This page from a legal document, dated February 28, 2023, argues for a new trial based on the misconduct of 'Juror 50'. It alleges the juror harbored bias and gave untruthful answers during jury selection (voir dire). The document outlines the applicable law, citing the Supreme Court's two-part test from McDonough v. Greenwood for when a juror's false answers warrant a new trial.
This legal document argues that the defendant, Maxwell, was denied her constitutional right to a fair trial. The basis for this claim is that a juror, identified as Juror 50, made false statements on his juror questionnaire and later revealed in interviews that he used his personal history as a victim of child sexual abuse to persuade other jurors to convict. Although the court held a hearing on the matter, it found the juror's testimony credible and denied the defendant's motion for a new trial.
This legal document argues that the District Court's application of statute § 3283 is improper because it creates "impermissible retroactive effects" without explicit authorization from Congress. The author cites several legal precedents, including Landgraf and U.S. v. Richardson, to support the established legal principle against the retroactive application of statutes, particularly criminal statutes of limitations. The document contends that because clear congressional intent for retroactivity is absent, the District Court's decision must be reversed.
This document is page 65 of a legal brief (Case 22-1426) filed on February 28, 2023. The text presents a legal argument regarding statutory interpretation, specifically debating whether a 'categorical approach' or a 'case-specific approach' should apply to 8 U.S.C. § 3283. The brief argues that the District Court erred by using a case-specific approach, citing conflicts with Supreme Court precedents such as *Nijhawan v. Holder*, *James v. U.S.*, and *Kawashima*.
This page is from a legal brief (Case 20-3061, Document 82) filed on October 2, 2020. The text argues against Ghislaine Maxwell's attempt to use a writ of mandamus to modify a Protective Order, citing that such writs are 'extraordinary remedies' reserved for exceptional circumstances like judicial abuse of power. It references legal precedents (Cheney, Glotzer) to support the argument that pretrial discovery orders are generally not reviewable on direct appeal.
This document is page 13 of a legal brief filed on October 2, 2020, in case 20-3061 (Maxwell appeal). The text argues that Maxwell's appeal regarding pretrial discovery materials does not meet the strict requirements of the collateral order doctrine established by the Supreme Court. The Government distinguishes Maxwell's situation from cases she cited (Pichler v. UNITE, Minpeco S.A. v. Conticommodity Servs.), noting those involved intervenors in civil cases rather than parties in criminal cases.
This legal document, a page from a court filing, argues that the collateral order exception, which allows for appeals of certain pretrial orders, must be interpreted with 'utmost strictness' in criminal cases. It cites Supreme Court precedent establishing that only four specific types of pretrial orders are appealable under this doctrine. The document emphasizes that the Court has consistently refused to expand this narrow exception, and that any justification for an immediate appeal must be exceptionally strong.
This document is page 6 of a legal filing dated September 28, 2020, concerning Case 20-3061. It presents a legal argument distinguishing the current appeal from *Flanagan v. United States*, asserting that Ghislaine Maxwell's appeal regarding Judge Nathan's order is comparable to a bail reduction motion because the harm (unsealing deposition materials) would be irreversible ("the cat is irretrievably out of the bag") if not addressed immediately. The text argues that Maxwell must be allowed to share information from Judge Nathan with Judge Preska to prevent the unsealing order from going into effect without reconsideration.
This document is a letter dated July 21, 2020, from attorney Jeffrey Pagliuca to Judge Alison J. Nathan of the Southern District of New York. On behalf of his client, Ghislaine Maxwell, Pagliuca requests a court order to prohibit the government and its agents from making extrajudicial statements about her case. The letter argues that such statements are prejudicial and violate Maxwell's Sixth Amendment right to a fair trial by an impartial jury, citing legal precedents to support the court's authority to issue such an order.
This document is page 24 (labeled 19 in the brief) of a legal filing dated September 24, 2020, related to Ghislaine Maxwell's appeal. It argues that Maxwell must be allowed to share specific information with Judge Preska to properly decide on unsealing deposition materials and a motion to stay, invoking *Martindell* protections and the Fifth Amendment. The text criticizes the government for attempting to keep relevant information secret from a 'co-equal' judge.
This legal document, part of Case 20-3061, argues that a specific court order is not immediately appealable. It cites Title 28 of the United States Code and case law (Pappas, Caparros, Van Cauwenberghe) to establish that discovery orders, even if framed with restrictive language, do not qualify as appealable injunctions. The document concludes that the order in question is not a final judgment and does not fit into the narrow exception for appealable collateral orders in criminal cases.
This document is page 11 of a legal filing (Case 20-3061) dated September 16, 2020. It presents legal arguments regarding the 'collateral-order doctrine' and protective orders in criminal cases, arguing that such orders are generally not subject to interlocutory appeal. The text cites various precedents (Firestone, Caparros, Pappas) to support the argument that restricting the dissemination of discovery materials does not violate First Amendment rights and that challenges to such orders should await final judgment.
