S.D.N.Y.
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This is page 2 of a court order filed on June 4, 2021, in the case United States v. Maxwell. The court is addressing Ghislaine Maxwell's request to subpoena the entire journal of 'Minor Victim-2.' The court rejects Maxwell's arguments, characterizing the request as a 'fishing expedition' and noting that impeachment material is generally not obtainable via Rule 17(c) subpoena prior to trial. The document also notes that 'BSF' (likely legal counsel for the victim) has stated the unproduced portions of the journal do not mention Maxwell or Jeffrey Epstein.
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This legal document is a portion of a government filing arguing against a defendant's motion for a bill of particulars. The government contends that the S2 Indictment provides sufficient detail for the defendant to prepare a defense for Counts Five and Six, which relate to her alleged participation in a conspiracy with Epstein to commit sex trafficking of minors. Specifically, the charges involve the trafficking of 'Minor Victim-4' between approximately 2001 and 2004.
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This document is page 18 of a Government filing (Document 295) in the case against Ghislaine Maxwell, filed on May 25, 2021. The Government argues that Maxwell's motion to dismiss charges based on pre-indictment delay should be denied because she failed to prove prejudice or improper tactical motives by the prosecution. The text specifically addresses the 'S2 Indictment,' noting that new charges involving 'Minor Victim-4' were added based on new evidence unavailable previously, refuting claims of bad faith delay.
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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.
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This legal document, a page from a court filing, argues that the defendant was never subjected to double jeopardy in the Southern District of Florida. It asserts that jeopardy never attached because she was never indicted, convicted, or faced adjudication of facts for the offenses in question. The document cites several legal precedents to support the claim that the Non-Prosecution Agreement (NPA) involving the defendant and Epstein did not trigger jeopardy protections as no indictment was ever filed.
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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.
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This document is a 'Table of Authorities' from a legal filing (Case 1:20-cr-00330-PAE, Document 295), filed on May 25, 2021. It lists numerous legal cases, primarily involving the United States as a party, which are cited as legal precedent within the main document. The table provides the case names, citations, and the page numbers where they are referenced in the brief.
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This legal document, filed on February 4, 2021, argues against the retroactive application of a 2003 Amendment to the alleged offenses of Ms. Maxwell. The author contends that Congressional intent was clear in rejecting retroactivity and that applying the amendment would have impermissible effects. The argument is supported by legal precedents, including Landgraf, Toussie, and Gentile, which favor interpreting criminal statutes of limitation in a way that provides 'repose' for the defendant.
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This document is page 71 of a court filing (Document 397) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. It is a legal argument by the prosecution opposing a defense motion to suppress an identification made by Minor Victim-4. The text argues that the victim's identification is reliable because she had multiple personal interactions with the defendant between 2001 and 2004, and concludes by asking the court to deny the defense's motion.
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This legal document is a page from a court filing, specifically Document 397 in case 1:20-cr-00330-PAE, filed on October 29, 2021. The text argues for the admissibility of expert testimony from a Dr. Rocchio, who would explain the psychological dynamics of abusive relationships to help the jury understand why victims might act in counterintuitive ways, such as returning to an abuser. The document cites several other cases to support the argument that such dynamics are beyond the common knowledge of an average juror, while also noting the defendant's objection that this type of testimony is not how Rule 702 is meant to work.
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This legal document, filed on October 29, 2021, argues against the defendant's claim regarding expert testimony in a sex trafficking case. It cites Judge Engelmayer's reasoning from another case (United States v. Randall) to assert that statistical error rates are an 'unusually poor fit' for evaluating qualitative research on trauma and grooming. The document concludes that the proper way to challenge the expert's (Dr. Rocchio's) findings is through cross-examination before a jury, not by deeming them irrelevant under a Daubert analysis.
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This legal filing (Document 397 in Case 1:20-cr-00330-PAE) argues for the admissibility of expert testimony regarding sex trafficking, coercive control, and the psychological relationship between pimps and victims. It cites several precedents (Kelly, Torres, Randall, Dupigny) where such testimony was permitted. Specifically, it defends the qualifications of Dr. Rocchio, a Brown University professor with 25 years of clinical experience, noting that the defendant does not contest her expertise.
