S.D.N.Y.
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This document is a court docket sheet from the case against Ghislaine Maxwell, detailing filings and orders from July 8 to July 13, 2020. Key events include the filing of a superseding indictment, motions for attorneys to appear on Maxwell's behalf, and a detailed court order outlining the procedures for a remote bail hearing scheduled for July 14, 2020, due to COVID-19 restrictions. The order specifies how the public, press, victims, and legal counsel can access the proceedings via teleconference and limited in-person viewing.
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This document is a page from a court docket (Case 21-58) covering entries between July 27 and July 30, 2020, regarding *United States v. Ghislaine Maxwell*. Key entries include a dispute over the terms of a Protective Order, specifically regarding Maxwell's ability to publicly reference alleged victims who have previously spoken publicly about her or Jeffrey Epstein. Judge Alison J. Nathan issued a Memorandum Opinion & Order siding with the Government to restrict Maxwell from publicly referencing these victims/witnesses to protect their privacy and safety.
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This document is a court docket from Case 21-58, detailing legal proceedings related to Ghislaine Maxwell between July 8 and July 13, 2020. Key events include the filing of a superseding indictment, motions and notices for attorney appearances on behalf of Maxwell, and a detailed court order outlining the procedures for a remote bail hearing scheduled for July 14, 2020. The order, signed by Judge Alison J. Nathan, specifies how the public, press, and involved parties can access the hearing via teleconference and limited in-person viewing due to COVID-19 restrictions.
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This page is from a court order filed on June 24, 2022, in case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The judge denies the Defendant's request to redact statements related to victims Annie Farmer, Kate, and Giuffre, ruling that the documents are judicial records subject to public access under the First Amendment. The court argues that the Defendant's concerns do not outweigh the presumption of public access, noting that the Court (as decision-maker) can evaluate the submissions without prejudice.
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This legal document, a page from a court filing, argues that the harsh conditions of incarceration during the COVID-19 pandemic should be considered a mitigating factor for sentencing. It cites multiple precedents from the Southern District of New York (S.D.N.Y.) to support the claim that the pandemic, with its associated lockdowns and health risks, has made prison time significantly more punitive than under normal circumstances. The argument is made in the context of a defendant, Ms. Maxwell, to warrant a downward variance in her sentence.
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This page from a court order (Case 1:20-cr-00330-PAE) rejects the Defendant's (Ghislaine Maxwell) argument that she was prejudiced by the inability to call deceased witnesses, specifically two architects and a housekeeper. The court rules that this argument is speculative and unsubstantiated because other available witnesses, including Juan Alessi, Larry Visoski, and David Rodgers, testified at trial covering similar topics regarding Epstein's residences, renovations, and private aircraft.
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This legal document is a court opinion from Case 1:20-cr-00330-PAE, filed on April 1, 2022. The court analyzes and rejects the Defendant's (Maxwell's) argument that Juror 50 was biased due to dishonest answers on a jury questionnaire. The court distinguishes this case from precedents involving deliberate deception, crediting Juror 50's explanation that his nondisclosure was an 'inadvertent mistake' resulting from personal distractions and 'skimming' the form.
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This document is page 46 of a legal filing (Case 1:20-cr-00330-PAE) filed on March 11, 2022. It discusses the procedural handling of 'Juror 50' regarding a potential hearing about false statements on a jury questionnaire concerning sexual assault history. The Government argues that Juror 50 should be allowed to see his questionnaire before testifying to consult with counsel about Fifth Amendment rights, but agrees with the defense that the juror should not intervene in defining the scope of the inquiry.
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This document is page 41 of a legal filing (Document 643, filed March 11, 2022) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The text presents legal arguments citing precedents (Guzman Loera, Bin Laden, Martha Stewart) to oppose an evidentiary hearing regarding juror misconduct allegations based solely on unsworn media reports. The filing argues that newspaper articles and hearsay do not constitute 'incontrovertible evidence' required to justify post-trial juror inquiries.
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This legal document, filed on March 11, 2022, argues against the necessity of a hearing based on an anonymous juror's report of misconduct. It cites legal precedents, including United States v. Stewart and United States v. Guzman Loera, to establish that a high standard of "clear, strong, substantial and incontrovertible evidence" is required, which anonymous tips do not meet. The document details the Guzman Loera case as an example where similar allegations of jurors being exposed to prejudicial media did not result in an evidentiary hearing, reinforcing the argument that the current situation does not warrant one either.
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This page is from a legal filing (Case 1:20-cr-00330-PAE) dated March 11, 2022. It contains legal arguments citing case law (Gagnon, Moten, Calbas) regarding the standards for post-verdict jury inquiries. The Government argues that the standard for a hearing has been met specifically regarding 'Juror 50' due to inconsistencies between the juror's public statements about being a sexual abuse victim and their answer to Question 48 on the juror questionnaire. The Government consents to a hearing to determine if Juror 50 deliberately lied.
