the defense
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This document is a page from a court transcript filed on August 10, 2022, related to Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). The Judge is addressing a government request regarding the testimony of a witness using the pseudonym 'Kate.' The Judge notes that while Kate alleges sexual conduct with Jeffrey Epstein, she was over the age of consent at the time and is not a victim of the specific crimes charged in this indictment. However, her testimony is deemed relevant to Mann Act counts and 404(b) evidence. The Judge rules that her testimony regarding sexual details will be limited to avoid prejudice and that the jury will be instructed that the Court prohibited asking for those specific details.
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This document is page 6 of a court order filed on December 9, 2021, in the case United States v. Ghislaine Maxwell. The Court overrules the Defense's objections to the admission of a 'directory' (contact book) on both authentication and hearsay grounds. The Judge cites Second Circuit precedents (Al-Moayad, Londono) to establish that address books can be admitted for the non-hearsay purpose of linking the possessor of the document to the names listed within, rather than proving the accuracy of the contact details.
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This document is page 64 of a court transcript from July 24, 2019, related to Case 1:19-cr-00490-RMB. A prosecutor is arguing before the judge ('Your Honor') regarding the legal presumption (likely for detention) and rebutting defense arguments that a lack of recent convictions or charges (specifically regarding obstruction or witness tampering) should work in the defendant's favor. The speaker emphasizes that Congress intended for sex crimes against children to carry lifelong liability.
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This document is a page from a court transcript (likely the sentencing hearing) for Ms. Maxwell. The judge rejects the defense's claim that Maxwell is indigent, citing her previous report of $22 million in assets and a lack of documentation regarding her marriage or divorce settlement, and states an intention to impose a fine. The judge also notes that the government is not seeking restitution and prepares to discuss sentencing guidelines after a lunch break.
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This legal document is a court transcript page where a judge explains their reasoning for rejecting a defense proposal regarding how to answer a jury's question about 'Count Four'. The judge found the proposal unhelpful and reiterated the need for the jury to consider the full legal instruction. The judge also formally places on the record their decision from the previous day to extend the jury's deliberation schedule by one hour.
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This document is page 2 of a court transcript from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on August 10, 2022. Prosecutor Ms. Moe addresses the Court in the absence of the jury, first noting a safety caution regarding an open door to the jury room. She then argues against a defense letter filed earlier that morning, stating it repeats arguments regarding jury instructions that the Court had already rejected the previous day.
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This document is a page from a Government court filing (Case 1:20-cr-00330-AJN, likely USA v. Maxwell) dated December 18, 2020. It addresses defense complaints regarding discovery access, noting that one hard drive malfunctioned because the defendant dropped it, and details her special confinement conditions at the MDC, which include 13 hours out of cell, private shower, computers, phone, and TV. A footnote highlights a contradiction in the defense's arguments regarding the value of discovery versus the prejudice caused by delays.
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This legal document, part of Case 1:20-cr-00330-PAE, addresses the defense's arguments against a motion, asserting that the Government's actions are not merely tactical but aimed at protecting victims. It emphasizes the importance of privacy safeguards for Minor Victims, including the use of pseudonyms and the sealing of exhibits containing identifying information, while maintaining public and press access to the trial and most evidence.
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This is page 13 of a legal filing (Document 383) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The visible text discusses 'Minor Victim-4,' arguing that the defense's attempts to attack her credibility based on statements made to the USAO-SDFL are irrelevant to her privacy interests regarding her upcoming testimony. Large portions of the page are redacted.
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This page is from a legal filing (Document 380) in the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on October 29, 2021. It contains a Government argument (Section A) requesting the Court preclude the Defense from presenting evidence regarding government charging decisions. The text cites Federal Rules of Evidence 402 and 403 and case law (Rosado, Borrero) to argue that such evidence is irrelevant, hearsay, and likely to confuse the jury.
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This document is a page from a Government legal filing (dated Oct 29, 2021) in the case against Ghislaine Maxwell. The Government rebuts defense accusations regarding discovery violations, stating they provided co-conspirator statements 'unusually early' (seven weeks before trial). Additionally, the Government argues against suppressing the identification of the defendant by 'Minor Victim-4,' asserting that the victim knew the defendant personally for decades.
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This document is a page from a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It details procedural disputes regarding the timing of the Government's disclosure of co-conspirator statements to the defense. The Court ruled that the Government's commitment to produce these statements six weeks before trial (alongside Jencks Act and Giglio materials) was sufficient, denying the defense's request for earlier identification.
