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United States District Court for the District of New Mexico The United States District Court United States District Court – District of New Hampshire Armed Forces of the United States United States of America (USA) United States / American policymakers United States intelligence agencies National Commission on Terrorist Attacks Upon the United States Kissinger Institute on China and the United States USAID (United States Agency for International Development) United States Attorney's Office in Miami (USAO) United States National Academy of Sciences United States Embassy - London United States Penitentiary Leavenworth United States Embassy, London USPHS (United States Public Health Service) United States Virgin Islands Department of Justice (USVIDOJ) USANYS (United States Attorney's Office) United States District Court, SDNY United States Attorney's Office for the District of New Jersey United States Attorney's Office for the Middle District of Pennsylvania United States Attorney's Office for the Northern District of Texas Office of the United States Attorney for the Southern

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person Jeffrey Epstein
Party to non prosecution agreement
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Date Event Type Description Location Actions
2007-09-01 N/A Jeffrey Epstein entered into a non-prosecution agreement (NPA) with the Office of the United Stat... N/A View

DOJ-OGR-00009212.jpg

This legal document, filed on February 24, 2022, is part of a motion on behalf of Ms. Maxwell arguing for a new trial or other relief due to juror misconduct. The filing contends that Juror No. 50 was not impartial, citing his 'pattern and practice of telling falsehoods' under oath during jury selection (voir dire). The document refutes the government's counterarguments and uses legal precedents like McDonough and Greer to support the claim that the juror's deliberate lies are evidence of bias and that the court would have struck him for cause had the truth been known.

Legal document
2025-11-20

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This legal document is a portion of a brief arguing against the government's reliance on the case United States v. Shaoul. The author contends that the government's interpretation of Shaoul is flawed because it did not address the specific argument being made, its relevant language is non-binding dictum, and it is inconsistent with earlier, controlling precedents like Langford and the Supreme Court's decision in McDonough. The document uses principles of legal precedent to assert that the court should not follow the government's reasoning.

Legal document
2025-11-20

DOJ-OGR-00009204.jpg

This legal document is a page from a motion filed on behalf of Ms. Maxwell, arguing that she is entitled to a new trial due to false answers given by Juror No. 50 during jury selection. The central argument is that Maxwell does not need to prove the juror's falsehoods were deliberate, citing several legal precedents to support the claim that even honest mistakes can warrant a new trial to ensure the constitutional right to a fair and impartial jury. The motion criticizes the government's position as a weak attempt to achieve "finality" at the expense of justice.

Legal document
2025-11-20

DOJ-OGR-00009161.jpg

This legal document argues that the court should deny the defendant's request for a post-verdict hearing and 'pre-hearing discovery' concerning juror conduct. The argument is based on legal precedent, stating that the defendant's evidence—a single anonymous sentence from a newspaper article—is inadmissible hearsay and does not meet the required standard of 'concrete allegations.' The document cites several cases to support the position that courts routinely deny such inquiries to protect the finality of verdicts and avoid the dangers of post-verdict juror scrutiny.

Legal document
2025-11-20

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This legal document, part of a court filing, argues against holding an evidentiary hearing to question a jury based on an anonymous, hearsay report. It cites legal precedent from cases like *United States v. Stewart* and *United States v. Guzman Loera* to assert that a high standard of evidence is required for such a hearing, which anonymous tips do not meet. The document details the *Guzman Loera* case as an example where a court denied a hearing despite allegations of juror misconduct published in a magazine article.

Legal document
2025-11-20

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This legal document is a filing by the Government arguing that the Court should personally conduct a narrow questioning of Juror 50 to investigate potential bias. The Government contends this approach is necessary to prevent juror harassment and protect the integrity of jury deliberations, citing numerous legal precedents where courts have similarly controlled such inquiries. The Government also argues against the defendant's request for "pre-hearing discovery" and calling other jurors as witnesses.

Legal document
2025-11-20

DOJ-OGR-00009147.jpg

This legal document argues against the automatic presumption of juror bias when a juror has engaged in conduct similar to the defendant's. It cites multiple court cases from various circuits (First, Second, Seventh, Ninth, Tenth) to support the position that juror removal is reserved for "extreme situations" and that a finding of bias often depends on a combination of factors, not just a similarity of experience. The document distinguishes cases cited by the defendant, arguing they are either inapposite or involve unique, egregious facts not present in the current matter.

