SOUTHERN DISTRICT OF NEW YORK
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This document is the cover page of a legal filing, specifically a memorandum in support of a renewed motion for bail for the defendant, Ghislaine Maxwell. Filed on December 14, 2020, in the U.S. District Court for the Southern District of New York, it lists the case name as United States of America v. Ghislaine Maxwell and identifies her legal counsel from three different law firms.
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This document is a court order from Judge Alison J. Nathan of the U.S. District Court for the Southern District of New York, filed on December 14, 2020, in the case of United States v. Ghislaine Maxwell. The order grants Maxwell's request to file her renewed bail application with redactions, as the government did not oppose it. The Court finds that the redactions are justified under the three-part test established in the Second Circuit case *Lugosch v. Pyramid Co. of Onondaga*, determining that the motions are judicial documents and that privacy interests outweigh the presumption of public access in this instance.
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This document is a 'Notice of Filing of Official Transcript' filed on December 10, 2020, in the United States District Court for the Southern District of New York, for the case United States v. Ghislaine Maxwell (Case No. 20 Cr. 330). Court Reporter Kristen Cai notifies the court that the transcript for a conference held on July 14, 2020, has been filed. The document outlines the timeline and procedures for attorneys to request redactions of personal identifiers (Social Security numbers, dates of birth, minors' names, financial accounts) before the transcript becomes publicly available.
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This document is page 74 of a court transcript from the case United States v. Ghislaine Maxwell (1:20-cr-00330-AJN), filed on December 10, 2020. A government prosecutor is arguing before the judge that Jeffrey Epstein's Non-Prosecution Agreement (NPA) does not protect the defendant (Maxwell) and asserting that the agreement does not bind the current office. The prosecutor further argues against bail, citing the defendant's extensive international ties, unknown finances, and lack of candor regarding resources to flee.
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This document is page 72 of a court transcript from the case U.S. v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on December 10, 2020. The prosecution argues to the Judge that the defendant is a serious flight risk, justifying why they did not offer her the chance to surrender voluntarily. The prosecutor also notes the defendant's lack of candor regarding finances and references separate civil litigation where defense counsel refused to accept service on the defendant's behalf.
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This document is a court transcript from a case (1:20-cr-00330-AJN) filed on December 10, 2020. In it, a government prosecutor, Ms. Moe of the U.S. Attorney's Office for the Southern District of New York, argues that the government's presentation is based on undisputed facts from a grand jury indictment, not media 'spin'. She references the indictment's 'chilling' allegations, including the trafficking of underage girls and the defendant's undisputed actions of living in hiding.
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This document is page 54 of a court transcript filed on December 10, 2020, in the case of USA v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). Defense attorney Mr. Cohen argues that the defense had previously urged the government not to indict and had made it clear they were available for voluntary surrender, yet the government arrested Maxwell without prior contact. Cohen notes that the government was fully aware that his firm and Haddon Morgan represented Maxwell, and he criticizes the prosecution for trying to 'throw some more dirt' on his client in a reply brief.
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This document is page 52 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. The defense attorney is arguing for the client's release on strict conditions, refuting the government's claim that the client is a flight risk or has been 'hiding out.' The attorney highlights that the client has been actively litigating civil cases since 2015 and denying impropriety regarding Jeffrey Epstein.
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This document is page 43 of a court transcript from the case United States v. Ghislaine Maxwell (1:20-cr-00330), dated December 10, 2020. Defense attorney Mr. Cohen argues that the government has unfairly introduced new facts late in the proceeding, preventing a written response. He attempts to distance his client from Jeffrey Epstein, stating she is 'not the monster' portrayed by the media and emphasizes her strong family and professional ties, noting that supporters are present on the call anonymously for safety reasons.
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This document is page 38 of a court transcript from case 1:20-cr-00330-AJN, filed on December 10, 2020. Prosecutor Ms. Moe reads a written statement from an anonymous victim ('Jane Doe') who claims she knew Ghislaine Maxwell for over ten years. The statement alleges that Maxwell was the primary manipulator in charge, recruiting victims and delivering them to Jeffrey Epstein for abuse.
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This document is a Court Order from the Southern District of New York signed by Judge Alison J. Nathan on December 7, 2020, in the case of USA v. Ghislaine Maxwell. The order sets a briefing schedule for a renewed bail motion, establishes page limits for filings (40 pages for motion/response), and grants permission for the Government to file submissions under seal with redactions.
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This is page 2 of a legal filing from the US Attorney's Office for the SDNY regarding the detention conditions of Ghislaine Maxwell. The prosecutors argue that Warden Tellez should provide a first-hand accounting of why Maxwell is subject to strict surveillance measures (body scans, flashlight checks) despite 24/7 camera monitoring, noting that the MDC Legal Department would only provide second-hand information.
