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This legal document, filed on June 25, 2021, argues that a person named Maxwell has no reasonable expectation of privacy regarding documents produced during a prior civil litigation. It asserts that because a protective order allowed these documents to be widely shared among various parties (attorneys, witnesses, court staff), they were not truly private. The document cites Supreme Court and Second Circuit precedents, such as Carpenter and Andover, to support the position that such information can be used by the Government in a subsequent criminal prosecution.
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This document is page 8 of a legal filing (Document 307) from the criminal case against Ghislaine Maxwell, filed on June 25, 2021. The text argues against Maxwell's attempt to suppress deposition transcripts from a civil case, citing legal precedents (Oshatz, Wong, Knox) to establish that even if a protective order was modified, the testimony can be used, particularly in a perjury trial where the statements themselves are the crime. The government asserts that civil deposition testimony does not violate rights against self-incrimination in this context.
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This page from a legal filing (Document 307 in Case 1:20-cr-00330-PAE) argues that Ghislaine Maxwell's Fifth Amendment rights were not violated when the Government used her civil deposition testimony in her criminal trial. The text asserts that civil protective orders do not prevent testimony from being used in subsequent criminal proceedings and that Maxwell was free to plead the Fifth during the original civil case but chose not to. It also addresses an argument regarding the law firm BSF turning over transcripts.
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This legal document summarizes expert opinions regarding Ghislaine Maxwell's potential extradition. Mr. Perry, an expert on UK law, concludes that Maxwell is unlikely to successfully resist extradition to the United States or be granted bail. William Julié, an expert on French law, clarifies that, contrary to government representations, the extradition of a French national to the USA is legally permissible.
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This legal document, page 16 of a filing from October 29, 2021, argues that the proposed expert testimony and 'grooming opinions' of an individual named Roccio should be deemed inadmissible. The author contends that Roccio's testimony is substantially more prejudicial than probative under Rule 403, fails to meet the Daubert standard for scientific reliability, and oversimplifies complex issues, thereby risking misleading the jury. The argument is supported by citations from several court cases, including United States v. Burns and Gonyer, which criticize similar 'grooming theories'.
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This document is page 12 of a legal filing (Case 1:20-cr-00330-PAE) filed on October 29, 2021. It is a legal argument seeking to exclude the testimony of an expert witness named Rocchio, arguing that her opinions on 'grooming' and sexual abuse are based on unverified personal beliefs rather than scientific methodology or representative studies. The text cites various legal precedents (including Supreme Court rulings) to support the claim that Rocchio's testimony is unreliable and 'virtually impregnable for purposes of cross-examination.'
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This legal document, part of a court filing, argues that precluding certain statements is the only appropriate remedy for a discovery violation. It cites Federal Rule of Criminal Procedure 16(d)(2)(C) and legal precedents, including the Supreme Court's decision in *Taylor v. Illinois*, to establish that a court has the discretion to impose such a sanction. The argument rests on balancing a defendant's rights against public interests like the integrity of the trial process and the fair administration of justice.
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This legal document is a filing by Ms. Maxwell's counsel arguing against the government's motion to limit the introduction of her statements at trial. The defense contends the motion is premature and improper because the government has not identified any specific hearsay statements it seeks to exclude. The filing asserts that the correct procedure is for the government to object to any potential hearsay testimony as it arises during the trial, allowing the Court to rule on admissibility in context.
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This legal document, filed on October 29, 2021, for case 1:20-cr-00330-PAE, argues for the admissibility of evidence regarding minor victims' consent. It distinguishes the actual charges of "sexual activity" and "sex trafficking" from "sexual abuse," which is not charged. The document provides context by comparing the varying legal definitions of "minor" and ages of consent across different jurisdictions, including New York, Florida, the United Kingdom, France, and New Mexico.
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This page is from a legal filing (Document 382) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on October 29, 2021. It presents a legal argument citing case law (Kyles v. Whitley, Bowen v. Maynard) to support the admissibility of evidence regarding the Non-Prosecution Agreement (NPA), prior charging decisions, and the death of Jeffrey Epstein. The defense argues these elements are necessary to challenge the thoroughness and good faith of the government's investigation.
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This document is a page from a Government legal filing (dated Oct 29, 2021) in the case against Ghislaine Maxwell. The Government rebuts defense accusations regarding discovery violations, stating they provided co-conspirator statements 'unusually early' (seven weeks before trial). Additionally, the Government argues against suppressing the identification of the defendant by 'Minor Victim-4,' asserting that the victim knew the defendant personally for decades.
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This document is a page from a Government filing in the Ghislaine Maxwell trial (Case 1:20-cr-00330), filed on October 29, 2021. It argues for the admissibility of the terms 'minor' and 'sexual abuse' regarding Minor Victim-3, noting she was 17 when sexual contact with Epstein began. The prosecution asserts that the defendant knew of Epstein's preference for underage girls and rejects the defense's request for jury instructions regarding United Kingdom law.
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This document is page 8 of a legal filing (Document 391) from the Ghislaine Maxwell trial, dated October 29, 2021. The defense argues that admitting seized evidence based on the affidavit of Detective Recarey violates Maxwell's Sixth Amendment rights because Recarey (the original custodian) is dead and unavailable for cross-examination. The text emphasizes that no other witness has sufficient personal knowledge of the seized items, their storage, or the 'confusing' handwritten notes in the inventory.
