SOUTHERN DISTRICT OF NEW YORK
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This legal document is a reply memorandum filed by the U.S. Government in the case against Ghislaine Maxwell. The government argues for her continued detention, asserting she is a significant flight risk due to her citizenship in a non-extraditing country and her access to considerable wealth. The memorandum emphasizes that her release would deny justice to the victims of her alleged sexual exploitation crimes.
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This document is the cover page for the Government's Reply Memorandum in Support of Detention in the case of United States of America v. Ghislaine Maxwell (Case 20 Cr. 330). It was filed on July 13, 2020, in the Southern District of New York. The filing lists Acting US Attorney Audrey Strauss and Assistant US Attorneys Alison Moe, Alex Rossmiller, and Maurene Comey as counsel for the prosecution.
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This document is page 20 (filed page 25) of a legal motion filed on July 10, 2020, arguing for Ghislaine Maxwell's release on bail. The defense proposes a $5 million bond co-signed by six friends and relatives, secured additionally by $3.75 million in UK property, alongside home detention, GPS monitoring, and private security within NY districts. The text argues that COVID-19 increases her risk in detention and cites *United States v. Boustani* regarding the use of private security guards for wealthy defendants.
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This legal document, filed on behalf of Ghislaine Maxwell, argues that she is not a flight risk and should be granted release. It refutes the government's claim of her 'frequent international travel' by emphasizing that she has remained in the United States since Jeffrey Epstein's arrest in July 2019 and subsequent death in August 2019. The filing contends that her decision to stay in the U.S. despite intense media scrutiny and public calls for her prosecution demonstrates she has no intention of fleeing.
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This document is page 4 of a legal filing (bail application) for Ghislaine Maxwell, dated July 10, 2020. The defense argues that the government's concerns about flight risk due to her citizenship and finances are unfounded and notes the alleged crimes are 25 years old. The defense proposes a $5 million bond co-signed by six people, secured by UK property, along with home confinement, GPS monitoring, and strict travel restrictions within New York.
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This legal document, part of a court filing, alleges that the defendant, in concert with Epstein and Maxwell, groomed and abused minors, using offers of financial assistance for travel and education as a lure. It further claims that in a 2016 deposition for a civil suit in the Southern District of New York, the defendant repeatedly lied under oath about her involvement. The document then outlines the legal basis for pretrial detention under the Bail Reform Act, citing relevant case law concerning flight risk and danger to the community.
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This document provides the background for a federal indictment returned on June 29, 2020, charging the defendant (Ghislaine Maxwell) with conspiracy, enticing minors for illegal sex acts, and perjury. It describes a scheme operating between 1994 and 1997 in New York, Florida, and New Mexico, where the defendant allegedly groomed underage girls to be sexually abused by Jeffrey Epstein. The text details specific grooming tactics used, such as befriending victims and taking them on shopping trips to normalize the abuse.
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This document is the cover page for a legal filing titled "THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION" in the case of United States of America v. Ghislaine Maxwell. Filed on July 5, 2020, in the U.S. District Court for the Southern District of New York, the memorandum was submitted by Acting U.S. Attorney Audrey Strauss and her team of Assistant U.S. Attorneys.
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This document is the cover page for a legal filing dated April 1, 2021, submitted to the U.S. Court of Appeals for the Second Circuit. It is an appendix to a motion for pretrial release for the appellant, Ghislaine Maxwell, in her appeal against the United States of America. The filing was prepared by attorney David Oscar Markus of the law firm MARKUS/MOSS PLLC.
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This legal document, part of case 21-770, argues for granting bond by citing four precedent cases from the Southern District of New York (Hussain, Buser, Acosta, and McFadden). In each cited case, defendants charged under similar statutes (18 U.S.C. 2422 and 2423) were granted personal recognizance bonds ranging from $100,000 to $250,000 with various conditions like home detention and electronic monitoring. The document uses these examples to demonstrate a pattern of granting bond in similar circumstances within the same jurisdiction.
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This document appears to be page 15 (internal numbering) of a legal brief filed on April 1, 2021, in Case 21-770 (United States v. Ghislaine Maxwell appeal). The text presents legal arguments against pre-trial detention, citing precedents such as *United States v. Stephens* and *United States v. Weigand* to argue that the COVID-19 pandemic creates obstacles to defense preparation that justify release. It specifically references a case where a 'wealthy defendant' deemed a flight risk was released due to the pandemic.
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This document is a page from a legal filing (dated April 1, 2021) presenting the 'Facts' from the defense's perspective regarding Ghislaine Maxwell. It details her arrest in New Hampshire in July 2020, characterizing it as unnecessary and 'showy,' and harshly criticizes her confinement conditions, comparing her isolation to that of Hannibal Lecter and alleging sleep deprivation and invasive searches.
