts to the government despite staying in contact. The judge argues that Maxwell may not have realized the severity of the charges or the likelihood of prosecution until her actual indictment.
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This document is page 18 of a legal filing (Document 386) from the Ghislaine Maxwell trial (Case 1:20-cr-00330), filed on October 29, 2021. It argues against the admissibility of testimony from an expert witness named Rocchio, specifically challenging her opinions on victim credibility and long-term psychological consequences of abuse as irrelevant, prejudicial, and violating Federal Rules of Evidence 401, 402, 403, and 704.
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This is page 7 of a legal argument filed by the defense in the case of United States v. Ghislaine Maxwell on October 29, 2021. The defense argues that the Government failed to comply with Rule 404(b) notice requirements regarding the admission of certain evidence and testimony from a redacted female witness. The document contends that because the Government did not specify the reasoning or purpose for this evidence, it should be precluded from the trial.
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This legal document is a portion of a court filing arguing against the defense's interpretation of Brady material. The author contends that the cases cited by the defense (such as Kyles, Bowen, and Lindsey) concern the withholding of directly exculpatory evidence and do not support the defense's attempt to introduce irrelevant information to attack the general 'thoroughness' of the investigation. The document uses precedent from Watson v. Greene to argue that these cases offer no guidance on what evidence must be admitted at trial for cross-examination purposes.
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This legal document, a page from a court filing dated October 29, 2021, argues that the jury should not consider the adequacy or methods of the government's investigation when determining a defendant's guilt. Citing multiple legal precedents, the author contends that details about investigations, including the one involving Jeffrey Epstein, are irrelevant to the case at hand. The document refutes the defense's position that they should be allowed to challenge the thoroughness of the government's investigation.
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This legal document, part of a court filing, outlines the Government's strategy for an upcoming trial. The prosecution anticipates defense attacks on the credibility of 'Minor Victims' and plans to introduce prior consistent statements to rebut these attacks and rehabilitate its witnesses. Additionally, the Government argues to preclude the defense from introducing what it deems irrelevant and prejudicial evidence, specifically concerning the history and outcomes of various 'Epstein investigations' in other jurisdictions.
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This legal document, filed on October 29, 2021, is part of the case against Ms. Maxwell. It argues that evidence of Jeffrey Epstein acting alone or without Ms. Maxwell's knowledge should be admissible to counter the government's conspiracy charge. The filing distinguishes Ms. Maxwell's case from several other legal precedents cited by the government, claiming they are inapplicable to the current situation.
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