This document is page 3 of 15 from a legal filing (Document 103-2) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on August 23, 2020. It contains a 'Table of Authorities' listing two legal precedents: United States v. Chen and United States v. Orta. The document bears a Department of Justice footer (DOJ-OGR-00001188).
This document is the final page (14) of a government filing dated July 12, 2019, addressed to Judge Richard M. Berman, arguing against bail for Jeffrey Epstein. The text provides legal precedents establishing that sex trafficking laws (Section 1591) apply to consumers/buyers, not just suppliers, refuting the defense's legal arguments. The conclusion explicitly requests pretrial detention based on Epstein's wealth, flight risk, possession of lewd photos of minors, and history of witness interference.
This document is page 35 (filed as page 41 of 45) of a legal motion arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a flight risk and that her current detention at the MDC amounts to 'de facto solitary confinement' under conditions more severe than supermax prisons or death row, which impedes her ability to prepare her defense. The text cites legal precedent regarding bail standards and claims wardens have never seen such restrictive regulations.
This document is page 41 of a legal filing (Doc 657) from April 2022 in the Ghislaine Maxwell case (1:20-cr-00330). The court is rejecting the Defendant's arguments that pre-indictment delay caused a prejudicial loss of evidence, specifically noting the Defendant failed to explain the loss of government property records, proof of Epstein's residency, or flight manifests delivered by pilot Larry Visoski to Epstein's New York office. The court also dismisses arguments regarding deceased potential witnesses as vague assertions.
This is a page from a legal filing (Government's opposition) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The prosecution argues that the defendant's claims of prejudice due to pre-indictment delay—specifically citing dead witnesses, lost Epstein employees, and corrupted memories—are insufficient to warrant dismissal based on established legal precedents. The document cites various case laws (Marion, Snyder, Iannelli, King) to support the position that fading memories or unavailable witnesses are inherent in delays and do not automatically constitute actual prejudice.
This document is page 53 of a legal filing (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) filed on April 16, 2021. It presents legal arguments regarding the statute of limitations for sex crimes involving minors, specifically arguing that the 2003 amendment to 18 U.S.C. § 3283 applies retroactively to crimes committed between 1994 and 1997. The text cites relevant case law (US v. Leo Sure Chief, US v. Jeffries) to support the position that the indictment is timely because the victims are still alive.
This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense asserts she is not a flight risk and argues that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions rivaling a Supermax prison, which impairs her ability to prepare her defense. The text cites United States v. Orta regarding bail standards and claims wardens have noted the unprecedented nature of her restrictive regime.
This document is a page from a 2005 BYU Law Review article discussing the Crime Victims' Rights Act (CVRA) and federal sentencing procedures. It details the rights of victims to access presentence reports and be heard regarding sentencing guidelines, citing Senator Kyl and various legal precedents. The document bears the name of attorney David Schoen and a House Oversight Committee Bates stamp, indicating it was likely submitted as a legal exhibit or research material during congressional inquiries related to the Epstein case (Schoen was one of Epstein's attorneys).
This document is an excerpt from a 2007 Utah Law Review article (page 29 of 78 in the evidence file) discussing amendments to Federal Rules of Criminal Procedure regarding victims' rights. It specifically details proposals for Rule 17 to protect victims from abusive subpoenas of their confidential information by defense attorneys, citing the Crime Victims' Rights Act. The document bears the name 'David Schoen' and a House Oversight Bates stamp, indicating it was part of the congressional investigation into the handling of the Epstein case (likely related to the non-prosecution agreement and victims' rights violations).
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