S.D.N.Y.
LocationRelationship Network
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This legal document is a page from a government filing arguing in favor of a limited sealing request to protect the identities of minor victims. The government asserts that this request is minimally burdensome and legally sound, citing precedents where victim privacy outweighs public access, especially for evidence not yet shared in open court. It directly refutes the defense's claim that the request violates Second Circuit law by distinguishing the cases the defense relies upon.
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This legal document is a page from a government motion arguing against publicizing the full names of four minor victims in an upcoming criminal trial. The government contends that the defense has not shown a specific need for this disclosure, and that the court should prioritize the victims' privacy and dignity. The motion cites several legal precedents that support protecting witnesses' identities, especially when safety and privacy are concerns.
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This legal document is a filing by Ms. Maxwell's counsel arguing against the government's motion to limit the introduction of her statements at trial. The defense contends the motion is premature and improper because the government has not identified any specific hearsay statements it seeks to exclude. The filing asserts that the correct procedure is for the government to object to any potential hearsay testimony as it arises during the trial, allowing the Court to rule on admissibility in context.
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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 is a filing by the defense in the case against Ms. Maxwell, arguing against the government's motion to preclude evidence related to its motives for prosecution. The defense asserts its right to present evidence about the timing of the charges against Maxwell in relation to Jeffrey Epstein's 2019 death, not to claim 'vindictive prosecution,' but to challenge the thoroughness and reliability of the government's investigation. The defense argues that the government's motion is an overreach and an attempt to force the disclosure of their trial strategy.
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This page is from a legal filing (Document 380) in the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on October 29, 2021. It contains a Government argument (Section A) requesting the Court preclude the Defense from presenting evidence regarding government charging decisions. The text cites Federal Rules of Evidence 402 and 403 and case law (Rosado, Borrero) to argue that such evidence is irrelevant, hearsay, and likely to confuse the jury.
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This document is page 6 of a legal filing (Document 195) from the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE), filed on April 5, 2021. The Government is arguing that the Court should require notice for all Rule 17(c) subpoenas rather than allowing them to be issued *ex parte* (without notice), citing various legal precedents (Wey, Earls, Skelos, St. Lawrence, Boyle) to support the position that *ex parte* proceedings should only be permitted with a compelling reason. Footnotes clarify the Government's concern regarding financial institutions responding to broad subpoenas for impeachment purposes and state that this request does not apply to subpoenas returnable at trial.
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This document is Page 4 of a legal filing (Document 195) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell) filed on April 5, 2021. The text argues that defense subpoenas asking for 'any and all' records are improper discovery requests and asserts that the Court should require the Defendant to notify the Government of any Rule 17(c) subpoena applications. It cites concerns regarding the harassment of witnesses and the protection of victim confidentiality.
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This legal document, page 3 of a filing from April 5, 2021, discusses the legal standard for obtaining documents via a subpoena under Rule 17(c). It heavily references the precedent set in 'United States v. Nixon', emphasizing that a request for documents must be made in good faith, be specific, and not constitute a general 'fishing expedition'. The document argues that courts require a stringent showing that the requested materials are relevant, admissible, and specifically identified, rather than just potentially useful to a case.
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This legal document, dated March 22, 2021, is a submission by Sigrid S. McCawley arguing against a defendant's motion to subpoena evidence from a third party, BSF. The document contends that the requested materials—including communications, a Grand Jury subpoena, cowboy boots, and photographs involving individuals like Annie Farmer, Virginia Giuffre, and Jeffrey Epstein—are either obtainable from the government or not relevant enough to require pre-trial production. The author concludes that the defendant's motion should be denied.
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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 document is a page from a legal brief filed by the Government on October 29, 2021, in case 1:20-cr-00330-PAE. The Government argues that it has provided sufficient and timely notice to the defense regarding Rule 404(b) evidence, citing the provision of extensive materials and relevant legal precedents. The brief refutes the defense's motion to preclude evidence based on claims of inadequate notice.
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This legal document, filed on October 29, 2021, argues for the admissibility of expert testimony from a Dr. Rocchio in a criminal case. The document outlines Dr. Rocchio's intended opinions on how grooming facilitates sexual abuse and why victims often delay disclosing trauma, asserting these opinions are reliable and supported by psychological literature. It distinguishes the defendant's alleged actions from 'grooming by proxy' and cites academic research to bolster the validity of the expert's claims about delayed disclosure.
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This document is a 'Table of Authorities' from a legal filing in case 1:20-cr-00330-PAE, filed on October 29, 2021. It lists two legal cases, 'Old Chief v. United States' (1997) and 'United States v. Salim' (2002), as well as three Federal Rules of Evidence (401, 403, 404). These authorities are cited to support arguments made elsewhere in the full legal document.
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This legal document is a portion of a motion arguing to exclude evidence of an alleged rape committed by Mr. Epstein from the trial of Ms. Maxwell. The argument posits that such evidence is not part of the charged conspiracy (which is limited to securing "sexualized massages"), is highly inflammatory and unduly prejudicial, and would confuse the jury, leading to a conviction on an improper emotional basis. The document cites several legal precedents to support the exclusion of this evidence under Rule 403.
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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 7 of a court filing from April 5, 2021, analyzes Federal Rule of Criminal Procedure 17(c) concerning ex parte applications for pretrial subpoenas. It contrasts the majority view, which generally disfavors such applications unless for trial use, with specific court precedents that permit them to protect sensitive information like trial strategy. The text cites several cases, including Weisman, Fox, and Reyes, to illustrate the legal arguments and differing practices among court districts.
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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 document is page 17 of a court order filed on March 24, 2021, in the case United States v. Schulte (Case 1:17-cr-00548-PAC). The text details the Court's rejection of the defendant's (Schulte) challenges regarding jury selection, specifically concerning the 'fair cross-section' requirement of the Sixth Amendment and an 'Equal Protection' challenge under the Fifth Amendment. The Court dismisses arguments regarding the underrepresentation of African American and Hispanic American jurors, citing a lack of discriminatory intent and noting that a technical glitch in the White Plains master wheel actually increased minority representation rather than diminishing it.
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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 legal document, filed on March 24, 2021, is a court order outlining the procedure for a law firm representing alleged victims to object to a proposed subpoena. The Court acknowledges receipt of a letter from the firm on March 19, 2021, and sets a deadline of March 26, 2021, for the firm to formally file its objections. The order mandates that the law firm must first confer with defense counsel to potentially narrow the issues and discuss redactions, citing legal precedents for these procedures.
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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 document is page 11 of a legal filing (Document 146) from the Ghislaine Maxwell case, dated February 4, 2021. The defense argues that allegations regarding 'Accuser-3' are time-barred because the statute of limitations expired before the 2003 amendment to 18 U.S.C. § 3283, and retroactive application would violate the Ex Post Facto Clause. Furthermore, the defense contends that allegations involving Accuser-3 are irrelevant to the conspiracy charges, which should only pertain to Accuser-1 and Accuser-2.
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This document is page 2 of a legal filing (Document 362) from the United States v. Ghislaine Maxwell case (1:20-cr-00330), filed on October 20, 2021. The text argues for public access to the jury selection process (voir dire) and juror questionnaires, citing numerous legal precedents including United States v. Shkreli and Press-Enterprise Co. v. Superior Court. It asserts that First Amendment rights require these proceedings and documents to be presumptively open to the press and public.
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