SOUTHERN DISTRICT OF NEW YORK

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Also known as:
Southern District of New York (implied by reporter name) Southern District of New York Office

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DOJ-OGR-00009628.jpg

This legal document is a letter dated March 7, 2022, from the U.S. Department of Justice's Office of the Assistant Attorney General to Damian Williams, the U.S. Attorney for the Southern District of New York. The letter grants authorization to seek a court order to compel a witness, whose name is redacted, to testify in the criminal case against Ghislaine Maxwell. This order would provide the witness with immunity, overcoming any refusal to testify based on the privilege against self-incrimination.

Legal document
2025-11-20

DOJ-OGR-00009627.jpg

This document is a legal filing from the Southern District of New York, signed by US Attorney Damian Williams on March 7, 2022. It requests the Court to issue an order compelling a redacted individual to testify at a March 8, 2022 hearing in the case of United States v. Ghislaine Maxwell. The request is made pursuant to Title 18, United States Code, Sections 6002 and 6003, which typically relate to granting immunity to witnesses to compel testimony.

Legal filing / court motion
2025-11-20

DOJ-OGR-00009626.jpg

This legal document is an application filed on March 7, 2022, by the U.S. Attorney for the Southern District of New York in the case of United States v. Ghislaine Maxwell. The application requests a court order to grant immunity to and compel the testimony of a witness, whose name is redacted, for a hearing scheduled on March 8, 2022. The witness had previously refused to testify, invoking their privilege against self-incrimination.

Legal document
2025-11-20

DOJ-OGR-00009614.jpg

This legal document is a letter dated March 1, 2022, from attorney Todd A. Spodek of Spodek Law Group to District Judge Alison J. Nathan. The letter concerns the case of United States v. Ghislaine Maxwell in the Southern District of New York. Spodek informs the court that his client, identified only as Juror 50, will invoke their Fifth Amendment privilege against self-incrimination at a court-ordered hearing scheduled for March 8, 2022.

Legal document
2025-11-20

DOJ-OGR-00009613.jpg

This is the conclusion and signature page of a legal filing by the United States Attorney for the Southern District of New York (Case 1:20-cr-00330-PAE). The Government submits that the Court should grant the defendant's motion regarding 'Count One' but deny all other post-trial motions. The document is dated February 25, 2022, and signed by US Attorney Damian Williams and four Assistant US Attorneys.

Legal filing (court motion conclusion/signature page)
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

DOJ-OGR-00009563.jpg

This document is the cover page for the Government's Memorandum in Opposition to Ghislaine Maxwell's Omnibus Post-Trial Motions, filed on February 25, 2022, in the Southern District of New York (Case 1:20-cr-00330). It lists Damian Williams as the U.S. Attorney and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach as Assistant U.S. Attorneys.

Legal filing (government memorandum)
2025-11-20

DOJ-OGR-00009544.jpg

This document is Page 3 of a court filing (Document 620) from February 25, 2022, in the Ghislaine Maxwell case (1:20-cr-00330). It details the discovery that 'Juror 50' gave media interviews admitting to being a sexual abuse victim despite denying it on his juror questionnaire, leading the Defendant to file a motion for a new trial. The document also chronicles communications between Juror 50 and the SDNY Jury Department/District Executive in January 2022, where the juror sought legal guidance and access to his questionnaire.

Court filing / order
2025-11-20

DOJ-OGR-00009542.jpg

This document is an Opinion & Order from the U.S. District Court for the Southern District of New York in the case of United States v. Ghislaine Maxwell. Judge Alison J. Nathan denies the Defendant's motion for a new trial based on the current record, which alleged misconduct by 'Juror 50'. However, the Court agrees to a limited evidentiary hearing to determine if Juror 50 provided a materially false answer on a jury questionnaire.

Legal document
2025-11-20

DOJ-OGR-00009539.jpg

This is the final signature page (page 3) of a court filing (Document 617) from the case USA v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on February 24, 2022. The US Attorney's office argues that because Juror 50 has already spoken publicly, no redactions are justified for a specific motion, which should be docketed. The document is signed by US Attorney Damian Williams and AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach.

Court filing (signature page / conclusion)
2025-11-20

DOJ-OGR-00009537.jpg

This document is a letter dated January 13, 2022, from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the case *United States v. Ghislaine Maxwell*. The Government argues that a motion filed by Counsel for Juror 50 to intervene and obtain jury selection materials should be filed publicly without redactions, countering the defendant's objection that it is not a judicial document. The document references a previous court order from January 12, 2022, and cites legal precedent regarding public access to judicial documents.

Legal correspondence / court filing (letter to judge)
2025-11-20

DOJ-OGR-00009527.jpg

This document is an Amended Sentencing Memorandum filed by the United States on March 18, 2013, regarding defendant David Parse. It outlines the procedural history, noting Parse's conviction on May 24, 2011, for obstructing IRS laws and mail fraud following an eleven-week trial involving 'one of the largest tax fraud schemes ever charged.' The document appears to be part of a larger case file (possibly related to the Jenkens & Gilchrist tax shelter case) that may have been included in a larger document production.

Court filing (amended sentencing memorandum)
2025-11-20

DOJ-OGR-00009525.jpg

This document is the cover page for an Amended Sentencing Memorandum filed by the United States (via US Attorney Preet Bharara) regarding defendant David Parse in the case *United States v. Paul Daugerdas, et al.* (S3 09 Cr. 581). Originally filed on March 18, 2013, this specific copy was submitted as Exhibit A-6074 on February 24, 2022, in the Ghislaine Maxwell case (1:20-cr-00330-AJN), likely as legal precedent or background material.

