S.D.N.Y.
OrganizationRelationship Network
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Epstein's lawyers
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Legal representative |
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DOJ-OGR-00002245(1).jpg
This is page 13 of a court order filed on December 30, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The court is analyzing the defendant's flight risk, concluding that her French citizenship, potential to flee to Israel, and extraordinary financial resources justify continued detention. The judge argues that anticipatory extradition waivers are insufficient because the defendant could still frustrate or delay the extradition process.
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This is page 2 of a court order filed on December 23, 2020, in Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell). Judge Alison J. Nathan orders the defendant to docket redacted documents related to a renewed motion for bail by the same day, citing case law that supports redactions to protect third-party privacy interests.
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This document is page 29 of a legal filing (Document 100) from December 18, 2020, in the case United States v. Ghislaine Maxwell (identified by case number). The text presents the prosecution's argument against granting bail, citing the defendant's wealth, foreign ties, and skill at hiding as flight risks. It argues that a 'privately funded jail' and GPS monitoring are insufficient to ensure appearance in court, citing legal precedents (Banki, Zarger, Benatar) to support the claim that electronic monitoring merely reduces a head start rather than preventing flight.
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This legal document, filed on December 18, 2020, argues that an unnamed defendant, who is a French citizen, would be completely protected from extradition to the United States if she were to flee to France. The argument is supported by direct communication from the French Ministry of Justice, which confirmed France's inflexible principle of not extraditing its citizens outside the European Union, and is further bolstered by a legal precedent from the 2013 case, United States v. Cilins.
DOJ-OGR-00002171.jpg
This page is from a legal filing dated December 18, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), though the defendant is not explicitly named in the body text. The text outlines legal arguments regarding pre-trial detention, citing the Bail Reform Act and specific statutes (18 U.S.C. §§ 2422, 2423) related to sex offenses involving minors, which create a presumption of detention. It discusses the legal standards for reopening a detention hearing and the burden of proof regarding flight risk, citing precedents from the Second Circuit and S.D.N.Y.
DOJ-OGR-00002171(1).jpg
This page is from a legal filing dated December 18, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), though the defendant is not explicitly named in the body text. The text outlines legal arguments regarding pre-trial detention, citing the Bail Reform Act and specific statutes (18 U.S.C. §§ 2422, 2423) related to sex offenses involving minors, which create a presumption of detention. It discusses the legal standards for reopening a detention hearing and the burden of proof regarding flight risk, citing precedents from the Second Circuit and S.D.N.Y.
DOJ-OGR-00001976.jpg
This document is page 4 of a court filing (Document 97) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-AJN), filed on December 14, 2020. It is a 'Table of Authorities' listing various legal precedents (United States v. Boustani, Bradshaw, Chen, etc.) cited elsewhere in the filing. The page is numbered 'iii' and bears the Bates stamp DOJ-OGR-00001976.
DOJ-OGR-00001833.jpg
This document is a page from a government filing in the case against Ghislaine Maxwell, outlining the charges in the indictment and discussing the production of discovery materials. The government argues for the delayed disclosure of certain sensitive materials related to Epstein victims not testifying at trial to protect ongoing investigations.
DOJ-OGR-00022102.jpg
This document is page 6 of a court filing from June 9, 2020, in the case against Thomas (likely regarding Epstein's guards). The Court denies the defendant's request to compel the Government to disclose evidence underlying an Office of Inspector General (OIG) report, accepting the Government's representation that no additional Brady material exists and that the OIG report is not yet drafted. The text cites various legal precedents regarding Rule 16 and Brady obligations.
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This document is page 5 of a court order filed on June 9, 2020, in Case 1:19-cr-00830-AT. It discusses legal precedents regarding 'joint investigations' and discovery obligations (Brady/Giglio/Rule 16). Specifically, it addresses a request by defendant Thomas for the disclosure of materials from the DOJ Office of the Inspector General (OIG) investigation into Jeffrey Epstein's death, noting that the Government concedes OIG attorneys participated in the investigation leading to Thomas's indictment.
DOJ-OGR-00022089.jpg
This page is from a legal filing (Case 1:19-cr-00830-AT) dated April 24, 2020, arguing against a motion by defendant Thomas (likely Michael Thomas, a guard involved in the Epstein case) to disclose draft versions of an Inspector General's Report regarding the Bureau of Prisons (BOP). The text argues that such drafts do not yet exist and, even if they did, would be protected by the 'deliberative process privilege.' The document cites numerous legal precedents to support the claim that pre-decisional government documents are shielded from discovery.
DOJ-OGR-00022084.jpg
This is page 22 of a legal filing (Document 35) from Case 1:19-cr-00830-AT (United States v. Ghislaine Maxwell), filed on April 24, 2020. The text outlines legal arguments and precedents regarding the Government's obligation (under Rule 16 and Brady) to review and produce records held by other agencies. It cites multiple cases to establish that the prosecution is not required to search other agencies' records (such as the SEC, PCAOB, or FAA) unless a 'joint investigation' was conducted with that specific agency.
