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This is a legal letter from Neil S. Binder of Binder & Schwartz LLP to Judge Paul A. Engelmayer regarding the case United States v. Maxwell. The letter, submitted under seal, addresses the DOJ's motion to unseal grand jury materials that reference the firm's client (whose name is redacted), arguing for the continued maintenance of grand jury secrecy based on established precedent and the lack of justification for special circumstances.
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This document is page 3 of a legal filing (Case 1:20-cr-00330) addressed to Judge Paul Engelmayer, dated August 6, 2025. It argues for strict protocols and heightened caution regarding the unsealing of grand jury materials to protect the privacy and safety of Epstein and Maxwell's victims, citing the Crime Victims' Rights Act (CVRA) and Rule 6(e). A significant footnote highlights that several victims have already died by suicide or overdose and argues that a potential pardon would cause irreparable harm.
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A page from a legal filing (Case 1:20-cr-00330-PAE) arguing against the unsealing of grand jury materials. The defense argues that because the grand jury convened only five years prior and Ghislaine Maxwell is still actively litigating her case (including a pending Supreme Court petition), releasing the materials would cause irrevocable reputational harm and taint the legal process. The filing explicitly notes that while Epstein is dead, Maxwell is alive, distinguishing this case from others where secrecy is no longer needed due to the death of principal parties.
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This legal document is a response filed by Ghislaine Maxwell's defense team in the U.S. District Court for the Southern District of New York. The defense opposes the government's motion to unseal grand jury transcripts, arguing that since Maxwell is alive and actively litigating her case (which is pending before the Supreme Court), releasing the transcripts would violate her due process rights. The defense also claims they cannot take an informed position as the Court has denied their request to review the materials themselves.
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This legal document, dated August 4, 2025, is a letter from the Government to Judges Richard M. Berman and Paul A. Engelmayer. It outlines the submission of grand jury materials related to the Epstein and Maxwell cases, including the dates the respective grand juries met. The Government discusses the process of identifying publicly available information from these materials and presents a legal argument that a 'nolle prosequi' in the Epstein case does not prevent the court from disclosing sealed records.
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This legal document is a motion filed by the U.S. Attorney General's office, arguing that the Court should release grand jury transcripts from the Epstein and Maxwell cases. The motion contends that public interest, coupled with the diminished privacy interests following Epstein's death, justifies this release, despite Maxwell's case being pending before the Supreme Court.
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This legal document discusses the application of Rule 33 motions concerning juror responses during voir dire, referencing the McDonough standard. It details the District Court's finding that Juror 50's erroneous responses were not deliberately incorrect and that Maxwell did not challenge other jurors with similar disclosures. The document cites several legal precedents, including United States v. Gambino and McDonough Power Equipment, Inc. v. Greenwood, to support its legal arguments regarding the standard for overturning trial results based on juror honesty.
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This document is page 15 of a legal filing (likely a government appellate brief) concerning United States v. Ghislaine Maxwell. It discusses the legal applicability of 18 U.S.C. § 3283 (statute of limitations for child abuse offenses) to the specific facts of the case, rejecting a 'categorical approach.' It specifically mentions witness 'Jane,' who testified to being sexually abused after being transported across state lines as a minor, and addresses Maxwell's argument that certain counts are barred by the statute of limitations.
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This document is page 88 of a court transcript from case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on August 22, 2022. The Judge ('The Court') is addressing the courtroom regarding sentencing guidelines, stating the applicable range is 188 to 235 months' imprisonment. The Judge outlines the legal requirements under *Booker* and 18 U.S.C. 3553(a) for determining a sentence that is 'sufficient, but no greater than necessary.'
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This document is page 20 of a court transcript (Document 779) filed on August 22, 2022, in Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell). The text records a defense attorney arguing that determining when offense conduct ended is a matter for the jury, specifically to avoid Ex Post Facto violations regarding sentencing guidelines. The speaker cites the 'Tykarsky' opinion and distinguishes the current situation from 'Apprendi' case law.
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This document is page 5 of a court transcript from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. The Judge is issuing a ruling regarding the Sixth Amendment confrontation clause and the admissibility of evidence concerning the thoroughness of the government's investigation. The Court rules to preclude the defense from introducing affirmative evidence attacking the investigation's thoroughness unless it is probative of the defendant's guilt, citing cases such as United States v. Figueroa and Kyles v. Whitley.
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This legal document, part of a court filing dated December 17, 2021, outlines the legal principles guiding the court's analysis of the government's investigation into Ms. Maxwell. It references precedents from the Second Circuit and the Supreme Court to establish rules regarding investigative techniques, challenges to government motives, and the admissibility of evidence related to charging decisions.