Legal pleading / sentencing memorandum
2025-11-20

DOJ-OGR-00009480.jpg

This document is a page from a court transcript filed on February 24, 2022, as part of a larger filing (Case 1:20-cr-00330-PAE, which corresponds to the Ghislaine Maxwell case). However, the content of the transcript records proceedings for 'United States of America v. David Parse,' where attorney Paul Shechtman argues for a new trial based on 'ineffective assistance of counsel.' This transcript was likely submitted in the Maxwell case as legal precedent or an exhibit regarding standards for new trials.

Court transcript (exhibit)
2025-11-20

DOJ-OGR-00009476.jpg

This is an affidavit from David Parse, a defendant in case S3 09 Cr. 581 in the Southern District of New York, filed on August 7, 2012. Parse states that he only became aware of a potential issue regarding a juror named Conrad being a suspended lawyer after his legal team, the Brune firm, had already filed a motion for a new trial. He specifies learning this information after a conference call on July 15, 2011, and recalls his lawyer, Theresa Trzaskoma, had previously dismissed a concern about a prospective juror having the same name during jury selection.

Legal document
2025-11-20

DOJ-OGR-00009447.jpg

This document is the first page of a legal declaration by Stephen Gillers, a law professor and expert in legal ethics, filed on April 6, 2012, in the U.S. District Court for the Southern District of New York. Gillers outlines his extensive qualifications and states that he has been asked by the court to provide an opinion on whether the attorneys for clients named Bruce and Richard fulfilled their ethical obligations regarding the potential failure to disclose a letter and an investigation concerning 'Juror No. 1' during March, May, and July of 2011.

Legal document
2025-11-20

DOJ-OGR-00009428.jpg

This document is a court transcript from a case filed on February 24, 2012, detailing the direct examination of witness Barry H. Berke. Mr. Berke, a partner at the law firm Kramer, Levin, Naftalis & Frankel, outlines his legal career, including his time as a judicial clerk, a lawyer with the Federal Defenders, and a professor at NYU. He also confirms his prior involvement as a lawyer in a trial concerning the defendant, David Parse.

Legal document
2025-11-20

DOJ-OGR-00009411.jpg

This document is a page from a transcript of testimony given by an individual named Edelstein. The testimony concerns the drafting of a legal brief and whether the legal team knowingly omitted information regarding a suspended lawyer named Catherine Conrad prior to voir dire (jury selection). The witness explains their focus was on establishing identity rather than waiving rights regarding juror misconduct.

Legal transcript / court testimony
2025-11-20

DOJ-OGR-00009365.jpg

This document is a page from a court transcript (Case 1:20-cr-00330-AJN) filed on February 24, 2022. A witness named Brune is testifying about a July 22nd phone call with the Judge regarding the identification of jury consultants, specifically mentioning Mr. Donohue, Julie Blackman, and Mr. Schoeman. The testimony clarifies that Mr. Nardello performed investigative work but was not a jury consultant.

Court transcript (testimony)
2025-11-20

DOJ-OGR-00009355.jpg

Transcript from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE) proceedings, specifically the questioning of Ms. Brune regarding the vetting of Juror 'Conrad'. Ms. Brune testifies about the distinction between a 'database search' and a full 'investigation' conducted by her team (including Benhamou, Kim, and Stapp) on May 12th. The testimony highlights a disconnect in the legal team's knowledge, admitting that Ms. Trzaskoma knew about specific email traffic that Ms. Brune was unaware of when she filed a brief stating there was no basis to question the juror's honesty.

Court transcript / testimony
2025-11-20

DOJ-OGR-00009308.jpg

This document is a page from a court transcript (Case 1:20-cr-00330) featuring the direct examination of a witness named Brune. The testimony covers Brune's professional background, specifically leaving the U.S. Attorney's Office in the Southern District of New York in November 1997 to start the law firm Brune & Richard with Hillary Richard in February 1998. The witness confirms that while Hillary Richard has done criminal cases, she is primarily a civil lawyer.

Court transcript (direct examination)
2025-11-20

DOJ-OGR-00003183.jpg

This page from a DOJ OPR report details the timeline following Jeffrey Epstein's August 2019 suicide, including the dismissal of his indictment in SDNY and the conclusion of CVRA litigation in Florida where the court found the government had not litigated in bad faith but had violated the CVRA. It summarizes the appellate history of 'Jane Doe 1' seeking a writ of mandamus in the 11th Circuit regarding the non-prosecution agreement (NPA). Additionally, it marks the initiation of the OPR investigation into DOJ attorney misconduct, triggered by a request from Senator Ben Sasse following the Miami Herald's November 2018 reporting.

Government report / court exhibit (doj opr report)
2025-11-20

DOJ-OGR-00003138.jpg

This document is a page from a legal filing, dated April 16, 2021, arguing against the misuse of a 'bill of particulars'. It cites numerous court cases to establish the legal precedent that a bill of particulars is not a tool for the defense to compel the Government to disclose its evidence, witnesses, or trial strategy. The document asserts that such a bill is only warranted when an indictment is so vague that it prevents the defendant from preparing a defense.

Legal document
2025-11-20

DOJ-OGR-00003130.jpg

This document is page 196 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues for the admissibility of evidence regarding 'Minor Victim-3' to demonstrate the defendant's intent and modus operandi, citing legal precedents (McDarrah, Brand). It also argues that the defendant's motion to dismiss Counts One or Three based on multiplicity is premature under Second Circuit precedent.

Legal filing (court document)
2025-11-20

DOJ-OGR-00003067.jpg

This document is page 133 of a legal filing (Document 204) in the case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It presents legal arguments and case law precedents regarding government misconduct, specifically the high burden required to prove 'outrageous' government conduct that would warrant dismissal of an indictment. The text argues that relief is only appropriate if the misconduct prejudiced the defense, and that suppression of evidence is the standard remedy rather than dismissal.

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