10th Cir.

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This is page 2 of a legal filing (Document 550) from United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 17, 2021. The Government argues regarding the admissibility of extrinsic evidence for impeaching a witness, specifically noting that the prior inconsistent statements come from FBI 302 reports written by agents, not the witness herself. The document cites various legal precedents to argue that if a witness admits to an inconsistency found in '3500 material' (Jencks Act material), no further extrinsic evidence is needed.

Legal filing / court document (motion or brief)
2025-11-20

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This document is page 7 of a legal filing from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 9, 2021. It discusses the legal admissibility of a telephone directory (Exhibit GX 606) found at the Palm Beach residence, arguing it is not hearsay because it is offered to prove a link between Maxwell and the listed contacts rather than the truth of the contact details. The text cites witness Mr. Alessi's testimony confirming Maxwell regularly used this directory.

Legal filing (court order/opinion or memorandum of law)
2025-11-20

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This legal document is a motion filed on behalf of Mr. Robertson, asking the court to reconsider its denial of his pretrial release. The motion argues for reconsideration based on new evidence, specifically unforeseen trial continuances and new potential placement options, including with the grandmother of his children and at La Pasada Halfway House. The document cites legal precedent to establish that the court has the authority to amend its prior orders.

Legal document
2025-11-20

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This document is a page from a legal filing (Case 22-1426, filed July 27, 2023) arguing for a new trial based on juror misconduct. The text specifically attacks the credibility of 'Juror 50,' alleging he gave intentionally false statements under oath regarding his own history of sexual abuse during the jury questionnaire process. It cites legal precedents (McDonough, Jones v. Cooper) to argue that actual or implied bias warrants a new trial.

Legal brief / appellate filing (page from appeal)
2025-11-20

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This document is a page from a legal brief (likely by the Government) appearing in the appellate case of United States v. Maxwell (Case 22-1426). It argues that the statute of limitations for the charges against Maxwell had not expired due to the 2003 amendment to Section 3283. The text supports Judge Nathan's lower court ruling that applying this amendment was not an impermissible retroactive effect, distinguishing Maxwell's situation from the precedent set in United States v. Richardson.

Legal brief / court filing (appellate)
2025-11-20

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This legal document discusses the government's arguments in a case, referencing previous cases like United States v. Torres and United States v. Daugerdas. It focuses on whether a new trial is warranted based on juror bias and concealed personal background information, arguing that the current case is stronger than in Torres.

Legal document
2025-11-20

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This document is page 44 of a legal filing (Document 613) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. The text presents legal arguments regarding 'inferable bias' in jury selection, citing precedents such as *United States v. