S.D.N.Y.
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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 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 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 legal document, part of a court filing, argues that the defendant was not legally prejudiced regarding witness testimony. It outlines that the defense received notes on witness Jane more than three weeks before trial and that the court's decision to permit witness Kate to testify came almost two weeks after notes were received, providing ample time for preparation. The filing cites legal precedents to assert that the court did not err in its handling of limiting instructions and that any failure to request them was the defendant's own, not a basis for a prejudice claim.
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This document is page 20 of a Court Order filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell. The Judge orders that Juror 50's completed questionnaire be unsealed and docketed, citing that public interest outweighs privacy concerns following the juror's public comments. Additionally, the Court schedules a hearing for March 8, 2022, requiring Juror 50 to testify under oath regarding their answers to specific questions on the juror questionnaire.
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This document is a legal filing from the law firm Zuckerman Spaeder LLP to Judge William H. Pauley, III, dated March 7, 2013. It serves as a sentencing memorandum for their client, David Parse, arguing for a non-incarcerative sentence following his conviction for involvement in backdating transactions. The letter emphasizes the significant personal, professional, and familial suffering Parse has endured since the investigation began in 2004 and cites legal precedents to support a lenient, individualized sentence.
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This legal document is a filing by the Government in response to a defense motion. The Government argues that it is not required to produce pages from a personal diary belonging to a third-party victim because the diary is not in its custody or control. Furthermore, the Government asserts that it has already inquired with the victim, who confirmed that no diary entries exist for the relevant time period in the spring of 1996 when she met the defendant while visiting Epstein.
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This legal document is a filing by the Government in Case 1:20-cr-00330-PAE, dated April 16, 2021. The Government argues that its proposed schedule for providing discovery materials (including Section 3500, Giglio, and Jencks Act information) to the defense is adequate and even exceeds the standard practice in the district for high-profile cases. The Government offers to produce non-testifying witness statements eight weeks before trial and testifying witness materials four weeks in advance, asserting this provides ample time for the defense to prepare.
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This legal document, filed on April 16, 2021, is part of a prosecution's argument against a defendant's request for a bill of particulars. The prosecution contends that the indictment is sufficiently detailed and that the defendant has already received over 2.7 million pages of discovery, making further specifics unnecessary. A footnote reveals that the Government was unable to obtain records of commercial flights taken by the defendant, Epstein, or any victims because the investigation was opened after the records were no longer available.
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This legal document is a portion of a court filing by the prosecution (the "Government") arguing against the defendant's request for a "bill of particulars." The Government contends that the existing 18-page Indictment provides sufficient detail about the charges, which involve conspiracies with Jeffrey Epstein to traffic minors between 1994-1997 and a subsequent cover-up during a 2016 deposition. Citing legal precedents, the prosecution argues that providing more detail would unfairly restrict its case and could allow the defendant to tailor her testimony.
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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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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 legal document, filed on April 16, 2021, is a government response in a criminal case. The prosecution argues that evidence concerning 'Minor Victim-3' is admissible to prove a conspiracy, even though a direct charge based on her testimony is time-barred because she turned 25 before 2003. The government asserts that the charges remain timely due to the involvement of 'Minor Victim-1' and 'Minor Victim-2' and distinguishes the current case from a cited precedent (*Hsia*) by stating the alleged conduct, grooming a minor for Jeffrey Epstein, is central to the conspiracy.
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This page is from a legal filing (Document 204) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against the defendant's claims that the indictment is vague or that 'grooming' is not illegal behavior, citing Second Circuit precedents that define grooming as a form of enticement or inducement of minors for illegal sexual activity. The document asserts that the indictment adequately informs the defendant of the charges under 18 U.S.C § 371, § 2422, and § 2243.
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This page is from a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330), filed on April 16, 2021. The prosecution argues against the defendant's motion to dismiss, citing legal precedents (United States v. Young, Edwards v. Mazzuca) to establish that specific dates are not required in indictments regarding sexual abuse of minors due to memory limitations of victims. The text specifically highlights 'Minor Victim-1' who suffered abuse over multiple years, arguing that a timeframe is sufficient for the indictment.
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This document is page 178 (Bates DOJ-OGR-00003112) of a filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), dated April 16, 2021. It is a legal memorandum discussing Federal Rule of Criminal Procedure 7 and the standards for the sufficiency of an indictment. The text cites various legal precedents (Alfonso, Resendiz-Ponce, Wey, Stringer) to argue that an indictment generally does not need to specify evidentiary details or how an offense was committed, provided it tracks the statutory language and protects against double jeopardy.
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This legal document is a portion of the prosecution's (the Government's) argument against a defendant's motion to sever perjury counts from other charges. The Government contends that a full re-litigation of a prior defamation action is not necessary and that any potential for 'spillover prejudice' can be managed through stipulations, using a pseudonym for a witness (Giuffre), and providing limiting instructions to the jury. The document cites several legal precedents to support the argument that juries are presumed to follow such instructions.
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This legal document is a portion of a court filing, likely from the prosecution, arguing against a defendant's motion. The prosecution asserts that the defendant's false statements, made in a civil deposition, were intended to obstruct a criminal investigation by the FBI and a grand jury, and are therefore connected to the substantive offenses. The argument cites several legal precedents to support the claim that the charges should not be severed.
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This document is page 170 of a legal filing (Document 204) in the case USA v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The text presents a legal argument supporting the joinder of perjury charges with substantive offenses, citing the precedent of *United States v. Ruiz* regarding a NY State Senator who lied to conceal a financial scheme. The prosecution argues that, like in *Ruiz*, the current defendant's perjury was part of a common scheme to conceal her role in the charged sexual offenses.
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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.
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This document is a page from a legal filing, likely a brief or motion, dated April 16, 2021. It argues against the severance of counts or defendants in a criminal case by citing numerous legal precedents. The text establishes that defendants have a 'heavy burden' to show 'substantial prejudice' to justify separate trials, and that courts generally favor joint trials for efficiency, leaving the decision to the district court's discretion.
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