S.D.N.Y.
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DOJ-OGR-00002765.jpg
This document is page 4 of a court order filed on March 18, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Government's broad requests to redact pages 1–128 and seal Exhibits 8 and 9, citing a lack of non-conclusory basis for how disclosure would imperil the investigation. The Court sets a deadline of March 22, 2021, for the Government to submit a letter justifying more tailored redactions and agrees with the Defendant regarding objections to redactions on pages 187–188.
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This document is page 13 of a court order filed on December 30, 2020 (Case 1:20-cr-00330-AJN), denying release/bail for the Defendant (contextually Ghislaine Maxwell). The Court argues that the Defendant poses a significant flight risk due to her French citizenship, the difficulty of extradition (specifically mentioning Israel), her extraordinary financial resources, and her proven ability to avoid detection. The Court explicitly rejects the Defendant's argument that waiving extradition rights indicates an intent not to flee.
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This document is page 27 of a legal filing (Case 1:20-cr-00330-AJN) filed on December 18, 2020. The text argues against the defense's motion for reconsideration of bail, stating the Court has already rejected comparisons to other high-profile cases (Esposito, Dreier, Madoff). The prosecution highlights the defendant's 'significant foreign connections' and 'sophistication in hiding those resources and herself' as reasons for continued detention.
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This document is page 19 of a legal filing (Document 100) from the US Government in the case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on June 18, 2020. The prosecution argues that Maxwell poses a flight risk because she is a French citizen, and French law strictly prohibits the extradition of its own nationals to the United States. The document references a letter from the French Ministry of Justice confirming this policy and notes that any extradition waiver signed by the defendant would be unenforceable in France.
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This document is Page 3 of a legal filing entitled 'Table of Authorities' from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on June 18, 2020. It lists numerous legal precedents cited in the filing, primarily 'United States v. [Defendant]' cases. Notably, the list includes two citations for 'United States v. Epstein' (one from 2001 in E.D. Pa. and one from 2019 in S.D.N.Y.) and one for 'United States v. Madoff'.
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This legal document is a motion from the Government arguing that the court should preclude the defense from calling case agents to testify about matters the Government deems irrelevant. These topics include the thoroughness, scope, timeline, and charging decisions of prior investigations in Florida and New York. The Government contends that this testimony is not relevant to the defendant's guilt or innocence and asks the court to require the defense to make an offer of proof before introducing such arguments or evidence.
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This legal document, a page from a court filing dated October 29, 2021, argues that the jury should not consider the adequacy or methods of the government's investigation when determining a defendant's guilt. Citing multiple legal precedents, the author contends that details about investigations, including the one involving Jeffrey Epstein, are irrelevant to the case at hand. The document refutes the defense's position that they should be allowed to challenge the thoroughness of the government's investigation.
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This legal document, filed on October 29, 2021, is part of the case against Ms. Maxwell. It argues that evidence of Jeffrey Epstein acting alone or without Ms. Maxwell's knowledge should be admissible to counter the government's conspiracy charge. The filing distinguishes Ms. Maxwell's case from several other legal precedents cited by the government, claiming they are inapplicable to the current situation.
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This legal document argues that there is no absolute right for an accused person to know a witness's true name and address, citing various legal precedents and the Crime Victims' Rights Act. It emphasizes the strong public interest in protecting the identities of victims, particularly in sex abuse cases, to ensure their dignity, privacy, and safety, and to encourage future victims to report crimes. The document provides multiple examples of cases where courts have permitted victims, including minors, to testify using pseudonyms or partial names.
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This document is page 6 of a legal filing from Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on October 29, 2021. It discusses legal standards and Second Circuit precedents regarding the protection of witness identities versus a defendant's right to cross-examination. The text cites various cases (Marcus, Marti, Urena, Cavallaro) to support the argument that courts must balance witness safety against the defense's need for information, particularly in cases involving sex trafficking or safety risks.
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This is a court order issued by District Judge Alison J. Nathan on October 28, 2021, in the case of United States v. Ghislaine Maxwell. The order schedules an in-person pretrial conference for November 1, 2021, and details the logistical arrangements, including the location, access for victims and family, and COVID-19 protocols for public viewing in designated overflow courtrooms. The order explicitly prohibits the use of electronic devices in the overflow rooms.
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This document is Page 2 of a legal filing from the United States v. Ghislaine Maxwell case (1:20-cr-00330), filed on October 18, 2021. The text outlines legal arguments regarding jury selection (*voir dire*), citing Second Circuit precedents to argue that the court, rather than attorneys, should conduct the questioning of potential jurors to ensure impartiality and efficiency. The filing asserts that the defendant (Maxwell) has provided no persuasive reason to deviate from this customary practice.
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This is page 2 of a legal filing (Document 354) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on October 15, 2021. The text argues that the Court has the authority to set an earlier deadline for the defense to file motions under Federal Rule of Evidence 412 (the rape shield law), citing various precedents to support the Government's request for an earlier briefing schedule. The document references multiple other cases (Andrews, Rivera, Dupigny, Backman, Valenzuela) to demonstrate that courts frequently set Rule 412 deadlines more than 14 days prior to trial.