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This document is page 18 of a legal filing (Document 148) in Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on February 4, 2021. The text constitutes 'Section V. Motion for Accelerated Disclosure of Witness Statements,' where the defense argues they need early access to Jencks Act material to prepare for trial. They cite the age of the allegations (25 years), the lack of electronic records from that era, the location of witnesses in foreign countries, and the logistical difficulties posed by the COVID-19 pandemic as reasons for the request.
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This is Page 3 of a legal filing (Document 351) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 15, 2021. The Government argues that the Defense's proposed deadline of November 15, 2021, for filing Rule 412 motions (concerning the admissibility of evidence regarding a victim's sexual behavior) is too close to trial, specifically conflicting with jury selection and the Thanksgiving holiday. The Government requests an earlier deadline to ensure victims have sufficient notice and the Court has time to resolve sensitive issues.
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This page from a court transcript (case 1:20-cr-00330-PAE) details sentencing proceedings for Ms. Maxwell. The Judge rejects the claim that Maxwell is indigent, citing $22 million in assets reported in 2020 and a lack of documentation regarding her marriage/divorce, and states an intention to impose a fine. The Judge also notes the government is not seeking restitution, finds no grounds for downward departures from sentencing guidelines, and calls for a lunch break.
Reconsideration of Court's response
Seeking reconsideration and raising possibility of constructive amendment or prejudicial variance. Asking for additional instruction.
Justification for sealing juror questionnaire
A letter mentioned in the document where the defense speculates that media coverage may prejudice the jury selection process.
Jencks Act materials
Detailed notes and reports of the Government’s interviews of the witness referenced in the letter.
Notice of resting case
The government warned the defense that they would rest their case.
Production of unredacted reports
The defense asked the government to produce unredacted copies of two FBI reports. The government responded that it had not applied the redactions and produced the documents as obtained.
Witness Statements
Disclosures corresponding to the Oct 11 letter.
Followup letter regarding jury's last note
Taking a slightly different approach to the jury's last note than what was argued in court.
Seeking testimony at trial
Defense served a subpoena on the attorney representing Minor Victim 4.
Testimony at trial
The defense served a subpoena on the attorney for Minor Victim 4, seeking his testimony at the trial.
Modification of previous juror strikes
The defense communicated its desire to modify its previous strikes, specifically wanting to move three jurors from the 'agreed to proceed to voir dire list' to the 'defense objects to proceeding to voir dire list'.
Modification of previous juror strikes
The defense communicated its desire to modify its previous strikes, specifically wanting to move three jurors from the 'agreed to proceed to voir dire list' to the 'defense objects to proceeding to voir dire list'.
Touhy letter requesting testimony
A letter from the defense requesting testimony from case agents concerning the scope, timeline, and steps of prior investigations.
Response to jury question
The defense made a suggestion on how to answer the jury's question, proposing to either point to the 'motivating factor' language or simply say 'no'. The judge rejected this proposal.
Verification of invoices
The defense sent 'several hundred' invoices to the witness (Chapell) for verification against archived records.
Application for release of Mr. Epstein
The speaker refers to a letter application from the defense for the release of Mr. Epstein, specifically referencing page 6.
Content of the notice letter
Exchanges between Villafaña and Epstein's defense team concerning the content of the victim notification letter prior to it being sent.
Supplemental Instruction for Count Four
Proposed language clarifying that intent must relate to activity within New York state.
Availability of an item for inspection
Ms. Moe states, 'We notified the defense in a letter that it was available for inspection.'
Invoices for verification
Sending several hundred invoices to be verified against archived records.
Justification for sealing juror questionnaire
A letter mentioned in the document where the defense speculates that media coverage may prejudice the jury selection process.
Request to ask Juror 50 specific questions
Defense requests the Court ask Juror 50 questions regarding his prior knowledge of the case and personal history of abuse.
Discovery Material
A large volume of electronically-stored information.
anticipated witnesses
The Court acknowledges receipt of a letter from the Defense dated December 13, 2021, concerning anticipated witnesses.
Defense witness list
The defense sent a letter to the Government on Friday evening (December 10, 2021, based on the filing date) identifying thirty-five defense witnesses in alphabetical order.
Response to government's request for admission of photogr...
The defense filed a response on December 5th to the government's letter regarding the admission of photographs.
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