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DOJ-OGR-00022084.jpg

This is page 22 of a legal filing (Document 35) from Case 1:19-cr-00830-AT (United States v. Ghislaine Maxwell), filed on April 24, 2020. The text outlines legal arguments and precedents regarding the Government's obligation (under Rule 16 and Brady) to review and produce records held by other agencies. It cites multiple cases to establish that the prosecution is not required to search other agencies' records (such as the SEC, PCAOB, or FAA) unless a 'joint investigation' was conducted with that specific agency.

Court filing / legal brief (case 1:19-cr-00830-at)
2025-11-20

DOJ-OGR-00022077.jpg

This legal document is a section of a government filing arguing against a defendant's (Thomas) request for certain records. The government contends that the records—related to BOP staffing, policies, and other employees—are not 'material' to preparing a legal defense under Rule 16. Instead, the government asserts Thomas seeks these records for the impermissible purpose of encouraging jury nullification by arguing that poor conditions at the BOP 'led' to his alleged criminal conduct.

Legal document
2025-11-20

DOJ-OGR-00022067.jpg

This document is page 5 of a 34-page legal filing (Document 35 in case 1:19-cr-00830-AT), filed on April 24, 2020. It serves as a table of authorities, listing numerous legal cases cited within the main document, such as United States v. Payne and United States v. Pelullo. Each entry includes the full legal citation and the page number(s) where the case is referenced in the filing.

Legal document
2025-11-20

DOJ-OGR-00010389.jpg

This legal document, part of a court filing, discusses the legal distinction between a 'constructive amendment' and a 'variance' in a criminal indictment. It cites numerous precedents to argue that for a variance to warrant reversal of a conviction, the defendant must demonstrate 'substantial prejudice'. The document concludes by noting that the Defendant has filed a motion under Rule 33 to vacate the judgment and grant a new trial.

Legal document
2025-11-20

DOJ-OGR-00009589.jpg

This page is from a legal filing (Document 621) in the case US v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 25, 2022. The text presents legal arguments citing Second Circuit precedents (specifically the 'Korfant factors') to argue that separate conspiracy counts are distinct and do not violate double jeopardy protections. The prosecution argues that Counts Three and Five charge different offenses and requests the Court reject the defendant's multiplicity claim.

Legal filing / court document (case 1:20-cr-00330-pae)
2025-11-20
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