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This document is page 19 of a legal filing (Document 35) from case 1:19-cr-00830-AT, filed on April 24, 2020. It contains the Government's legal argument opposing discovery requests made by the defendant, Thomas (likely Michael Thomas, a guard involved in the Epstein jail case). The Government argues that Thomas's requests are irrelevant to the charges and are instead an attempt to 'garner sympathy' and argue 'jury nullification,' citing various legal precedents to support the exclusion of such evidence.
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This document is page 12 of a legal filing (Case 1:19-cr-00830-AT) dated April 9, 2020, related to defendant Michael Thomas (one of the guards charged in connection with Jeffrey Epstein's death). The text argues that Michael Thomas is entitled to the complete Inspector General's Report under Federal Rule of Criminal Procedure 16(a)(1)E, citing various legal precedents (Armstrong, Rigas, McGuinness, Giffen) to define 'material' evidence necessary for defense preparation.
DOJ-OGR-00021999.jpg
This document is page 2 of a government legal filing dated January 28, 2020, arguing against a defense request to adjourn the trial. The text references defendants 'Thomas' and 'Noel' (likely the guards on duty during Epstein's suicide), stating that the case revolves around a 'brief, fourteen-hour window' and is not complex enough to warrant a six-month delay. The government asserts it has already provided witness statements (3500 material) well in advance and notes that no search warrants were obtained nor did defendants make post-arrest statements.
DOJ-OGR-00021930.jpg
This legal document, filed on November 19, 2019, in the Southern District of New York, outlines the bail conditions for defendant Tova Noel. She was released on a $100,000 personal recognizance bond with several conditions, including travel restrictions, surrender of travel documents, and a specific prohibition against contacting her co-defendant without counsel present. The document also schedules future court dates, including a conference on November 25, 2019, and a preliminary hearing on December 19, 2019.
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This document is page 14 of a legal ruling filed on December 2, 2024 (Case 22-1426), likely from the Second Circuit Court of Appeals. The court affirms the District Court's decision to deny Ghislaine Maxwell's motion to dismiss Counts Three and Four of her indictment. The court rules that the offenses involving sexual abuse of minors fall within the extended statute of limitations provided by 18 U.S.C. § 3283 and that the 2003 amendment to this statute was correctly applied retroactively.
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This document is page 4 (labeled 'iii') of a Table of Authorities from a legal brief filed on November 1, 2024, in Case 22-1426 (likely the Ghislaine Maxwell appeal). It lists various legal precedents cited in the brief, including a 2024 Second Circuit decision in *U.S. v. Maxwell*, along with citations to other federal cases such as *U.S. v. Papa* and *U.S. v. Persico*. The document bears a Department of Justice Bates stamp.
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This legal document argues that a news article alleging juror misconduct is insufficient to warrant an evidentiary hearing. It cites numerous legal precedents from various courts, including the Second Circuit, which have consistently held that unsworn, hearsay, anonymous, or speculative reports do not meet the high evidentiary standard required to investigate such claims.
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This legal document argues that a District Court's interpretation of statute § 3283 is flawed because it relies on misinterpreted legal precedent. The author contends the court, following a Third Circuit opinion, improperly applied a quote from the *Dodge* case, which concerned a different statute (SORNA), to invent a legislative history for § 3283 that does not exist.
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This document appears to be page 5 (labeled Roman numeral iv) of a legal brief or filing related to Case 20-3061, filed on October 2, 2020. It is a Table of Authorities listing various legal precedents (case law) cited in the main document, including United States v. Caparros and United States v. Kerik. The footer indicates it is part of a Department of Justice (DOJ-OGR) release.
DOJ-OGR-00019595.jpg
This is a page from a legal brief filed on September 28, 2020, in the Second Circuit Court of Appeals (Case 20-3061). The text argues that a district court's refusal to modify a protective order is immediately appealable under the 'collateral order doctrine.' The filing contends that the appeal is necessary to share 'critical new information' with Judge Preska before deposition materials in the civil case *Giuffre v. Maxwell* are unsealed, arguing that post-judgment review would be moot.
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This is a Motion Information Statement filed on September 24, 2020, in the U.S. Court of Appeals for the Second Circuit for the case of United States v. Maxwell (Docket No. 20-3061). Ghislaine Maxwell's attorney, Adam Mueller, is requesting permission to file several documents under seal, including an unredacted brief and Appendix Volume 2, arguing they contain confidential material. The motion states that the opposing counsel for the United States, Maurene Comey, does not oppose this request.
DOJ-OGR-00019576.jpg
This legal document, dated August 24, 2020, is page 3 of a filing to Judge Alison J. Nathan on behalf of Ms. Maxwell. It argues against the U.S. Government's position, refuting the claim that materials Ms. Maxwell seeks to file under seal are 'Confidential' or would compromise a 'secret' investigation. The filing cites legal precedent and states that the subpoena recipient is already aware of the information in question.
DOJ-OGR-00019552.jpg
This document is a page from a legal filing addressed to Judge Alison J. Nathan, arguing against a criminal defendant's request to use discovery materials in a civil case. The Government contends there is no precedent for such use and defends the secrecy of grand jury investigations and subpoenas against the defendant's accusations of impropriety. It cites several cases to support maintaining protective orders and separating criminal and civil proceedings.
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