This document is page 9 of a legal brief filed on September 16, 2020, in Case 20-3061 (United States v. Maxwell). The text outlines legal arguments regarding the 'collateral-order doctrine' and 'interlocutory appeals' in criminal cases. It cites numerous precedents (Cohen, Stack, Abney, Sell) to demonstrate that the Supreme Court rarely permits appeals before a trial concludes, arguing that an order is only immediately reviewable if rights would be 'effectively unreviewable' later.
This document is a page from a legal filing that discusses the principle of finality in criminal cases, which generally prohibits appeals until a final judgment is rendered. It outlines the very limited 'collateral order doctrine,' a narrow exception that permits immediate appeal of certain orders if they meet a strict three-part test. The text cites numerous Supreme Court cases to emphasize that this exception is rare and must be interpreted with the 'utmost strictness' in criminal proceedings to avoid undue delay and piecemeal litigation.
This document is a legal filing arguing that an appeal should be dismissed for lack of jurisdiction. It cites the 'Collateral Order Doctrine' and legal precedent, such as the final judgment rule from Title 28, Section 1291 of the U.S. Code, to support the argument that appellate review is generally not permitted until a final judgment is rendered. The context is a motion filed by Maxwell on September 10, 2020, to consolidate appeals, one of which relates to the civil case 'Giuffre v. Maxwell'.
This page from a legal brief (Case 20-3061, dated Sept 16, 2020) argues that Ghislaine Maxwell's appeal should be dismissed for lack of jurisdiction. The text contends that Judge Nathan's refusal to modify a Protective Order is not an 'immediately appealable collateral order' and does not fall under categories allowing prejudgment appeals in criminal cases.
This legal document, page 12 of a filing from September 16, 2020, argues that protective orders regulating the use of documents in a criminal case are not subject to interlocutory appeal. It cites numerous court precedents, including from the Supreme Court, to establish that such orders are not immediately appealable under the collateral-order doctrine and do not constitute an impermissible prior restraint under the First Amendment. The document asserts that any challenge to a litigant's right to release documents can wait until a final judgment is rendered.
This document is page 10 of a legal filing (Case 20-3061, dated September 16, 2020) related to United States v. Ghislaine Maxwell in the Second Circuit. The text consists of legal arguments regarding the 'collateral-order doctrine' and cites multiple Supreme Court precedents (such as Stack v. Boyle and Sell v. United States) to define when pretrial orders in criminal cases can be appealed immediately. The document argues that exceptions allowing for interlocutory appeals are rare.
This page from a legal document discusses the principle of finality in criminal cases, which generally prohibits appeals until a final judgment is rendered. It outlines the narrow 'collateral order' exception that permits immediate appeals under specific, strict conditions. The text cites multiple Supreme Court cases to emphasize that this exception is rare and must be interpreted with the 'utmost strictness' to avoid the damaging effects of piecemeal litigation on the administration of justice.
This document is a legal filing arguing that an appeal should be dismissed for lack of jurisdiction. It cites the 'final judgment rule' from Title 28 of the U.S. Code, which generally prohibits appeals until a final decision is made on the merits of a case. The filing emphasizes that this policy against 'piecemeal' appeals is particularly strong in criminal law, referencing several Supreme Court precedents.
This document is a page from a Government sentencing filing (Case 1:20-cr-00330-PAE) arguing for a 'Four-Point Leadership Enhancement' under sentencing guidelines. It asserts that the defendant (Ghislaine Maxwell) was a leader of an 'otherwise extensive' criminal conspiracy involving Jeffrey Epstein, spanning the UK, Virgin Islands, and three states. The text cites testimony from victims (Carolyn, Virginia) and staff (Juan Alessi, pilots) to demonstrate the scale of the operation and the defendant's role in recruiting victims and managing Epstein's properties.
This legal document argues that the government's reliance on the Tanner and Ianniello legal precedents is incorrect in the case of Ms. Maxwell. The author contends that unlike those cases, the alleged misconduct by Juror No. 50 occurred outside the jury room, specifically through false answers during voir dire and subsequent self-publicity. The document asserts that Ms. Maxwell is entitled to an evidentiary hearing and that the juror's own actions in seeking the limelight are the reason the misconduct came to light.
This legal document is a filing on behalf of Ms. Maxwell arguing against the government's proposal for a limited evidentiary hearing concerning Juror No. 50. The defense contends that the juror's alleged false answers necessitate a reversal, citing Supreme Court precedent, and that Ms. Maxwell has a constitutional right to a full adversarial hearing, not the narrow one proposed by the government. The filing draws parallels to the United States v. Daugerdas case to support its claim for a new trial.
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.
This document is page 13 of a court filing (Document 615) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. The text outlines legal standards for Rule 33 motions regarding alleged juror misconduct and misrepresentations during voir dire. It cites various precedents (Tanner, McDonough, Shaoul) to establish that courts disfavor post-verdict inquiries and require a strict two-part test to prove that a juror answered dishonestly and that a truthful answer would have resulted in a dismissal for cause.
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