S.D.N.Y.
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This document is page 3 of a court filing (Case 1:20-cr-00330-AJN) filed on November 6, 2020, likely in the prosecution of Ghislaine Maxwell. The Government argues regarding discovery deadlines, agreeing to a laptop for the defendant to review evidence at the MDC but refusing early disclosure of witness lists (Giglio/Jencks material) seven months before trial. The text details upcoming discovery productions, specifically mentioning thousands of images/videos from Epstein's electronic devices, portions of seized iPads and an iPhone, and documents from the FBI's Florida files.
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This is page 3 of a legal filing (Case 1:20-cr-00330-AJN, likely US v. Ghislaine Maxwell) dated November 6, 2020. The Government argues against the immediate production of witness lists (Giglio/Jencks material), stating it is premature seven months before trial. The document details an upcoming 'sixth discovery production' due November 9, 2020, which includes thousands of images/videos from Jeffrey Epstein's electronic devices, portions of his iPads and iPhone, and FBI Florida files.
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This legal document is a letter dated October 14, 2020, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell argues against the government's request to delay the disclosure of evidence to his client, Ms. Maxwell, in case 1:20-cr-00330-AJN. He asserts the government has not provided sufficient legal justification, such as risks to an ongoing investigation or witness safety, and asks the court to order the immediate production of the materials to the defense.
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This legal document is a letter dated August 24, 2020, from Jeffrey S. Pagliuca to Judge Alison J. Nathan. Pagliuca argues on behalf of his client, Ms. Maxwell, for a limited request to present sealed materials to other judicial officers, asserting that the materials are judicial documents and that disclosure would not compromise grand jury secrecy. The letter contends that the government has failed to provide a sufficient reason to prevent this limited disclosure.
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This legal document, dated August 17, 2020, is a filing addressed to Judge Alison J. Nathan on behalf of Ms. Maxwell. It argues for the court's discretion in handling certain materials, citing legal precedent from the Second Circuit for staying civil proceedings during a related criminal case to protect Fifth Amendment rights. The filing also discusses the proper jurisdiction for interpreting a protective order from a separate civil case, suggesting the government has previously agreed that the civil court, not this criminal court, is the appropriate forum.
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This document is page 2 of a court order filed on September 2, 2020, in case 1:20-cr-00330-AJN. The court denies the defendant's request to modify a protective order that was previously entered on July 30, 2020. The court's decision is based on the original agreement between the parties, which stipulated that discovery materials provided by the government would be used solely for the defense of the current criminal case and not for any civil proceedings.
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This legal document is a filing by the Government to Judge Alison J. Nathan in a criminal case, dated August 13, 2020. The Government argues that the defendant's request for more detailed charges is premature and should be handled through a formal motion for a bill of particulars after discovery is complete. The filing also expresses significant concern over the defense counsel's recent actions in a related civil case, suggesting they may have violated a protective order by publicly referencing sealed discovery materials.
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This document is page 3 of a legal filing (Document 38) dated August 10, 2020, addressed to Judge Alison J. Nathan in the case United States v. Ghislaine Maxwell. The defense argues for the pretrial disclosure of the identities of 'Victims 1-3,' citing legal precedents that a defendant's right to prepare a defense outweighs privacy interests when a protective order is in place. The filing asserts that because the victims are now adults and many have already spoken publicly or filed civil suits against Epstein and Maxwell, there is no risk of intimidation.
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This document is page 2 of a court filing (Case 1:20-cr-00330-AJN) dated July 30, 2020. The Court rules in favor of the Government regarding a protective order, restricting Ghislaine Maxwell and her defense team from publicly disclosing the identities of alleged victims and witnesses, even those who may have previously made public statements about Maxwell or Jeffrey Epstein. The judge argues that participating in a criminal investigation warrants privacy protection distinct from previous voluntary public statements.
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This legal document, page 3 of a filing to Judge Alison J. Nathan dated July 29, 2020, presents the defense's argument against a government-proposed protective order in the case against Ms. Maxwell. The defense contends the order would impede their ability to investigate alleged victims and witnesses, citing legal precedents where individuals waived their privacy rights by making information public. The document asserts the need for a full investigation to challenge the credibility of accusers and mount an effective defense for their client, who is presumed innocent.
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This legal document, filed on July 28, 2020, is the government's argument against a defendant's request to publicly name victims of herself or Epstein. The government contends that such disclosure is inappropriate and violates victims' rights to privacy and safety, citing the Crime Victims' Rights Act and several legal precedents. The filing supports a proposed protective order that would prevent public identification of victims while still allowing the defense to prepare for trial.
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This legal document, dated July 27, 2020, is a filing to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The filing argues in favor of Maxwell's proposed protective order, which would allow her defense team to publicly reference alleged victims or witnesses who have already spoken on the public record regarding Maxwell or Jeffrey Epstein. It contrasts this with the government's more restrictive proposal, arguing the government's position is 'broader than necessary' and would hinder the defense's ability to prepare for trial.
