4th Cir.
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This document is page 2 of a court filing (Document 528) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 6, 2021. It is a legal memorandum arguing points regarding attorney-client privilege, specifically focusing on waiver and implied waiver. The text cites various legal precedents (United States v. Krug, In re von Bulow) to establish that privilege belongs to the client and cannot generally be waived by the attorney without consent, unless the client asserts an advice-of-counsel defense.
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This legal document, part of a court filing from July 29, 2025, argues for the disclosure of grand jury materials. It analyzes legal precedents, noting that while the Government may oppose disclosure, factors like public interest can be overriding. The document states that Defendant Epstein is deceased and cannot assert a position, while Defendant Maxwell intends to respond, and argues that the significant public interest in the crimes of Epstein and Maxwell justifies disclosure.
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This page is from a legal filing (Document 35, filed 04/24/20) in the case against Thomas (likely Michael Thomas, a guard involved in the Epstein case). The prosecution argues that Thomas is not entitled to draft OIG reports under Rule 16 or Brady obligations. Furthermore, the text argues Thomas has failed to meet the burden of proof required to demand discovery to support a 'selective prosecution' claim, specifically failing to prove discriminatory intent or effect regarding his charges relative to rampant conduct within the Bureau of Prisons.
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This document is page 'iii' of a Table of Authorities from a legal filing dated April 24, 2020, in Case 1:19-cr-00830-AT (which corresponds to USA v. Parnas et al., though released in a DOJ OGR batch). It lists numerous legal precedents (case law citations) primarily from the Second Circuit and Southern District of New York, referencing cases such as U.S. v. Coppa, U.S. v. Ghailani, and others used to support legal arguments in the main brief.
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This page from a legal filing argues that plea agreements made by any U.S. Attorney are binding on the entire U.S. government across all federal districts. It cites several court cases establishing this principle and the related rule that any ambiguities in such agreements must be interpreted against the government. The document concludes by stating that a case named Annabi contradicts this established legal precedent.
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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 document is a page from a legal filing (Case 22-1426, filed July 27, 2023) arguing for a new trial based on juror misconduct. The text specifically attacks the credibility of 'Juror 50,' alleging he gave intentionally false statements under oath regarding his own history of sexual abuse during the jury questionnaire process. It cites legal precedents (McDonough, Jones v. Cooper) to argue that actual or implied bias warrants a new trial.
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This legal document argues that the extension of the statute of limitations for charges against Maxwell was legally sound. It cites multiple court cases (Enterprise, Weingarten, Cruz v. Maypa) to support the conclusion of Judge Nathan that since the original limitations period had not expired, Maxwell was not deprived of a vested right. The document further asserts that such an extension does not violate the Ex Post Facto Clause of the Constitution.
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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.
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This document is page 7 of a legal filing (Document 614) from February 24, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). It argues that 'Juror 50' provided untrue answers during jury selection (voir dire) by denying past sexual abuse and claiming impartiality, facts which were later contradicted by the juror's own press statements. The text cites the 'McDonough test' to argue that these false answers prevented the defense from challenging the juror for cause.
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This legal document is a court filing that refutes two arguments made by the defendant. First, it argues that the standard for the victim's (Carolyn's) behavior is 'undue influence,' not complete lack of voluntary action. Second, it dismisses the defendant's claim of 'double-counting' in sentencing enhancements by citing legal precedents (Watkins, Kohlmeier, Arbaugh) which establish that different guideline provisions can address different harms from the same conduct.
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This document is page 147 of a court filing (Document 204) from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal analysis regarding perjury charges, specifically discussing the legal standard for 'fundamental ambiguity' in questioning. The text cites various precedents to argue that a perjury count stands unless a question is so ambiguous that people of ordinary intellect cannot agree on its meaning, noting that simple amenability to multiple meanings is not a sufficient defense.
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This legal document is a filing by the Government arguing against the defendant's (Maxwell's) claims. The Government refutes the defendant's assertion that she was protected by a civil protective order when giving deposition testimony, citing case law (e.g., Andover Data Servs., Davis) to establish that such orders do not provide the same protections as the Fifth Amendment. The document also dismisses the defendant's claim that the Government's conduct violated her due process rights as "meritless."
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This handwritten legal document, filed on October 12, 2021, analyzes the legislative history and judicial interpretation of U.S. federal sexual abuse laws. It discusses the 1986 Sexual Abuse Act (SAA), its relationship with the Victim of Child Abuse Act and specific statutes like ยง3283, and cites court cases such as U.S. v. Shaw (2017) and U.S. v. Haynsworth (1997) to illustrate how courts have defined terms and applied the law. The note also references legislative proposals from 1984 and 1990 concerning statutes of limitations and legal definitions.
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This document is a page from a 2007 Utah Law Review article authored by David Schoen, who later served as an attorney for Jeffrey Epstein. The text is a legal analysis of Federal Rule of Criminal Procedure 17, arguing for strict adherence to the 'Nixon factors' (specificity, relevancy, and admissibility) when issuing subpoenas to prevent 'fishing expeditions.' The document includes extensive legal footnotes citing various precedents and was produced as part of a House Oversight Committee investigation (likely regarding the handling of the Epstein case).
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