Eastern District
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EFTA00025188.pdf
This document is an email dated March 27, 2020, from an Assistant U.S. Attorney in the Southern District of New York to 'John' at raymitevlaw.com. The email acknowledges receipt of a letter dated March 9, 2020, concerning the Epstein investigation. The AUSA requests the identity of the source of the information to pass to the FBI and specifically asks if there are allegations that relevant 'interns' were underage.
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This document, labeled as page 8 of a larger filing (DOJ-OGR-00000208), discusses how the Department of Justice drafts plea agreements with a limited, single-district scope, meaning they typically only bind specific U.S. Attorney's Offices and not the entire Department or other authorities. It provides three examples of such plea agreement language from the Middle District of Alabama, Northern District of Alabama, and Eastern District of California, citing specific court cases and ECF filing numbers with dates in 2023 and 2024.
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This document is a page from a court transcript (Case 1:20-cr-00330-PAE, filed 12/10/21) detailing a legal argument regarding expert witnesses. The defense discusses the potential testimony of Mr. Kelso, noting it depends on the testimony of government witness Mr. Flatley, who will speak about metadata retrieved from devices seized at Epstein's home. Prosecutor Mr. Rohrbach responds that the government has provided ample notice and '3500 information' regarding Flatley's expected testimony.
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This document is a transcript from a legal proceeding where a speaker is arguing for bail for a defendant. The speaker cites several precedent cases (Esposito, Madoff, Dreier, Deutsch, Conway, and Mattis) to demonstrate that defendants in serious cases, including organized crime, massive financial fraud, and violent acts, have been granted release on bail conditions and have consistently appeared for trial. The argument aims to persuade the judge that release on conditions is appropriate in the current case as well.
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This document is a page from a court transcript (Page 45, filed on 04/01/2021) regarding a bail hearing. Defense counsel is arguing for the release of their client (implied to be Ghislaine Maxwell based on the case ID context), asserting that while the Crime Victims' Rights Act (CVRA) gives victims a voice, it does not give them a 'veto' over a defendant's right to release. The counsel cites Judge Orenstein's opinion in *United States v. Turner* (2005) to support the argument that victim objections regarding flight risk should not automatically deny bail.
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This legal document, dated February 28, 2023, is a page from a court filing that argues about the scope of plea agreements. It discusses whether a plea agreement made with a U.S. Attorney's Office (USAO) in one district can prevent prosecutions in other districts, citing several legal precedents like United States v. Alessi and United States v. Russo. The document uses Leslie Groff, an assistant to Epstein, as an example and analyzes factors such as whether other USAOs or the Department of Justice were involved in the negotiations.
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This page from a legal brief (Case 22-1426) argues points regarding the scope of plea agreements and Double Jeopardy. It analyzes the 'Abbamonte-Alessi rule' and the 'Annabi' precedent to determine if a plea agreement binding 'the Government' applies to other United States Attorney Offices (USAOs). The text argues that for charges to be distinct enough to bypass the rule, they must cover a new time period, noting that in the Annabi case, the conspiracy period was two years longer.
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This document is page 51 of a court transcript from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on December 10, 2020. The text captures an oral argument by the defense counsel advocating for the defendant's release on bail by citing various legal precedents (Esposito, Madoff, Dreier, Deutsch, Conway, and Mattis). The argument highlights that defendants in cases involving organized crime, massive financial fraud, sex crimes, and even violence (Molotov cocktail) were previously granted bail under strict conditions.
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This document is a page from a court transcript dated December 10, 2020, where an attorney argues for a client's release. The attorney cites a 2005 opinion by Judge Orenstein in *United States v. Turner* to support the argument that while victims have a right to be heard, this right does not constitute a veto over a defendant's release, especially when conditions can be set to ensure the defendant's appearance in court.
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This document is a page from a court transcript where the witness, Schoeman, is being questioned about his relationship with a lawyer named Theresa Trzaskoma. Schoeman explains that he met her around the year 2000 and they became family friends, and that he also had a prior professional connection to her husband from the law firm Paul Weiss. The witness confirms that Ms. Trzaskoma was a lawyer for David Parse during a trial.
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This document is page 12 (internal page 8) of a legal filing (Document 295) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on May 25, 2021. The text presents legal arguments regarding 'Double Jeopardy' and 'jeopardy attachment,' specifically analyzing when a defendant is considered to be at risk of conviction during pretrial dispositions and plea agreements. It heavily cites Second Circuit case law (Dionisio, Vanhoesen, Morris v. Reynolds) to argue that jeopardy does not attach to counts dismissed merely due to an agreement between parties without fact-based resolution.
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This legal document, filed on May 25, 2021, is a legal argument concerning the scope of plea agreements across different federal judicial districts. The author argues, based on Second Circuit precedent like Annabi, that a plea agreement from one district does not bind another unless explicitly stated. The document contrasts this with a broader interpretation from the Third Circuit (in United States v. Gebbie), which the defendant in the current case (Maxwell) is urging the court to adopt.
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This document is page 8 of a legal filing (Document 295) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on May 25, 2021. The text presents a legal argument by the prosecution distinguishing the current case from the precedent set in *Annabi*, *Abbamonte*, and *Alessi* regarding the Double Jeopardy Clause and plea agreements. The prosecution argues that Maxwell cannot claim Double Jeopardy protections because she was not previously prosecuted for the offenses listed in the S2 Indictment, and disputes her interpretation of the Non-Prosecution Agreement (NPA).
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This document is page 14 of a 78-page excerpt from a 2007 Utah Law Review article, likely authored by Paul Cassell, discussing the Crime Victims' Rights Act (CVRA). It argues for amending Federal Rules of Criminal Procedure (specifically Rule 1 and Rule 11) to align with the CVRA, quoting Senators Feinstein and Kyl on the Act's intent to reform the legal culture surrounding victims' rights. The document bears a footer for attorney David Schoen and a House Oversight Committee Bates stamp, suggesting it was part of the congressional investigation into the handling of the Epstein case (where the CVRA was a central legal issue).
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This document contains a log of electronic messages exchanged on November 21, 2018, between Jeffrey Epstein (using the email alias jeeitunes@gmail.com) and a redacted individual. The conversation focuses on the legal standing of 'djt' (Donald Trump) regarding the Mueller investigation, with the redacted party relaying a third party's legal opinion that obstruction charges are unlikely but financial issues in the 'southern eastern district' pose a risk. Epstein reacts positively to the news regarding the Mueller investigation, calling it 'Epic'.
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This document is page 2 of 5 from an interview with white-collar defense attorney Reid Weingarten. He discusses his criteria for accepting or declining clients, the issue of conflicts of interest in law firms, and his assessment of various federal prosecutor offices, specifically highlighting the Southern District of New York as the most formidable.
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