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This is a legal letter dated July 21, 2020, from Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C., to Judge Alison J. Nathan of the Southern District of New York. The attorney, representing defendant Ghislaine Maxwell, requests that the court issue an order prohibiting the U.S. Government and its affiliates from making extrajudicial statements about the case, arguing such statements are prejudicial and violate Maxwell's Sixth Amendment right to a fair trial.
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This page is from a legal memorandum filed on July 10, 2020, arguing for the pretrial release of Ghislaine Maxwell. The defense contends that the government has failed to prove she is a flight risk or that no conditions exist to assure her appearance, citing the Bail Reform Act and Supreme Court precedent (Salerno) establishing liberty as the norm and detention as an exception. A footnote references a separate letter regarding poor prison conditions, including lack of visitation and legal access, which the defense argues are 'compelling reasons' for release.
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This legal document is a filing, likely by the government, arguing that the district court should deny the defendant's 'Third Bail Motion'. The primary argument is that the court lacks jurisdiction because the defendant has a simultaneous bail appeal pending in the Second Circuit. A secondary argument is that even if jurisdiction existed, the motion should be denied because the court has already twice found the defendant to be a flight risk.
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This document is a page from a court transcript (Case 21-770) dated April 1, 2021. Defense attorney Mr. Cohen argues for bail, claiming the government's indictment of conduct from 1994-1997 is tactical and lacks physical evidence like tapes or video. He asserts that the client has been kept in custody 'by design' and references the 2007 Non-Prosecution Agreement (NPA).
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This document is a transcript from a court hearing on April 1, 2021, where a defense attorney argues for their client's pretrial release. The attorney contends that the government has the unwavering burden to prove the client is a flight risk and has failed to do so, citing precedent from the Supreme Court and a Second Circuit case written by Judge Raggi. The attorney also informs the court that they have proactively prepared a bail package for consideration, subject to verification by Pretrial Services.
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This page is from a legal filing (likely a memorandum in support of bail) arguing for the release of Ghislaine Maxwell. It asserts that the government has failed to prove she is a flight risk or that no conditions can assure her appearance, citing the Bail Reform Act and Supreme Court precedent favoring liberty. It also references the COVID-19 crisis and a footnote cites a letter regarding poor prison conditions hindering legal defense preparation.
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This document is page 3 of a government filing dated August 4, 2025, addressed to Judges Berman and Engelmayer regarding the Epstein and Maxwell cases. It details specific dates the grand juries met for both cases (2019 for Epstein, 2020-2021 for Maxwell) and discusses the submission of grand jury exhibits and transcripts under seal. The government argues that the 'nolle prosequi' (dismissal due to death) in the Epstein case does not prevent the court from disclosing sealed grand jury minutes.
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This document is page 47 of a court transcript from July 24, 2019, in the case United States v. Epstein (1:19-cr-00490). Defense attorney Mr. Weinberg is arguing against the government's claim that payments of $250,000 and $100,000 made by the defendant constituted witness tampering or obstruction of justice. Weinberg contends these were acts of generosity to employees or friends and argues that, under the Aguilar Supreme Court precedent, these actions do not rise to federal obstruction because there was no pending judicial proceeding at the time.
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This document is a page from a court transcript dated July 24, 2019, in which a speaker, Mr. Weinberg, discusses the legal history of his client, Mr. Epstein's, sex offender classification. Weinberg argues that Epstein has complied with all registration requirements, noting his principal residence is the Virgin Islands where he is a tier 1 offender, and that an attempt to register in New Mexico was deemed unnecessary by that state.
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This document is page 6 of a legal filing dated July 16, 2019, addressed to Judge Richard M. Berman. The author asserts that Epstein consistently notified New Mexico official Detective Deborah Anaya of his presence at his residence there. The filing also counters a point made by the judge, arguing against the idea that sex offender recidivism rates increase after 15 years by citing studies suggesting the risk of relapse substantially drops over time for offense-free individuals.
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This document is page 6 of a legal filing dated July 16, 2019, addressed to Judge Richard M. Berman. The author refutes the judge's suggestion that sex offender recidivism rates increase after 15 years, citing two studies that conclude the opposite. The document also mentions a New Mexico detective, Deborah Anaya, and speculation by a third-party counsel, Mr. Boies, regarding alleged payments in late 2018.
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This document is a legal filing arguing for the dismissal of a petition due to a lack of subject matter jurisdiction. The central argument is that the Petitioners lack Article III standing because they cannot demonstrate a sufficient "injury in fact" that is redressable by the court. The filing cites numerous legal precedents, including Supreme Court decisions, to support its position on the requirements for standing.
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This document is page 18 of a legal filing (Case 22-1426) dated September 17, 2024. It discusses a Rule 33 motion regarding Juror 50's erroneous responses during voir dire in the Ghislaine Maxwell trial. The text argues that under the 'McDonough' standard, a new trial is not warranted because the District Court found the juror's errors were not deliberate and would not have resulted in a strike for cause.
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