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This legal document argues against the defendant's assertion that a juror's similar life experiences should automatically presume bias, requiring their removal. It cites multiple legal precedents (from the Second, First, Seventh, and other circuits) to support the position that only "extreme situations" warrant such a presumption. The document contends that similarity of experience is just one of many factors to be considered and is often insufficient on its own to justify a juror's dismissal for cause.
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This page from a legal filing (Case 1:20-cr-00330-PAE) argues against a defense motion claiming Juror 50 was biased. The Government asserts that Juror 50's post-trial statements and negative attitude toward the defendant reflect the evidence presented during the trial, not pre-existing bias. It cites legal precedents including *United States v. Stewart* to support the argument that jurors bring subjective lived experiences to deliberations.
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This document is page 17 of a legal brief filed on March 11, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). It argues that the defendant has not met the burden of proving that 'Juror 50' deliberately lied during jury selection (voir dire) regarding past sexual abuse, distinguishing between deliberate deceit and honest mistakes based on Second Circuit case law. The Government notes that while Juror 50 made public statements about being a victim, it is not yet proven that his questionnaire answers were deliberately false.
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This page from a court filing (Case 1:20-cr-00330-PAE, likely United States v. Ghislaine Maxwell) argues against providing discovery materials (specifically a questionnaire) to 'Juror No. 50.' The prosecution contends that releasing this information would allow the juror to manipulate their testimony and argues that the juror lacks standing, citing various legal precedents. The document suggests Juror No. 50 attempted to destroy evidence and flee the media, and mentions the possibility of future charges for perjury or criminal contempt.
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This document constitutes page 46 of a legal filing (Document 621) in the case United States v. Ghislaine Maxwell, filed on February 25, 2022. The text argues that Maxwell failed to prove that the Government intentionally delayed her indictment to gain a 'tactical advantage,' citing numerous Second Circuit legal precedents to support this standard. The court dismisses Maxwell's arguments regarding the delay as 'specious' and notes a lack of evidence that the delay was intended to thwart her defense.
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This document is a legal filing, specifically page 45 of a brief, arguing that the defendant has failed to prove the government improperly delayed an indictment. It cites numerous legal precedents from the Supreme Court and the Second Circuit to establish that a defendant must show not only prejudice from a delay but also that the government intentionally caused the delay to gain a tactical advantage. The argument asserts that without meeting this high standard, the defendant's motion to dismiss should fail.
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This document, a legal filing from February 25, 2022, discusses the defendant's arguments regarding the availability and completeness of phone records and flight manifests in a criminal case. The defendant claims that Carolyn's testimony could have been disproven by phone records and that flight manifests would have helped challenge Jane's recollections, but the document refutes these claims, citing testimony from Visoski and Rodgers about the handling and incompleteness of flight manifests.
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This legal document is a portion of a court filing arguing against a defendant's claim of prejudice due to the unavailability of certain witnesses (Pinto, Salhi, Markham, and Fontanilla). The author cites multiple legal precedents, including States v. Long and United States v. Scala, to assert that the defendant's claims are speculative and lack the definite proof of actual prejudice required by law to dismiss an indictment or vacate a conviction. The document concludes that the defense's unsworn assertions about what these witnesses might have testified to are insufficient legal grounds for their motion.
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This document is page 31 of a legal filing from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 25, 2022. It argues against a defense claim of 'multiplicity' regarding conspiracy counts, referencing trial testimony from a victim named Carolyn. The text highlights that Sarah Kellen, Epstein's personal assistant since the early 2000s, contacted Carolyn to schedule appointments for sexualized massages.
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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.
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Page 5 of 51 from a court filing (Document 621) in the case of United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on Feb 25, 2022. The text argues that no 'constructive amendment' of the indictment occurred regarding the charges of enticing and transporting victim 'Jane' and other minor victims to New York. The remainder of the page outlines applicable law regarding the Fifth Amendment's Grand Jury Clause, citing precedents like U.S. v. Khalupsky and U.S. v. Dove to define the legal standard for constructive amendments.
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This legal document is a page from a court filing, likely an opinion or order, dated February 25, 2022. The court is addressing a defendant's argument for an evidentiary hearing, rejecting it by citing numerous legal precedents that establish a very high standard for post-verdict inquiries into jury conduct. The court emphasizes that motions to set aside verdicts are disfavored and that allowing such inquiries without concrete evidence could lead to negative consequences like jury harassment and tampering.
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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.
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This document is page 203 of a legal filing (Document 204) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal arguments citing various precedents (Bortnovsky, Mandell, Levy, etc.) to support the Government's position that providing voluminous discovery negates the need for a 'bill of particulars,' arguing that the defense is not entitled to a preview of the Government's legal theories, only what is strictly necessary for defense preparation.
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