S.D.N.Y.
OrganizationRelationship Network
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Epstein's lawyers
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DOJ-OGR-00003134.jpg
This is page 200 of a legal filing (Document 204) in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text outlines the Government's argument that separate counts for 'conspiracy to transport' and 'conspiracy to entice' minors are not multiplicitous because a jury could theoretically convict on one while acquitting on the other. The Government asserts it intends to prove the defendant did both.
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This is page 168 of a legal filing (Document 204) from the case United States v. Ghislaine Maxwell, filed on April 16, 2021. The Government argues that perjury counts (Counts Five and Six) should be tried jointly with the sex trafficking counts (Counts One through Four) because they involve the same evidence and separating them would waste judicial resources and traumatize victims by forcing them to testify twice. The text explicitly references Epstein's scheme to abuse underage girls and Maxwell's alleged participation in recruiting girls for sexual massages.
DOJ-OGR-00003082.jpg
This document is a page from a legal filing, specifically a memorandum of law, discussing the legal standards for perjury. The author argues against dismissing a perjury count before trial based on 'fundamental ambiguity,' citing numerous court cases to establish that such challenges are typically evaluated after a trial. The text distinguishes between answers that are literally true but misleading (which may not be perjury) and answers that are outright false, regardless of responsiveness (which can be perjury).
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This legal document, a page from a court filing dated April 16, 2021, discusses the legal standard for challenging an affidavit based on alleged omissions of fact. It cites numerous precedents, primarily from the Second Circuit and the Southern District of New York, to argue that a motion to suppress evidence should be denied unless the omissions were intentional, deliberate, or made with reckless disregard for the truth. The document emphasizes that this is a high standard to meet, as courts recognize that all affidavits will inevitably omit some facts that may seem significant in retrospect.
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This legal document, page 140 of a court filing from April 16, 2021, outlines the legal standard for a defendant to obtain a "Franks hearing" to challenge the validity of an affidavit used for probable cause. It details the three-part test a defendant must meet, requiring a "substantial preliminary showing" of inaccuracies or omissions in the affidavit that were material and made with deliberate falsehood or reckless disregard for the truth. The document explains that a court must then determine the materiality of these errors by revising the affidavit to see if it still supports a finding of probable cause.
DOJ-OGR-00003067.jpg
This document is page 133 of a legal filing (Document 204) in the case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It presents legal arguments and case law precedents regarding government misconduct, specifically the high burden required to prove 'outrageous' government conduct that would warrant dismissal of an indictment. The text argues that relief is only appropriate if the misconduct prejudiced the defense, and that suppression of evidence is the standard remedy rather than dismissal.
DOJ-OGR-00003063.jpg
This document page is from a legal filing in the case United States v. Ghislaine Maxwell (1:20-cr-00330). The text presents a legal argument distinguishing the current case from *United States v. Oshatz*, specifically regarding the enforceability of subpoenas for deposition transcripts and protective orders. It cites Chief Judge McMahon's finding that the Government demonstrated 'extraordinary circumstances' justifying the modification of a protective order, unlike in *Oshatz* where the government was characterzied as 'trolling for evidence'.
DOJ-OGR-00003062.jpg
This document is a page from a legal filing, likely a government brief, arguing against a defendant's claim of Fifth Amendment privilege. It cites numerous court cases (such as Boyd, Fisher, and Bryson) to establish that the act of production privilege for private papers has been limited and that the Fifth Amendment does not protect an individual from prosecution for perjury, even if testimony was improperly compelled. The core argument is that a citizen cannot lie to the government with impunity.
DOJ-OGR-00003059.jpg
This legal document, page 125 of a court filing from April 16, 2021, discusses the application of the Fifth Amendment privilege against self-incrimination to the act of producing documents. It cites several legal precedents to argue that the privilege only applies when the act of production itself is testimonial and incriminating, not merely because the documents' contents are incriminating. The document further asserts that the Fifth Amendment is primarily concerned with protecting individuals from governmental coercion, not from other moral or psychological pressures.
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This document is page 106 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The text details the Government's argument that it did not circumvent the 'Martindell' legal standard when seeking evidence previously under protective orders, specifically referring to a subpoena issued to the law firm Boies Schiller. It notes that Judges McMahon and Netburn ruled that the Government had demonstrated 'extraordinary circumstances' justifying the release of testimony to the grand jury despite previous protective orders.
DOJ-OGR-00003028.jpg
This document describes the Government's efforts to obtain materials from the law firm Boies Schiller via grand jury subpoenas for a criminal investigation (implied U.S. v. Maxwell). Due to the covert nature of the investigation, the defendant was not notified. Boies Schiller complied with non-protected materials but required court intervention (from Judges Sweet and Netburn) to modify protective orders in civil cases (including Jane Doe 43 v. Epstein) to release protected documents, which the Government argued for in sealed letters submitted around February 28, 2019.
DOJ-OGR-00003014.jpg
This document is page 80 of a legal filing (Document 204) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. The text presents legal arguments regarding the dismissal of an indictment due to pre-indictment delay, citing numerous Second Circuit precedents (such as Cornielle, Alameh, and Delacruz) to establish that a defendant must prove the Government intentionally delayed specifically to gain a 'tactical advantage.'
