Supreme Court
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This document is Page 2 of a court order filed on June 9, 2020, in the case against prison guards Thomas and Noel. The court denies Thomas' motion for additional discovery, noting that the Government has already produced significant evidence, including surveillance video dating back to July 5, 2019, count slips, round forms, and staffing rosters covering the period of Epstein's suicide. The text outlines the legal standards (Rule 16, Brady, Giglio) under which Thomas argued for further access to information.
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This page is from a legal filing (Case 1:19-cr-00830-AT) dated April 24, 2020, arguing against a motion by defendant Thomas (likely Michael Thomas, a guard involved in the Epstein case) to disclose draft versions of an Inspector General's Report regarding the Bureau of Prisons (BOP). The text argues that such drafts do not yet exist and, even if they did, would be protected by the 'deliberative process privilege.' The document cites numerous legal precedents to support the claim that pre-decisional government documents are shielded from discovery.
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This legal document is a section of a government filing arguing against a defendant's (Thomas) request for certain records. The government contends that the records—related to BOP staffing, policies, and other employees—are not 'material' to preparing a legal defense under Rule 16. Instead, the government asserts Thomas seeks these records for the impermissible purpose of encouraging jury nullification by arguing that poor conditions at the BOP 'led' to his alleged criminal conduct.
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This legal document, page 18 of a court filing dated December 2, 2024, discusses the District Court's denial of a Rule 33 motion for a new trial. The motion was based on an allegedly erroneous answer given by 'Juror 50' during voir dire. The document explains that the court applied the standard from 'McDonough v. Greenwood', finding the juror's testimony credible and his response not deliberately incorrect, and also noting that the defendant, Maxwell, had not challenged other jurors with similar backgrounds.
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This legal document, part of an appellate court opinion, addresses arguments made by a defendant named Maxwell. The court rejects a 'categorical approach' for determining if offenses involved sexual abuse, citing testimony from a victim, 'Jane', about being abused as a minor across state lines. The document then introduces Maxwell's second argument: that certain counts are barred by the statute of limitations because a 2003 amendment to § 3283 should not apply retroactively, referencing the Supreme Court case Landgraf v. USI Film Products.
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This page from a legal filing (Case 22-1426) discusses a Rule 33 motion for a new trial based on 'Juror 50's' alleged erroneous responses during jury selection (voir dire). The text argues that the District Court correctly applied the 'McDonough' standard, finding the juror's errors were not deliberate and that accurate answers would not have led to a dismissal for cause. It also notes that Ghislaine Maxwell did not challenge other jurors who had disclosed histories of sexual abuse.
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This legal document, dated November 1, 2024, presents an argument for an en banc review to potentially overrule or limit the 'Annabi' canon of construction for plea agreements. The text discusses the jurisdictional authority of U.S. Attorneys' offices, citing the U.S. Attorneys' Manual and the Judiciary Act of 1789 to argue about the scope of immunity and the government's obligation to be explicit about its limitations. The argument is framed in the context of a past case involving interviews with Epstein's lawyers.
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This document is a legal filing (Case 22-1426) arguing for an en banc review of a panel decision. The core argument is that the precedent set by United States v. Annabi, which limits a plea agreement's scope to a single U.S. Attorney's office by default, conflicts with the broader, long-standing legal principle that plea agreements should be construed strictly against the government. The filing cites several other cases to demonstrate this tension with established circuit and Supreme Court jurisprudence.
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This legal document, a page from a court filing, discusses the standard for granting a new trial based on a juror's incorrect answers during voir dire, referencing the precedent set in McDonough Power Equipment, Inc. v. Greenwood. The District Court found that Juror 50's erroneous responses were not deliberate and would not have resulted in being struck for cause. The document also notes that the party, Maxwell, did not challenge other jurors who had disclosed experiences with sexual abuse, assault, or harassment.
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This legal document, part of Case 22-1426, discusses two key arguments. First, it affirms that charges involving the sexual abuse of a minor ("Jane") transported across state lines fall under § 3283. Second, it addresses an argument by Maxwell that certain counts are time-barred because a 2003 amendment to the statute of limitations in § 3283 should not apply retroactively, referencing the Supreme Court's test in 'Landgraf v. USI Film Products'.
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This page is from a legal brief (likely by the Government/DOJ given the footer) in the appeal of Ghislaine Maxwell (Case 22-1426). It argues against Maxwell's claim for a new trial based on 'Juror 50's' failure to disclose prior sexual abuse. The text cites legal precedents (McDonough, Shaoul, Langford) to establish that a new trial requires 'deliberate dishonesty' by a juror, not just an honest mistake, and asserts that Juror 50 was genuinely surprised by the questionnaire content.
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This document is page 61 of a legal brief filed on June 29, 2023 (Case 22-1426), likely by the government in response to an appeal by Ghislaine Maxwell. The text argues that case law cited by Maxwell regarding the 'essential ingredient' test and statutes of limitations (specifically Bridges, Scharton, and Noveck) is distinguishable and inapplicable to her case involving sexual abuse of a child (18 U.S.C. § 3283). It asserts that Congress intended a broader application for child sexual abuse statutes compared to the fraud statutes discussed in the cited cases.
