S.D.N.Y.
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This document is page 6 of a court filing (Case 1:20-mj-00132-AJ) dated July 2, 2020. It discusses the court's decision to implement a partial closure of the courtroom, conducting the hearing via video and telephone conference due to the COVID-19 pandemic. The court argues this is necessary for public health and cites United States v. Alimehmeti as a precedent for partial closures.
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This legal document, filed on June 22, 2022, is a portion of a court filing arguing that the judge (the Court), not the jury, is responsible for determining which version of the Sentencing Guidelines to apply in a case. The filing cites legal precedent from the Second Circuit and the text of the Guidelines themselves to refute the defendant's claim that this factual determination must be made by a jury, particularly regarding the date of an offense for ex post facto considerations.
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This legal document is a portion of a court filing arguing against a defendant's motion. The defendant seeks to strike a motion to intervene filed by 'Juror 50', claiming it is inappropriate and not a 'judicial document' deserving public access. The author of this filing refutes these claims, arguing that the defendant's cited legal precedents are inapplicable and that Juror 50's motion is relevant to the judicial process and should not be struck.
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This legal document argues that the court should deny the defendant's request for a post-verdict hearing and 'pre-hearing discovery' concerning juror conduct. The argument is based on legal precedent, stating that the defendant's evidence—a single anonymous sentence from a newspaper article—is inadmissible hearsay and does not meet the required standard of 'concrete allegations.' The document cites several cases to support the position that courts routinely deny such inquiries to protect the finality of verdicts and avoid the dangers of post-verdict juror scrutiny.
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This document is page 41 of a legal brief filed on February 24, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text argues against granting an evidentiary hearing regarding juror misconduct allegations, citing precedents from cases involving El Chapo (Guzman Loera), Bin Laden, and Martha Stewart. The argument asserts that unsworn newspaper reports or anonymous claims are insufficient evidence to warrant a juror inquiry.
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This legal document, part of a court filing, argues against holding an evidentiary hearing to question a jury based on an anonymous, hearsay report. It cites legal precedent from cases like *United States v. Stewart* and *United States v. Guzman Loera* to assert that a high standard of evidence is required for such a hearing, which anonymous tips do not meet. The document details the *Guzman Loera* case as an example where a court denied a hearing despite allegations of juror misconduct published in a magazine article.
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This legal document is a portion of a court filing by the U.S. Government, likely a motion or memorandum. It cites various legal precedents to establish the standards for conducting a post-verdict inquiry into potential juror misconduct. The Government argues that these standards have been met with respect to 'Juror 50' due to an inconsistency between his public statements about being a victim of sexual abuse and his answer on a juror questionnaire, and therefore consents to a hearing to determine if the juror lied.
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This legal document argues against the automatic presumption of juror bias when a juror has engaged in conduct similar to the defendant's. It cites multiple court cases from various circuits (First, Second, Seventh, Ninth, Tenth) to support the position that juror removal is reserved for "extreme situations" and that a finding of bias often depends on a combination of factors, not just a similarity of experience. The document distinguishes cases cited by the defendant, arguing they are either inapposite or involve unique, egregious facts not present in the current matter.
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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 legal document, filed on February 24, 2022, argues against setting aside a jury verdict. It establishes that the standard for doing so is an "exacting hurdle," citing Federal Rule of Evidence 606(b), which severely restricts jurors from testifying about their deliberations. The document contrasts this federal standard with New Jersey state law and clarifies that only specific, improper outside influences, not a juror's personal experiences, can be grounds for such an inquiry.
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This legal document is a filing on behalf of Ms. Maxwell arguing that the court should strike all filings made by 'Juror No. 50.' The argument posits that the juror, as a non-party, lacks standing and that the filings are an improper attempt at discovery, not 'judicial documents' entitled to public access. Alternatively, it requests that the juror's filings remain sealed pending the outcome of Ms. Maxwell's motion for a new trial, which is based on the same juror's alleged dishonesty during jury selection.
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This document is a page from a legal filing that argues for a defendant's right to a fair trial by an impartial jury under the Sixth Amendment. It cites multiple legal precedents to underscore the critical importance of the voir dire process, which must provide defendants with a full and fair opportunity to uncover potential juror bias. The text establishes that ensuring an impartial jury is a fundamental principle of constitutional law and due process.
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This page from a legal filing in the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE) argues that 'Juror 50' must be allowed to review their own Jury Questionnaire and voir dire transcript. The filing asserts this review is necessary for the juror to address questions regarding their truthfulness about prior sexual abuse, in compliance with a January 5, 2022 order by Judge Nathan. It cites legal precedents regarding third-party intervention and privilege.
