This legal document, part of a court filing, argues that Ms. Maxwell must be sentenced under the 2003 Guidelines rather than the harsher 2004 Guidelines. It asserts that applying the 2004 Guidelines would violate the Ex Post Facto Clause unless a jury, not the judge, found that her criminal conduct continued past November 1, 2004. Since the jury made no such finding, the court is bound to use the earlier guidelines.
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.
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.
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.
This legal document, filed on October 29, 2021, is part of a court case where the Government is arguing against a defendant's motion. The Government contends that the defendant has not shown a 'particularized need' to publicly disclose the true names of the 'Minor Victims' during trial. The Government asserts that the defendant already knows the victims' identities and can conduct a thorough cross-examination without this public disclosure, which would protect the victims' privacy.
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.
This document is a page from a legal filing, dated October 29, 2021, arguing for the use of pseudonyms for testifying victims. It cites several legal precedents from the Eastern and Southern Districts of New York, including the cases of Raniere, Martinez, Schulte, and Hernandez, to support the argument that protecting victims from harassment, embarrassment, and encouraging testimony outweighs defense interests, particularly in sensitive cases like sex trafficking and national security.
This document is page 6 of a legal filing from Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on October 29, 2021. It discusses legal standards and Second Circuit precedents regarding the protection of witness identities versus a defendant's right to cross-examination. The text cites various cases (Marcus, Marti, Urena, Cavallaro) to support the argument that courts must balance witness safety against the defense's need for information, particularly in cases involving sex trafficking or safety risks.
An email chain from August 2012 between Barbro Ehnbom and Jeffrey Epstein (using the alias jeevacation). Epstein explicitly asks Ehnbom for a 'wife choice' for the year, to which she replies with the name and photo of a 'brainy and sensual' female project manager. The thread also discusses an invitation to Bill Clinton, a fundraiser for Congresswoman Diana deGette, and mutual friends including 'Goldsamt' in Miami.
This document is page 389 of a bibliography from a book, likely related to mathematics, logic, physics, music, or consciousness studies, given the titles listed (e.g., 'Gödel’s Theorem', 'Musicophilia', 'The Emperor’s New Mind'). It lists citations for works by prominent scientists and thinkers such as Roger Penrose, Douglas Hofstadter, Oliver Sacks, and Alan Turing. The page includes a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was produced as evidence for a congressional investigation, likely regarding Jeffrey Epstein's connections to the scientific community.
This document appears to be pages 101-102 from a manuscript (likely Virginia Giuffre's memoir). The narrator, identifying herself as 'Jenna,' recounts a phone call with a scared friend named T.J., leading her to drive to a drug-ridden apartment in downtown Palm Beach to rescue him. She finds T.J. in a 'K-Hole' inside a squalid apartment, physically drags him out to her truck, and takes him home to clean him up, noting that she has free time because 'Jeffrey' (presumably Epstein) is in Palm Beach entertaining royalty.
This document appears to be an excerpt from a manuscript (likely Virginia Giuffre's unpublished memoir, given the Bates stamps) recounting a period involving drug use in Palm Beach. The narrator, identifying herself as 'Jenna', is searching for her ex-boyfriend T.J. and contacts a drug dealer named Ritchie-Rich. During her search, she learns from an acquaintance named Marcus that T.J.'s best friend, Adam, was recently murdered during a drug deal that T.J. failed to show up for.
Jenna asks for Ritchie's number to find T.J.; Marcus reveals Adam was killed.
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