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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'.
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This document is a page from a legal filing, specifically page 7 of document 397 in case 1:20-cr-00330-PAE, filed on October 29, 2021. It outlines the legal standard for admitting expert testimony under the 'Daubert' framework, citing Federal Rule of Evidence 702 and numerous precedent cases. The text explains that a court must first assess an expert's qualifications and then determine if their testimony is both relevant and reliable, detailing several criteria for establishing reliability.
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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 legal document is part of a motion where a defendant proposes a new, comprehensive bail package to secure release from pretrial detention. The defendant offers a $28.5 million package, secured by property and cash, and co-signed by her spouse, friends, and family, along with conditions like home confinement, GPS monitoring, and restricted travel. The motion cites legal precedents affirming the court's authority to reconsider its previous bail decisions.
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This legal document, filed on February 18, 2020, argues for the continued detention of a female defendant, asserting she is a significant flight risk due to her financial means, foreign ties, and skill at hiding. The filing dismisses proposed bail conditions, such as private security guards and GPS monitoring, as insufficient to ensure her appearance in court. To support its position, the document cites several past federal cases (Banki, Zarger, Benatar) where courts denied bail under similar circumstances, deeming electronic monitoring and home confinement inadequate for high-risk defendants.
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This document is page 18 of a government filing (Document 102) from June 18, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues against bail by highlighting flight risks, specifically noting that France does not extradite its own citizens (citing the 'Peterson' case) and arguing that any 'anticipatory waiver' of extradition the defendant might sign regarding the United Kingdom is legally unenforceable under UK law (referencing the Extradition Act of 2003 and U.S. v. Stanton). The prosecution asserts that such waivers are meaningless until a defendant is physically present before a British judge.
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This legal document, part of a court filing, argues on behalf of Ms. Maxwell by citing several past U.S. court cases where defendants waived extradition rights to demonstrate they were not a flight risk. It then introduces expert reports, specifically one from U.K. barrister David Perry, which conclude it is highly unlikely Ms. Maxwell could successfully resist extradition from the U.K. or France back to the United States, further supporting the argument that she is not a flight risk.
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This legal document argues that the court should reconsider Ms. Maxwell's bail application based on new evidence. It cites legal precedents affirming the court's authority to reconsider such decisions and states that Ms. Maxwell has received over 2.7 million pages of discovery from the government since her initial hearing, which allegedly raises serious questions about the strength of the government's case.
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This document is page 12 of a legal filing (Case 1:20-cr-00330-PAE) filed on October 29, 2021. It is a legal argument seeking to exclude the testimony of an expert witness named Rocchio, arguing that her opinions on 'grooming' and sexual abuse are based on unverified personal beliefs rather than scientific methodology or representative studies. The text cites various legal precedents (including Supreme Court rulings) to support the claim that Rocchio's testimony is unreliable and 'virtually impregnable for purposes of cross-examination.'
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This legal document, part of a court filing from October 29, 2021, argues against the admissibility of expert opinions from a treatment provider named Rocchio. The filing contends that Rocchio's opinions on grooming are based solely on personal experience, lack a reliable methodology, and are not supported by scientific literature. It cites various legal precedents and an academic article to assert that her testimony fails to meet the standards for expert witnesses.
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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 is a portion of a motion filed by the prosecution ('Government') arguing against the defense's desire to introduce evidence related to a past charging decision from a Florida investigation. The prosecution contends this evidence is irrelevant, cumulative, and would invite the jury to speculate, creating a 'bizarre spectacle' that distracts from the actual evidence of the current trial. The document cites case law to support its position that the jury should only consider the evidence presented in this specific case, not the prosecutorial decisions made in other jurisdictions.
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This document is a legal filing from the prosecution ("the Government") in case 1:20-cr-00330-PAE, filed on October 29, 2021. The Government argues that the Court should prevent the defense from discussing certain issues or offering related evidence during its opening statement and the trial, claiming such evidence is irrelevant, inadmissible, and prejudicial. The filing cites several legal precedents to support the Court's authority to limit the defense's presentation to ensure a fair trial and avoid a mistrial.
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