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This document is page 8 of a court order filed on March 26, 2021, in the case of United States v. Schulte (Case 1:17-cr-00548). The text addresses a legal dispute regarding 'Underrepresentation' in jury selection, specifically defining the 'Relevant Jury Venire.' The defendant (Schulte) argued for the use of the White Plains 'qualified wheel,' while the Government argued for the 'master wheel.' The Court ruled in favor of the Government, concluding that the White Plains master wheel is the relevant jury venire for the fair cross-section analysis.
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This document is page 16 of a legal filing (Document 148) in the case United States v. Ghislaine Maxwell, filed on February 4, 2021. It contains legal arguments by the defense requesting the immediate disclosure of 'Brady' and 'Giglio' material (exculpatory and impeachment evidence) from the government. The defense argues that Ms. Maxwell needs this information early to prepare an effective defense, citing various legal precedents (United States v. Rodriguez, Bagley, etc.) to support the claim that impeachment evidence falls under the Brady rule.
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This document is page 2 of a legal filing (Document 362) from the United States v. Ghislaine Maxwell case (1:20-cr-00330), filed on October 20, 2021. The text argues for public access to the jury selection process (voir dire) and juror questionnaires, citing numerous legal precedents including United States v. Shkreli and Press-Enterprise Co. v. Superior Court. It asserts that First Amendment rights require these proceedings and documents to be presumptively open to the press and public.
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This document is page 5 of a legal filing (Document 342) from the case United States v. Ghislaine Maxwell, filed on October 13, 2021. The defense argues for 'individual voir dire' during jury selection, citing the 'tsunami' of negative pretrial publicity surrounding Maxwell and Jeffrey Epstein since Epstein's arrest in July 2019 and death in August 2019. The text references Supreme Court precedent regarding the necessity of questioning jurors individually to avoid bias in high-profile cases.
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This document is a legal argument from a court filing, dated October 12, 2021. The author contends that certain federal statutes, like 18 USC § 3299 and § 3509, intentionally exclude child pornography and exploitation from the definition of sexual abuse, a fact the Justice Department has allegedly always known. The argument is supported by citing 1990 legislative history (VCAA) to claim that Congress intended these laws to apply specifically to federal enclaves.
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This document is a handwritten legal argument filed in court on October 12, 2021, challenging a court's interpretation of statute §3283. The author argues that the statute's legislative history, originating from the 1986 Sexual Abuse Act, demonstrates its narrow purpose is for sexual assault and related offenses, not a broader application. The argument cites several legal cases (Davis, Pledges, Bridges) to contend that the court's findings are 'patently wrong'.
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This document is page 2 of a legal filing (Document 195) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 5, 2021. The text presents legal arguments regarding the limitations of Rule 17 subpoenas in criminal cases, arguing they cannot be used for broad discovery or to find leads, unlike in civil procedure. The text heavily cites legal precedents including *Bowman Dairy Co. v. United States*, *United States v. Purin*, and *United States v. Tagliaferro* to establish the standard for requiring document production.
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This legal document is a filing by the Government arguing against the defense's claims of prejudice due to the volume of discovery material. The Government asserts that the defense's complaints are exaggerated, that it has clearly identified the evidence it will use at trial, and that suppression of evidence is not the proper remedy. A footnote clarifies that many co-conspirator statements, such as instructions from Epstein, are admissible on grounds other than the co-conspirator exception to hearsay.
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This document is a court transcript from July 22, 2022, in which a judge explains the legal considerations for an upcoming sentencing. The judge states the guideline range is 188 to 235 months but clarifies that, due to the Supreme Court's 'Booker' decision, this is only one of many factors to be considered under federal statute 18 U.S.C. 3553(a). The judge outlines these factors, including the nature of the offense, deterrence, and public safety, before concluding that the sentence must be sufficient but not greater than necessary.
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This document is a page from a court transcript dated July 22, 2022, where an attorney argues a legal point to a judge. The attorney contends that determining the end date of an offense, which is critical for an Ex Post Facto Clause violation claim, is a factual question for the jury, not a Sixth Amendment issue for the judge as per the Apprendi line of cases. The attorney cites the 'Tykarsky' opinion as support and notes that the government has not responded to this specific argument.
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This document describes the global trend of authoritarian regimes sharing "worst practices" to restrict NGOs, a tactic pioneered by Russia and adopted by others to limit civil society autonomy and foreign funding. It specifically details China's 2016 law regulating foreign NGOs, which introduced strict bureaucratic hurdles and police oversight amidst a broader crackdown on Western influence and human rights activists.
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A newspaper clipping containing two main articles. The first details the Trump administration's lawsuit against California regarding sanctuary laws, highlighting the conflict between Attorney General Jeff Sessions and California officials like Jerry Brown and Xavier Becerra. The second article reports on the suspension of prominent physicist Lawrence M. Krauss by Arizona State University following sexual misconduct allegations published by BuzzFeed. Krauss, who directed the Origins Project (an initiative known to have been funded by Jeffrey Epstein, though Epstein is not explicitly named in this specific text), issued a rebuttal denying the claims.
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