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This legal document is a page from a court filing that refutes a defendant's argument about the legislative intent of Section 3283. The author argues the defendant used a misleading, selective quote from Senator Patrick Leahy to claim Congress did not intend for an extended statute of limitations to apply retroactively. The document provides the full quotation to show that Congress removed the retroactivity provision due to constitutional concerns, not to limit the statute's application as the defendant suggests.
DOJ-OGR-00002984.jpg
This document is page 23 of a government filing in the case against Ghislaine Maxwell, arguing against her motions to dismiss. The prosecution asserts that the Non-Prosecution Agreement (NPA) from the Southern District of Florida does not apply to the current indictment or district, and denies her request for discovery due to lack of evidence. Furthermore, the document argues that the indictment is timely under 18 U.S.C. § 3283 because the statute allows prosecution for child sexual abuse offenses as long as the victims are alive, rejecting Maxwell's argument that the statute applies only prospectively.
DOJ-OGR-00002955.jpg
This document is page 21 of a Table of Authorities from a legal filing (Document 204) in Case 1:20-cr-00330-PAE, which corresponds to the trial of United States v. Ghislaine Maxwell. The page lists various legal precedents (case law citations) ranging from 'United States v. Rahimi' to 'United States v. Rosa' used to support legal arguments in the main brief. The document bears the Bates stamp DOJ-OGR-00002955.
DOJ-OGR-00002951.jpg
This document is page xvi from a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It serves as a table of authorities, listing numerous 'United States v.' court cases with defendants ranging from Israel to Laurenti. Each entry provides the legal citation for the case and the page numbers where it is referenced within the main document.
DOJ-OGR-00002948.jpg
This document is page xiii from a legal filing, specifically a Table of Authorities from Document 204 in case 1:20-cr-00330-PAE, filed on April 16, 2021. It lists numerous U.S. federal court cases cited within the larger document, providing the case name, legal citation, and the page numbers where each case is referenced. The cases listed involve the United States as the plaintiff against various individual defendants.
DOJ-OGR-00002944.jpg
This document is page 10 (labeled 'ix') of a Table of Authorities from a legal filing dated April 16, 2021, in the case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It lists legal precedents beginning with 'S' through 'U', including citations for *United States v. Nader* (marked 'passim', meaning cited frequently) and various Second Circuit decisions. The footer indicates this document was processed by the DOJ Office of Government Relations.
DOJ-OGR-00004732.jpg
This legal document is a filing by the Government arguing against the defense's motion for early disclosure of impeachment material related to a witness, Minor Victim-4. The Government contends that Minor Victim-4's prior consistent statement from a deposition, made over a decade before the defendant's 2020 indictment, confirms the defendant's role in scheduling her massages with Epstein, thereby undermining the defense's claim of recent fabrication. The Government affirms its intent to provide this material ten days before trial, in line with customary practice.
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This legal document, page 22 of a filing from May 25, 2021, outlines the prosecution's argument against a defendant's motion. It details allegations from the S2 Indictment, stating the defendant facilitated the sex trafficking of 'Minor Victim-4' to Epstein by scheduling appointments, making payments, and encouraging recruitment of others. The document argues these details are sufficient to deny the defendant's request for a bill of particulars, citing several legal precedents.
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This document is page 19 of a legal filing (Case 1:20-cr-00330-PAE) filed on May 25, 2021, likely by the prosecution. It argues that the 'S2 Indictment' was filed timely and not delayed for strategic reasons, explaining that interviews with 'Minor Victim-4' were delayed until early 2021 due to COVID-19 travel constraints. The text refutes the defendant's motion to dismiss based on pre-indictment delay.
DOJ-OGR-00004724.jpg
This document is page 17 of a Government filing (Document 295) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on May 25, 2021. The text argues that the Defendant's motion to dismiss the S2 Indictment based on improper pre-trial delay should be denied, citing that the Court has already rejected similar arguments and that the defendant failed to prove actual prejudice or intentional delay by the Government. It references case law standards for due process violations regarding pre-indictment delays.
DOJ-OGR-00004719.jpg
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.
DOJ-OGR-00005792.jpg
This legal document, a page from a court filing, discusses the standards for admitting expert testimony in court. It argues that a district court has broad discretion in determining the reliability of such testimony and that it must also be relevant, concerning matters beyond the understanding of an average juror. The document cites several precedents, focusing on cases where courts admitted expert testimony on the psychological dynamics between perpetrators and victims of sex crimes, such as the 'pimp-prostitute relationship' and 'trauma bonding'.
DOJ-OGR-00002818.jpg
This legal filing argues against a subpoena issued by the Defendant (Ghislaine Maxwell) to BSF, claiming the requested documents are either procurable from the government or are items (boots and photographs) better produced at trial if relevant. The document specifically mentions photographs connecting the Defendant, Virginia Giuffre, and Prince Andrew at a London townhome, as well as items related to Annie and Maria Farmer.
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