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This legal document is a letter dated November 23, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC), specifically that she was placed in quarantine after a staff member tested positive for COVID-19. The letter details that Maxwell tested negative, outlines the protocols for her quarantine including access to legal calls and discovery materials, and confirms she is being monitored by medical staff.
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This document is a court order from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). The Government requested to delay the disclosure of sensitive witness information to the defense to protect an ongoing investigation and encourage victim cooperation. Judge Alison J. Nathan granted the request for delay but rejected the Government's proposed timeline, ordering that the materials be produced by March 12, 2021, to ensure the defense can adequately prepare for trial.
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This legal document is a letter dated October 6, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution requests permission to delay the disclosure of sensitive evidence—photographs and documents of Jeffrey Epstein's sexual abuse victims—to Ghislaine Maxwell's defense team until eight weeks before trial. The government argues this is necessary to protect an ongoing investigation and sensitive victim information, while noting the defense objects to this request.
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This document is an affidavit of certification filed on October 6, 2020, by Assistant U.S. Attorney Maurene Comey in the case of U.S. v. Ghislaine Maxwell. Comey attests that the government attempted to negotiate with Maxwell's defense counsel to delay the disclosure of materials concerning victims of Jeffrey Epstein, but the defense refused to consent, leading to an inability to reach an agreement. The affidavit is filed pursuant to Local Criminal Rule 16.1 to certify this impasse to the court.
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This document is an official statement summarizing the FBI's conclusion that Jeffrey Epstein committed suicide in his cell at the Metropolitan Correctional Center on August 10, 2019. This finding is supported by video evidence showing no one entered his cell tier overnight and is consistent with previous findings from the NYC Chief Medical Examiner, the U.S. Attorney's Office, and the DOJ's Inspector General. The statement also provides links to the raw and enhanced video footage.
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This is a Property Release Order from the U.S. District Court for the Southern District of New York, filed on January 6, 2022. The order, signed by Judge Analisa Torres, directs the New York City Police Department to immediately return a firearm and other property to the defendant, Tova Noel. This action was taken in response to a letter application from Noel's attorney, Jason E. Foy, regarding property surrendered as a condition of bail.
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This is a Property Release Order from the U.S. District Court for the Southern District of New York, filed on January 5, 2022, in the case of United States v. Tova Noel. The order, signed by Judge Analisa Torres, directs the New York City Police Department to immediately return a firearm and other property to the defendant, Tova Noel. This property had been surrendered as a condition of her bail, and the order was granted based on a letter application from her attorney, Jason E. Foy.
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This legal document, filed on January 3, 2022, is a court order from the Southern District of New York for case 1:19-cr-00830-AT. It contains a directive from U.S. Attorney Damian Williams, dated December 13, 2021, to file a "nolle prosequi," effectively dropping the prosecution against defendants Tova Noel and Michael Thomas. The order is officially approved and signed by U.S. District Judge Analisa Torres on January 3, 2022.
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This is a 'Nolle Prosequi' filing from the United States District Court for the Southern District of New York, dated January 3, 2022. It formally dismisses the criminal case (19 Cr. 830) against Tova Noel and Michael Thomas, the correctional officers on duty when Jeffrey Epstein died. The dismissal follows their successful completion of a six-month deferred prosecution agreement entered into in May 2021, which required good behavior and community service.
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This is a legal document filed on December 30, 2021, in the Southern District of New York (Case 1:19-cr-00830-AT). United States Attorney Damian Williams directs that an order of 'nolle prosequi' (abandonment of prosecution) be filed regarding defendants Tova Noel and Michael Thomas, effectively dropping the charges related to Indictment 19 Cr. 830. The document includes a space for Judge Analisa Torres to order the action.
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This is a court order filed on December 10, 2021, in the case of United States v. Tova Noel and Michael Thomas (the guards on duty during Jeffrey Epstein's death). Judge Analisa Torres adjourned a status conference originally scheduled for December 16, 2021, at 1:00 p.m., moving it to 3:30 p.m. on the same day. The order specifies that proceedings will be held via videoconference due to COVID-19 protocols and provides dial-in information for the public and press.
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This document is the signature page (page 3 of 5) of a legal agreement filed on May 25, 2021, and dated May 20, 2021. The agreement stipulates that if the defendant successfully completes their term of supervision, the Government will move to dismiss the indictment. The document is signed by Assistant U.S. Attorney Jessica Lonergan on behalf of Audrey Struass, the U.S. Attorney for the Southern District of New York.
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This document is page 2 of a deferred prosecution agreement filed in May 2021 (Case 1:19-cr-00830-AT), likely concerning a Bureau of Prisons employee involved in the Epstein case (guards Tova Noel or Michael Thomas). The text outlines conditions of release, including mandatory cooperation with the FBI and DOJ-OIG regarding BOP activities, 100 hours of community service, and potential administrative termination of employment. The agreement allows for the deferral (and eventual dismissal) of prosecution if all conditions are met over a six-month period.
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