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This legal document, dated July 27, 2020, is a filing in the criminal case of Ms. Maxwell, addressed to Judge Alison J. Nathan. It discusses the legal standard for a protective order over discovery materials, arguing that restrictions should apply not only to the defense but also to the government's potential witnesses and their counsel. The filing expresses concern that these witnesses, who are also involved in civil litigation against Ms. Maxwell, might use the discovery materials to support their civil cases or in public statements.
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This legal document, part of a court filing from July 13, 2020, argues against a defendant's motion for temporary release. It cites two prior rulings from the Southern District of New York (involving Gonzalez and Eley) to establish that release is not necessary, especially when trials are not imminent. The document further contends that the detention center (MDC) has been responsive and accommodating to defense counsel's requests for client access, undermining the argument that release is required for defense preparation.
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This document is page 15 of a Government memorandum filed on July 13, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The prosecution argues against granting bail, citing that the MDC is adequately handling COVID-19 risks and referencing legal precedents where bail was denied despite the pandemic. A footnote emphasizes the Government's position that the defendant has the financial means to flee the country and that pandemic travel restrictions would not prevent her flight.
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This legal document argues against a defendant's request for bail. It contends the defendant is a significant flight risk due to substantial financial resources, international ties, and a lack of connection to the United States. The document also asserts that the COVID-19 pandemic is not a sufficient reason for release, citing several legal precedents from New York district courts that have denied similar applications.
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This legal document is a portion of a filing arguing for bail for Ms. Maxwell. The defense contends that the COVID-19 pandemic significantly mitigates her flight risk, citing a recent ruling in another case (U.S. v. El Mokadem) where a defendant was released for this reason. The filing also distinguishes Maxwell's case from Epstein's, arguing the government does not allege she poses a current danger to the community, and that her alleged offenses ended in 1997.
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This document is page 20 of a legal filing (Document 18) dated July 10, 2020, in the case United States v. Ghislaine Maxwell. The text argues against the government's assertion that Maxwell is a flight risk, citing her isolation as a protective measure rather than an attempt to flee, and noting that wealth and foreign citizenship alone are insufficient grounds for detention without proof of 'inclination' to flee. It also argues that COVID-19 travel restrictions make flight unlikely and mentions in a footnote that individuals in the media (specifically in the UK) are falsely claiming to have ties to her.
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This is page 9 of a legal filing (Document 18) dated July 10, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues that Maxwell should be released on bail because the government failed to prove she is a flight risk and because the COVID-19 pandemic poses a significant health risk to her in detention, citing the precedent of United States v. Stephens. The document also highlights that detention would hinder her ability to prepare a defense due to restrictions on attorney access.
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This legal document is a court's conclusion, filed on July 6, 2020, justifying the partial closure of a court hearing due to the COVID-19 pandemic. Citing the precedent of United States v. Alimehmeti, the court rules that the hearing will proceed via video and telephone conference to protect public health, while ensuring public access is maintained by telephone.
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This legal document, part of a court filing, refutes claims made by an inmate named Maxwell regarding her conditions of confinement at the MDC. It distinguishes her situation from a case involving Tiffany Days, who experienced sewage flooding at a different facility (the MCC), and argues there is no evidence of such issues at the MDC. The document also counters Maxwell's claim of being in "solitary confinement" by detailing her daily access to a day room and various amenities for thirteen hours.
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This legal document, page 14 of a court filing dated May 27, 2021, outlines the legal standards for reviewing a district court's detention order and for considering a defendant's temporary release. It cites U.S. statutes and several legal precedents, including United States v. Watkins and United States v. Scarborough, to establish that the court applies a 'deferential review' and that a defendant bears the burden of proving temporary release is necessary for their defense or for other compelling reasons.
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This document represents page 17 of a legal brief filed on April 12, 2021, arguing against the release of Ghislaine Maxwell. The text asserts that Judge Nathan did not err in denying bail, citing Maxwell as a flight risk and noting the strength of the Government's evidence, which includes multiple victims and documentary corroboration. It discusses legal standards for temporary release under 18 U.S.C. § 3142(i) and cites relevant case law.
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This legal document is a court filing arguing against a defendant's third motion for release on bail. The author, likely the prosecution (Government), contends that the defendant remains an extreme flight risk due to strong evidence, substantial resources, and foreign ties to a non-extraditing country. The document dismisses the defendant's new proposals—renouncing foreign citizenship and placing some assets under monitorship—as insufficient to ensure their appearance in court and urges the motion to be denied.
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This legal document is a page from a court filing that discusses the enforceability of an anticipatory waiver of extradition, likely in the context of Ghislaine Maxwell's case. The author argues that the defendant has not provided cases where such waivers are enforceable and cites several past court decisions (e.g., Epstein, Morrison, Stroh) where courts have deemed such waivers unenforceable, invalid until a formal request is made, or an 'empty gesture'. The document contrasts these with cases cited by the defense (e.g., Cirillo, Salvagno) where waivers were considered but were not the central factor in the court's reasoning.
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