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This legal document page discusses the second step of the Landgraf analysis, a legal test to determine if a statute can be applied retroactively. It cites Supreme Court precedent from the Landgraf case to explain that a statute is impermissibly retroactive if it impairs rights, increases liability, or imposes new duties for past conduct, but clarifies that changes to procedural rules are generally not considered retroactive. The document also references the case of Vernon v. Cassadaga Valley Cent. School Dist. as an example of the court considering a new statute of limitations.
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This page from a legal document outlines the legal standard for retroactivity as established in the Supreme Court case Landgraf v. USI Film Products. It then introduces an argument from a claimant named Maxwell, who alleges that the District Court incorrectly applied a 2003 amendment to Section 3283 retroactively to her convictions on Counts Three, Four, and Six, which involved conduct predating the amendment.
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This page of a legal document argues against a critique by Maxwell of the 'Annabi' rule. The author contends the rule is sound, prevents defendants from receiving unintended immunity, and is supported by the Justice Manual's policy on multi-district agreements. The document concludes that the court is bound by this rule as it is an established precedent that has not been overturned.
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This document is a page from a court transcript dated June 29, 2023, in which a judge is outlining the legal basis for an upcoming sentence. The judge states the applicable guideline range is 188 to 235 months but notes that, due to the Supreme Court's 'Booker' decision, this is only one of many factors to consider. The judge then lists the various sentencing factors required by law (18 U.S.C. 3553(a)), such as the nature of the offense, deterrence, and avoiding sentencing disparities.
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This document is a page from a court transcript dated June 29, 2023, where a government prosecutor is arguing for an above-guideline sentence for a female defendant. The prosecutor contends that the defendant's dishonesty, the severe and predatory nature of her sex-trafficking crimes, and the acknowledged inadequacy of the 2003 sentencing guidelines all justify a sentence longer than the calculated 188-235 months.
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This document is page 14 of a court filing (Case 1:20-cr-00330-AJN) filed on 02/25/22, addressing Ghislaine Maxwell's motion for a new trial based on alleged juror misconduct. The court rejects Maxwell's argument that Federal Rule of Evidence 606 violates her confrontation and due process rights, clarifying that Juror 50 is a factfinder, not a witness against her. The text cites various legal precedents to support the limitation on using juror affidavits to impeach a verdict.
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This document is a page from a legal brief filed by the prosecution on February 25, 2022, in the case against Ghislaine Maxwell. It argues against the Defendant's motion for a new trial based on alleged juror misconduct (specifically regarding 'Juror 50' and a 'second juror' lying during voir dire). The text cites Federal Rule of Evidence 606 and the Supreme Court case Warger v. Shauers to argue that juror testimony regarding internal deliberations or personal experiences is inadmissible and does not constitute 'extraneous prejudicial information.'
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This legal document is a page from a court filing, likely a judicial opinion or a party's brief, dated February 25, 2022. The text analyzes Federal Rule of Evidence 606, which prohibits jurors from testifying about their deliberations to challenge a verdict. The document discusses the rule's specific exceptions, such as external influence or racial bias, in the context of the Defendant's attempt to use statements from 'Juror 50' about what another juror said. The central issue is whether these statements are barred by Rule 606 or fall under one of its exceptions.
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This document is page 4 of a court order (filed Feb 25, 2022) addressing Ghislaine Maxwell's motion for a new trial based on alleged juror misconduct. The text outlines the legal standards under Federal Rule of Criminal Procedure 33 and the 'McDonough' test regarding juror nondisclosure during voir dire. Specifically, the court is analyzing whether 'Juror 50' failed to answer honestly about past sexual abuse, though the court notes in a footnote that it is not yet resolving whether a new trial is merited at this specific juncture.
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This legal document analyzes the ambiguity of the Crime Victims' Rights Act (CVRA) concerning when victims' rights attach, particularly before formal charges are filed. It notes that at the time of the 2007 Non-Prosecution Agreement (NPA) in the Epstein case, court precedent was sparse and divided, a situation that continued as of the writing of this report. Because the law was not clear, the Office of Professional Responsibility (OPR) concluded that the prosecutors' failure to consult with victims before signing the NPA did not constitute professional misconduct.
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This document is page 170 of a DOJ Office of Professional Responsibility (OPR) report evaluating Alexander Acosta's conduct regarding the Jeffrey Epstein case. It concludes that Acosta exercised 'poor judgment' by prematurely resolving the federal investigation through a state plea and Non-Prosecution Agreement (NPA) based on a flawed application of the 'Petite policy.' The report notes that Acosta failed to strengthen the federal case (e.g., by obtaining Epstein's missing computers) and that the crimes involved substantial federal interests including the sexual exploitation of children and interstate travel.
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This document is a page from a legal brief (likely related to the Ghislaine Maxwell trial, given the case number 1:20-cr-00330) discussing legal precedents involving prosecutorial discretion and immunity. It cites Supreme Court cases such as Wayte v. United States and Imbler v. Pachtman to argue that prosecutors have broad discretion in charging decisions and absolute immunity regarding those decisions, including the decision *not* to charge. The document concludes by introducing a section on plea agreement promises of leniency towards third parties, which is relevant to the non-prosecution agreement in the Epstein case.
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This legal document outlines the Department of Justice's policy regarding the deportation of criminal aliens, referencing a 1995 memorandum from the Attorney General that directs federal prosecutors to seek deportation unless extraordinary circumstances exist. It also discusses the legal concept of prosecutorial discretion, citing the 1978 Supreme Court case Bordenkircher v. Hayes, and provides legal definitions for terms like 'criminal alien' and offenses leading to deportation.
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