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This document is page 8 of a court filing (Document 609) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 24, 2022. It presents legal arguments citing various precedents to establish that jurors retain privacy interests after a trial concludes and that jurors face criminal exposure for perjury on questionnaires. It also argues that third parties may intervene in criminal trials to protect their constitutional rights.
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This document is page 4 of a legal filing (Document 604) in case 1:20-cr-00330-PAE, filed on February 17, 2022. The filing party, NACDL, argues for the importance of its perspective in the case, citing legal precedents like Skilling v. United States regarding jury selection and other cases concerning the role of amicus curiae (friends of the court). The document aims to persuade the court to consider its suggestions on ensuring juror honesty and establishing a fair framework for the proceedings.
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This document is page 25 of a legal filing (Document 600) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 11, 2022. The text outlines legal arguments regarding the Double Jeopardy Clause of the Fifth Amendment, specifically focusing on how to determine if multiple conspiracy charges constitute the same offense. It details a multifactor test adopted by the Second Circuit to distinguish between single and multiple conspiracies.
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This legal document, dated February 9, 2022, from Winston & Strawn LLP, describes the National Association of Criminal Defense Lawyers (NACDL) and its practice of filing amicus curiae briefs. It cites legal precedents for amicus participation and requests the Court's permission to file an amicus brief regarding a motion for a new trial based on juror misconduct. The document notes that Counsel for the Defendant has consented, while Counsel for the DOJ has not yet responded to inquiries.
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This legal document is a court order from case 1:20-cr-00330-PAE, filed on February 11, 2022. The Court denies two separate requests: first, it denies Juror 50's motion to intervene in the criminal case, and second, it denies the Defendant's requests to either strike or seal Juror 50's motion. The Court's reasoning relies on legal precedent, stating that motions to strike are disfavored and that Juror 50's motion qualifies as a judicial document subject to the presumption of public access.
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This is page 3 of a court order filed on Feb 11, 2022, in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330). The Court rules against the Defendant's request to completely seal motion papers related to an inquiry into 'Juror 50,' stating that wholesale sealing is not narrowly tailored to serve the interest of justice. The Judge notes that much of the information is already public and that the Court, as the fact-finder for the inquiry, is already privy to the information regardless of sealing.
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This legal document argues that the risks of COVID-19 to inmates in correctional facilities have significantly increased, citing a doubling of cases and a 73% increase in deaths in the last month. It highlights that the virus is now spreading in the Metropolitan Detention Center (MDC), where Ms. Maxwell was recently transferred by the Bureau of Prisons. The document uses prior court opinions and news reports to support the claim of heightened risk and the inevitability of community spread in such facilities.
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This document is page 'iii' (Table of Authorities) from a legal filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It lists legal precedents cited within the brief, including 'United States v. Epstein' (2019) and 'United States v. Salerno' (1987), along with a citation to 18 U.S.C. § 3142 regarding bail/detention. The page bears a Bates stamp DOJ-OGR-00019878.
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This legal document argues that the government has failed to meet its burden of proof regarding Ms. Maxwell's flight risk, citing Supreme Court precedent on bail. It references the case of United States v. Bodmer, where a defendant was released to home confinement with GPS monitoring despite the government's speculative arguments. The document concludes that Ms. Maxwell should receive similar treatment to other defendants granted bond.
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This document is a court docket sheet (Page 23 of 24) from 'Case 21-58' covering entries from March 22 to March 24, 2021. It details the denial of Ghislaine Maxwell's third motion for bail by Judge Alison J. Nathan and Maxwell's subsequent notice of appeal. Additionally, it contains a detailed order regarding a defense subpoena directed at a law firm representing alleged victims, requiring the firm to file objections on the public docket.
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This document is a page from a court docket (likely an appellate record for Case 21-58) detailing events in the US v. Ghislaine Maxwell case between December 18 and December 28, 2020. It records the filing of legal arguments regarding Maxwell's renewed bail motion, the Judge's orders approving specific redactions to protect third-party privacy, and ultimately the Court's order on December 28 denying the defendant's motion for release on bail. The document lists Maurene Comey for the prosecution and Christian Everdell for the defense.
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This document is a court docket sheet from late July 2020 detailing filings in the case of USA v. Ghislaine Maxwell. It records a dispute regarding a protective order, where the defense sought to allow Maxwell to publicly name victims who had already spoken publicly about her or Jeffrey Epstein. Judge Alison Nathan ruled in favor of the Government, adopting their proposed protective order to restrict Maxwell from disseminating the identities of alleged victims or witnesses to protect their privacy.
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