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This document is the cover page for a legal filing, specifically 'Appellant Ghislaine Maxwell's Motion for Pretrial Release', submitted to the U.S. Court of Appeals for the Second Circuit on April 1, 2021. The motion is part of an appeal from a case in the U.S. District Court for the Southern District of New York, in the matter of United States of America v. Ghislaine Maxwell. The filing was made by attorney David Oscar Markus of the Miami-based law firm MARKUS/MOSS PLLC.
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This is a Notice of Appearance filed on March 30, 2021, in the case of United States v. Maxwell (Docket No. 21-770). Lara Pomerantz of the U.S. Attorney's Office for the Southern District of New York is entering the case as additional counsel, joining co-counsel Won S. Shin, on behalf of the United States (Appellee). The document certifies her admission to the court and provides her contact information.
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This document is a page from the court docket in the case of United States v. Ghislaine Maxwell, covering a period in August 2020. It details a judicial order denying a broad defense request regarding witness privacy and discovery materials, followed by a log of subsequent legal filings (motions, affidavits, and endorsements) between the defense team (Everdell, Pagliuca) and the prosecution (Rossmiller) regarding discovery disclosure and protective orders.
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This document is a criminal docket sheet from the U.S. District Court for the Southern District of New York for the case USA v. Maxwell (1:20-cr-00330-AJN), filed on June 29, 2020. It identifies Ghislaine Maxwell as the defendant and lists her legal counsel, including five attorneys from various law firms in New York and Denver. The case was assigned to Judge Alison J. Nathan.
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This document is an electronic filing notice from the U.S. District Court, Southern District of New York, dated March 24, 2021. It informs recipients that the appeal record for the case USA v. Maxwell (1:20-cr-00330-AJN), concerning Ghislaine Maxwell's Notice of Appeal, has been electronically transmitted to the U.S. Court of Appeals. The notice also includes important information regarding PACER access fees and the policy for obtaining free electronic copies of court documents for legal professionals.
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This is a court order filed on March 22, 2021, by District Judge Alison J. Nathan in the case against Ghislaine Maxwell. The document outlines the charges against Maxwell, including conspiracy to entice and transport minors for illegal sex acts and perjury. It summarizes the procedural history of her bail applications, noting that she was twice denied bail in 2020 due to being a flight risk, and references a third motion for bail filed on February 23, 2021.
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This document is a page from a court docket (Case 21-770) detailing legal proceedings in United States v. Ghislaine Maxwell between July and August 2020. It includes a judicial order rejecting a defense request regarding protective orders to safeguard witness privacy, followed by a log of subsequent letter motions and responses regarding discovery disclosure filed by defense attorneys Christian Everdell and Jeffrey Pagliuca, and government attorney Alex Rossmiller. The document tracks the procedural back-and-forth regarding the handling of sensitive discovery materials and protective orders.
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This is a legal document from Case 21-770, dated March 24, 2021. It identifies the plaintiff as the USA and lists the five attorneys from the U.S. Attorney's Office for the Southern District of New York who are representing the government. The document provides contact information, including addresses, phone numbers, and email addresses, for attorneys Alex Rossmiller, Alison Gainfort Moe, Maurene Ryan Comey, Andrew Rohrbach, and Lara Elizabeth Pomerantz.
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This document is a Notice of Appeal filed on March 24, 2021, in the U.S. District Court for the Southern District of New York on behalf of defendant Ghislaine Maxwell. The appeal challenges a court order from March 22, 2021, which denied her 'Third Motion for Release on Bail'. The document identifies Maxwell's attorney, David Oscar Markus, and the prosecuting Assistant U.S. Attorneys.
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This legal document is a Notice of Appearance filed on August 5, 2019, for the case of United States v. Jeffrey Epstein (Docket No. 19-2221). Attorney Alex Rossmiller, from the U.S. Attorney's Office for the Southern District of New York, is formally entering his appearance to serve as additional counsel for the United States, acting as co-counsel alongside Sarah K. Eddy.
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This is a legal document filed on July 24, 2019, in the case of United States v. Jeffrey Epstein (Docket No. 19-2221). Attorney Alison G. Moe of the U.S. Attorney's Office for the Southern District of New York files a notice of appearance, indicating she will serve as additional co-counsel for the United States, alongside Sarah K. Eddy.
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This legal document, dated July 24, 2019, is a Notice of Appearance filed by Maurene Comey in the case of United States v. Jeffrey Epstein (Docket No. 19-2221). Comey, from the U.S. Attorney's Office for the Southern District of New York, is entering her appearance as additional counsel for the United States, joining her colleague Sarah K. Eddy on the prosecution team.
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This document contains docket entries for Case 19-2221 (USA v. Jeffrey Epstein) from July 15-16, 2019. It records court appearances by Epstein, his defense team (Weinberg, Weingarten, Fernich, etc.), and government representatives (Comey, FBI Agent Young, NYPD Detective Byrne). Key events include the scheduling of a bail hearing ruling for July 18, 2019, the granting of a speedy trial time exclusion, the filing of transcripts from a July 8 conference, and the admission of Martin Weinberg as counsel Pro Hac Vice.
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