S.D.N.Y.
OrganizationRelationship Network
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Epstein's lawyers
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This document is page 22 of a court order (Document 657) filed on April 29, 2022, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The page outlines the 'Applicable Law' regarding the Fifth Amendment's Grand Jury Clause and 'prejudicial variance' or 'constructive amendment' of an indictment. It cites various legal precedents (Second Circuit cases) to define the standards for determining if a defendant was convicted of a crime different from the one charged in the indictment. The Court denies the Defendant's motion on this basis.
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This page from a legal document details the legal framework used by the Second Circuit to determine if multiple charges constitute a single conspiracy, which is relevant to double jeopardy claims. It lists the eight "Korfant factors" and explains the burden-shifting process where a defendant must first make a non-frivolous claim, after which the burden shifts to the government to prove the conspiracies are distinct. The text relies heavily on citations to previous court cases to establish these legal standards.
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This document is page 5 of a 45-page legal filing (Document 657) from the Ghislaine Maxwell case (1:20-cr-00330-AJN), filed on April 29, 2022. It outlines the 'Applicable law' regarding the Double Jeopardy Clause of the Fifth Amendment, specifically discussing 'multiplicitous' indictments and how courts determine if multiple conspiracy charges constitute the same offense. It cites various Second Circuit and Supreme Court precedents to establish the legal standard for reviewing such claims.
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This document is page 2 of a legal letter addressed to Judge Alison J. Nathan dated December 27, 2021, regarding the trial of Ms. Maxwell. It argues that without specific jury instructions, there is a risk of 'constructive amendment' or 'prejudicial variance' from the S2 Indictment, citing case law (Gross, D'Amelio, Wozniak) to define the constitutional protections against convicting a defendant on charges not specified in the indictment.
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This document is a page from a court order in the case of United States v. Ghislaine Maxwell (part of appeal record Case 22-1426). The Judge denies Maxwell's motion to compel the immediate disclosure of prior statements by 'Minor Victim-4' in which the victim allegedly did not mention Maxwell. The Court rules that the Government's deadline of October 11, 2021, for Jencks Act and Giglio material is sufficient and that the Government understands its Brady obligations regarding exculpatory evidence.
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This legal document is a court order addressing a discovery request from the defendant, Maxwell, concerning evidence under Federal Rule of Evidence 404(b). The Court considers the Government's proposal to disclose this evidence 45 days before trial to be reasonable and denies Maxwell's request for earlier disclosure. However, the Court encourages the parties to negotiate a final schedule and concludes that disclosure six to eight weeks before trial would be appropriate.
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This document is page 31 of a court order filed on April 16, 2021, in the case against Ghislaine Maxwell. The court discusses the timeline for the Government to produce a witness list, noting that while Maxwell faces challenges due to the 'decades-old allegations,' the Government's proposal to provide information six weeks in advance is reasonable. The text also notes that on April 13, 2021, the Government produced over 20,000 pages of discovery materials related to non-testifying witnesses.
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This document is page 22 of a court ruling (Document 207) filed on April 16, 2021, in the case United States v. Maxwell. The court is denying Maxwell's motion to dismiss perjury counts, arguing that the ambiguity of questions and the materiality of her statements are issues of fact for a jury to decide, not grounds for pretrial dismissal. The text cites legal precedents regarding perjury, materiality in civil depositions, and the role of the jury.
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This legal document is a page from a court filing in the case against Maxwell, dated April 16, 2021. The court addresses and rejects several of Maxwell's arguments that the indictment is impermissibly vague, specifically concerning the lack of precise dates for the alleged abuse, the inclusion of noncriminal conduct, and the omission of victims' names. The court cites legal precedents to affirm that the indictment is sufficient, particularly in cases involving the sexual abuse of children where victims may struggle to recall exact dates.
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This document is a court docket entry from February 28, 2023, for Case 22-1426, primarily concerning Ghislaine Maxwell. It details court orders and filings from November 2021, including COVID-19 protocols for courthouse access, scheduling revisions for motions in limine, and a pretrial conference. The entries highlight communications between the prosecution (USA) and defense (Ghislaine Maxwell's attorneys) regarding trial logistics and a ruling on witness testimony, all overseen by Judge Alison J. Nathan.
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This document is a page from a court docket in the case of Ghislaine Maxwell, dated February 22, 2023, but detailing events from July 2020. It includes an order from Judge Alison J. Nathan regarding public and press access to hearings, followed by a list of filings such as attorney appearances and motions. The key event is a minute entry for Maxwell's arraignment on July 14, 2020, where she pleaded not guilty via video conference, was denied bail, and had a trial date set for July 12, 2021.
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This document, dated February 28, 2023, details court orders and filings from July 2020 concerning Ghislaine Maxwell's case. It outlines the scheduling of her remote arraignment, initial conference, and bail hearing for July 14, 2020, including protocols for video appearances, public access, and COVID-19 courthouse entry requirements. The document also references letters from both defense and prosecution counsel regarding scheduling and highlights crime victims' rights under 18 U.S.C. § 3771.