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This document is a 'Table of Authorities' from a court filing dated February 4, 2021, associated with Case 1:20-cr-00330-AJN (the Ghislaine Maxwell trial). It lists legal precedents (cases), statutes, and rules relied upon in the main document. Key statutes cited include 18 U.S.C. § 2421, 2422, and 2423, which relate to the transportation of individuals for illegal sexual activity (Mann Act) and sexual exploitation of minors.
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This document is page 52 of a legal filing (Case 1:20-cr-00330, U.S. v. Ghislaine Maxwell) dated October 29, 2021. The text argues for the admissibility of 'Minor Victim-3's' testimony under Rule 404(b) to establish the defendant's intent and modus operandi regarding grooming and recruitment. It cites three legal precedents (Vickers, McDarrah, and Brand) to support the admission of evidence regarding grooming, email communications, and interest in minors.
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This document is page 42 of a legal filing (Document 397) from October 29, 2021, in the case against Ghislaine Maxwell (implied by case number). The Government argues that the testimony of 'Minor Victim-3' is admissible as direct evidence of the charged offenses, specifically citing the sexual abuse committed by the defendant and Jeffrey Epstein. It also addresses procedural arguments regarding Rule 404(b) notices.
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This is page 8 of a court filing (Document 195) in Case 1:20-cr-00330-PAE (US v. Maxwell), filed on April 5, 2021. The Government argues against the defendant's attempt to issue a subpoena to 'BSF' (Boies Schiller Flexner), characterizing it as an improper 'fishing expedition' for victim information and impeachment material that violates the 'Nixon test.' The Government also notes that the defendant failed to file a required response by the April 2, 2021 deadline.
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This legal document, page 5 of a filing from April 5, 2021, presents the U.S. Government's argument for having legal standing to challenge subpoenas issued to third parties. Citing multiple court precedents (including Nachamie, Cole, and Carton), the Government asserts its legitimate interest in preventing witness harassment, controlling the timing of disclosures (such as Giglio material), and protecting its own communications. The document argues that allowing the Government to intervene is the only way to protect these interests, especially when a subpoena recipient may not be fully aware of the case's context.
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This page is from a legal filing (Document 189) in the case of United States v. Schulte (Case 1:17-cr-00548-PAC), filed on March 24, 2021. The text discusses a legal dispute regarding jury selection venues, specifically distinguishing the current case from *United States v. Johnson*. The court argues that unlike in *Johnson*, Schulte's grand and petit juries were drawn from different courthouses, invalidating his argument regarding the 'relevant community' for the jury pool. The document mentions the 'underrepresentation analysis' and the 'absolute disparity method' for assessing jury fairness. While comprised in a dataset potentially related to Epstein, the text explicitly concerns Joshua Schulte (likely the CIA Vault 7 case).
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This document is page 7 of a legal order filed on March 22, 2021, in the case of United States v. Schulte (Case 1:17-cr-00548). The text details the court's analysis of Schulte's 'fair cross-section challenge' regarding the exclusion of African American and Hispanic American jurors under the Jury Selection and Service Act (JSSA) and the Sixth Amendment. While the court acknowledges these demographics are 'distinctive groups,' it rules that Schulte failed to meet the second and third elements of the Duren test, resulting in the rejection of his challenge.
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This document is page 20 of a legal filing (Document 148) from February 4, 2021, in the case of United States v. Ghislaine Maxwell. It outlines a legal argument based on the 'Turkish factors' to justify the defense's request for early disclosure of the government's witness list. The defense argues that Maxwell has no criminal history, is not a danger to the community, and that the complexity of the case combined with the global pandemic necessitates this disclosure for fair preparation.
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This legal document is page 3 of a court filing from October 18, 2021, in case 1:20-cr-00330-PAE. It details the court's reasoning for denying a defendant's request for attorney-conducted voir dire. The defendant argued for it based on significant pretrial publicity and the case's sensitive nature, but the court concluded that court-conducted voir dire is sufficient to ensure fairness and prevent potential prejudice, citing legal precedents.
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This document is Page 2 of a legal filing (Document 351) in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on October 15, 2021. The Government argues that under Federal Rule of Evidence 412 (Rape Shield Law), the Court has the authority to set a deadline for defense motions regarding sexual behavior evidence earlier than the standard 14 days before trial. The text cites multiple legal precedents (Andrews, Rivera, Dupigny, Backman, Valenzuela) to support the request for an earlier briefing schedule to ensure victims' rights to be heard.
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This document is Page 9 of a legal filing (Document 195) from April 5, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text argues that any records obtained via Rule 17(c) subpoenas must be marked confidential under a protective order and shared with the opposing party, citing that the rule does not allow for secretive evidence gathering. It references the reciprocal discovery obligations of Rule 16 and cites the precedent of United States v. St. Lawrence.
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This document is page 2 of a legal filing (Document 195) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 5, 2021. The text presents legal arguments regarding the limitations of Rule 17 subpoenas in criminal cases, arguing they cannot be used for broad discovery or to find leads, unlike in civil procedure. The text heavily cites legal precedents including *Bowman Dairy Co. v. United States*, *United States v. Purin*, and *United States v. Tagliaferro* to establish the standard for requiring document production.
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