Legal document
2025-11-20

DOJ-OGR-00009146.jpg

This legal document, part of a court filing, argues against a finding of implied bias for 'Juror 50'. It outlines the Second Circuit's established 'narrow' view on the matter, citing multiple precedents where the court refused to presume bias based on occupational relationships or personal experiences without a showing of actual prejudice. The document asserts that the current circumstances involving Juror 50 do not meet the high threshold for mandatory disqualification set by the Second Circuit.

Legal document
2025-11-20

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This legal document is a court filing arguing for the credibility of Juror 50 against a defendant's challenge. The filing contends that any inconsistencies in the juror's questionnaire answers should be assessed in a formal hearing, not based on public statements, and cites legal precedents suggesting jurors can make honest mistakes. It further argues that the juror's disclosure of having read about the defendant's connection to Epstein and the illogical nature of deliberately lying only to immediately risk exposure suggest the juror did not intentionally mislead the court.

Legal document
2025-11-20

DOJ-OGR-00009136.jpg

This legal document, part of a court filing, argues that there is no basis to find that 'Juror 50' committed a 'deliberate falsehood' during the jury selection process (voir dire). It cites several legal precedents, primarily from the Second Circuit, to establish that juror misconduct requires proving intentional deceit, not just an honest mistake or failure to answer. The document concludes that the current record does not meet this high threshold to prove dishonesty by Juror 50.

Legal document
2025-11-20

DOJ-OGR-00009047.jpg

This legal document, part of case 1:20-cr-00330-PAE filed on February 24, 2022, presents an argument on behalf of Ms. Maxwell that Juror No. 50 intentionally provided false answers to questions during the jury selection process (voir dire). The document asserts that Ms. Maxwell can meet the burden of proof to show the juror's dishonesty and that the court should infer bias, citing legal precedents to support its claims. The filing suggests that video evidence of the juror being confronted with the false answers supports the claim of intentional deception.

Legal document
2025-11-20

DOJ-OGR-00009041.jpg

This legal document discusses the critical issue of juror impartiality and memory reliability in court proceedings. It references the Sampson v. United States case, where a new penalty-phase hearing was ordered due to a juror's undisclosed personal experiences as a crime victim, drawing parallels to concerns about Juror No. 50's ability to fairly evaluate evidence in the current case. The document also incorporates expert testimony from Dr. Loftus regarding the confidence and accuracy of memories, emphasizing the potential for bias when jurors' personal experiences align with case details.

Legal document
2025-11-20

DOJ-OGR-00009039.jpg

This legal document, page 38 of a court filing from February 24, 2022, argues that a specific juror, Juror No. 50, should be considered impliedly biased. The argument is supported by citing legal precedent from various cases (Eubanks, Daugerdas, Dyer, Sampson) which establish two main theories for implied bias: when a juror lies during the selection process (voir dire) and when a juror's personal life experiences are too similar to the issues being litigated in the case, potentially compromising their impartiality.

Legal document
2025-11-20

DOJ-OGR-00009037.jpg

This legal document discusses the challenge for cause of Juror No. 50. It cites various legal precedents regarding the impartiality of jurors and the grounds for excusing a juror.

Legal document
2025-11-20

DOJ-OGR-00009036.jpg

This legal document argues that Ms. Maxwell is entitled to a new trial. The basis for the argument is that a juror, identified as Juror No. 50, provided false answers during the jury selection process (voir dire) by denying he had ever been a victim of a crime or sexual abuse. The document asserts that the juror later admitted to media outlets that he was a victim of childhood sexual abuse, and that this dishonesty was material to his ability to serve as an impartial juror, thus satisfying the legal test for a new trial.

Legal document
2025-11-20

DOJ-OGR-00009007.jpg

This document is page vi of a legal filing (Case 1:20-cr-00330-PAE, Document 613), filed on February 24, 2022. It is a table of authorities, listing numerous legal cases with their citations and the page numbers where they are referenced in the main document. The cases cited span from 1936 to 2018 and involve various parties in different U.S. federal and state courts.