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This document is a court docket page from the case USA v. Ghislaine Maxwell (Case 22-1426) covering proceedings from November 10-11, 2021. It details a pretrial conference attended by Maxwell and her legal team, scheduling orders for voir dire (jury selection), and rulings on motions in limine regarding expert testimony on grooming. The document also outlines strict COVID-19 protocols for the courthouse and notes the denial of a defense motion to exclude specific expert testimony.
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This document is a docket sheet from July to August 2021 detailing legal maneuvers in the case against Ghislaine Maxwell. Significant entries involve a dispute over an Op-Ed written by attorney David Oscar Markus, leading to a court order enforcing Local Criminal Rule 23.1 regarding extrajudicial statements to protect the integrity of the trial. Additionally, the defense filed motions referencing the 'Cosby Opinion' and sought to suppress evidence obtained from a subpoena to the law firm Boies Schiller.
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This document is a page from the court docket for United States v. Ghislaine Maxwell, covering proceedings on November 10 and 11, 2021. It details the scheduling of voir dire, COVID-19 courtroom protocols, and rulings on motions in limine, including the denial of a defense motion to exclude expert testimony on grooming. It also lists the attorneys present for both the prosecution and defense during a pretrial conference.
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This document is a court docket summary from July and August 2021 for the case of Ghislaine Maxwell, presided over by Judge Alison J. Nathan. It details a series of filings, including letters from Maxwell's counsel and motions from the U.S. government. A significant event is the court's order addressing an op-ed written by attorney David Markus, which led to him being ordered to comply with local rules regarding extrajudicial statements that could prejudice a trial.
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This document is page 15 of a legal filing dated August 11, 2025, discussing the Government's motion to unseal grand jury materials related to Ghislaine Maxwell based on 'special circumstances' and public interest in the Epstein investigation. It references a July 6, 2025 Memorandum regarding the Government's review of the investigation and notes that a separate court in the Southern District of Florida recently denied a similar motion on July 23, 2025.
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This page from a court filing argues that the court has the inherent authority to suppress evidence obtained through government misrepresentation. It cites multiple legal precedents to support the claim that sanctions can be applied even if the misconduct occurred in a different venue, provided it is related to the current case.
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This legal document is a preliminary statement arguing that Ghislaine Maxwell's Sixth Amendment rights were violated. The defense claims the government, rushing to meet a self-imposed July 2, 2020 deadline, improperly used a grand jury from the White Plains Division instead of the Manhattan Division, where the alleged crimes occurred. This resulted in a grand jury pool that significantly underrepresented Black and Hispanic residents, thus denying Maxwell her right to be indicted by a jury drawn from a fair cross-section of the community.
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This document is a preliminary statement from a legal motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell. The defense argues that the government violated Maxwell's Sixth Amendment rights by using a grand jury from the White Plains Division rather than the Manhattan Division, allegedly to rush the indictment to coincide with the July 2 anniversary of Jeffrey Epstein's indictment. The defense claims this excluded a fair cross-section of the community, specifically underrepresenting Black and Hispanic residents, despite a Manhattan grand jury being available as early as June 25, 2020.
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This legal document, filed on January 25, 2021, argues that the indictment against Ms. Maxwell lacks sufficient specificity regarding the alleged crimes and the identities of accusers/victims. It contends that the open-ended time periods and vague descriptions of 'minor girls' or 'victims' in the indictment make it impossible for Ms. Maxwell to prepare an adequate defense or apply the statute of limitations. The document cites legal precedents to support the argument for greater specificity in criminal charges.
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This document is page 9 of a legal filing (Document 120) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on January 25, 2021. The text argues legal standards for the 'Severance of Offenses,' citing Federal Rule of Criminal Procedure 14 and various precedents regarding when charges should be tried separately to avoid prejudice to the defendant. It lists numerous case citations including U.S. v. Mitan, U.S. v. Bradford, and U.S. v. Burke to support the argument that misjoined counts must be severed.
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This document is page 9 of a legal filing (Document 120) from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on January 25, 2021. The text presents legal arguments regarding the 'Severance of Offenses' under Federal Rule of Criminal Procedure 14, citing various precedents to argue that counts should be severed if joinder prejudices the defendant. It discusses the legal standards for 'misjoinder' and 'substantial prejudice' required to grant a motion to sever.
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This document is page 8 of a legal filing (Document 120) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on January 25, 2021. The text presents legal arguments and case citations regarding the severance of charges and 'joinder,' specifically arguing that perjury counts should not be joined with substantive crimes if they are not sufficiently connected physically, temporally, or transactionally. The document cites precedents such as *United States v. Rivera*, *Randazzo*, and *Potamitis* to support the argument that unrelated offenses should be tried separately.
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This document is page 'ii' (3 of 19) of a legal filing from January 25, 2021, related to Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It is a 'Table of Authorities' section listing various legal precedents (cases) cited in the main document, including United States v. Halper and United States v. Burke. The document bears a Department of Justice Bates stamp 'DOJ-OGR-00002281'.
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