Legal document
2025-11-20

DOJ-OGR-00008989.jpg

This legal document, part of case 1:20-cr-00330-PAE, argues that the Court possesses the authority to release the sealed Jury Questionnaire and voir dire testimony of Juror 50. It cites multiple legal precedents to establish that such a release is permissible but is subject to a balancing test, weighing public access against juror privacy, security, and potential harassment. The document emphasizes that any limitations on access to these materials must be narrowly defined and justified by a demonstrated need.

Legal document
2025-11-20

DOJ-OGR-00008938.jpg

This legal document, filed on February 11, 2022, distinguishes between a 'constructive amendment' and a 'variance' in a criminal indictment, citing several legal precedents. It argues that the central element, or 'core of criminality,' of the Mann Act charges against Epstein and Ms. Maxwell was a clear scheme to entice underage girls to travel to New York for the purpose of violating New York law.

Legal document
2025-11-20

DOJ-OGR-00008937.jpg

This document is a page from a legal filing, specifically a memorandum or brief, discussing the legal concept of "constructive amendment" in criminal law. It cites several Second Circuit precedents (D'Amelio, Roshko, Wozniak, Attanasio) to define the "core of criminality" that must be established in an indictment to provide proper notice to a defendant. The text outlines the legal test for determining if the evidence presented at trial improperly broadened the charges beyond what was specified in the indictment.

Legal document
2025-11-20

DOJ-OGR-00008936.jpg

This legal document, filed on February 11, 2022, details the defense's request for an additional jury instruction concerning Mann Act counts, arguing against conviction based solely on New Mexico conduct. The Court declined this instruction, and the jury subsequently convicted Ms. Maxwell on Count Four, with charges also in Counts One and Three. The document also cites applicable law regarding constructive amendments, defining them and explaining their impact on a defendant's Grand Jury Clause rights.

Legal document
2025-11-20

DOJ-OGR-00008914.jpg

This legal document is a court order from case 1:20-cr-00330-PAE, filed on February 11, 2022. The Court denies two separate requests: first, it denies Juror 50's motion to intervene in the criminal case, and second, it denies the Defendant's requests to either strike or seal Juror 50's motion. The Court's reasoning relies on legal precedent, stating that motions to strike are disfavored and that Juror 50's motion qualifies as a judicial document subject to the presumption of public access.

Legal document
2025-11-20

DOJ-OGR-00008910.jpg

This legal document, dated February 11, 2022, is a court ruling from case 1:20-cr-00330-PAE. The Court denies Juror 50's motion to intervene and also denies the Defendant's request to seal that motion, citing the public's right to access judicial documents. The document then details the Court's analysis of a separate request from the Defendant to temporarily seal documents related to a motion for a new trial, outlining the three-part legal test from the Second Circuit used to evaluate such requests.

Legal document
2025-11-20

DOJ-OGR-00019878.jpg

This document is page 'iii' (Table of Authorities) from a legal filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It lists legal precedents cited within the brief, including 'United States v. Epstein' (2019) and 'United States v. Salerno' (1987), along with a citation to 18 U.S.C. § 3142 regarding bail/detention. The page bears a Bates stamp DOJ-OGR-00019878.

Legal filing - table of authorities
2025-11-20

DOJ-OGR-00019869.jpg

This legal document, filed on July 2, 2020, argues for the detention of a 58-year-old defendant, asserting they are a significant flight risk. The argument is based on the severity of the alleged crimes involving multiple minors, a potential 35-year prison sentence, and the strength of the evidence, which includes victim testimony corroborated by flight records, diaries, and business records. The document also confirms that the charges are timely under the amended statute of limitations.

Legal document
2025-11-20

DOJ-OGR-00019857.jpg

This legal document argues that the government has failed to meet its burden of proof regarding Ms. Maxwell's flight risk, citing Supreme Court precedent on bail. It references the case of United States v. Bodmer, where a defendant was released to home confinement with GPS monitoring despite the government's speculative arguments. The document concludes that Ms. Maxwell should receive similar treatment to other defendants granted bond.

Legal document
2025-11-20
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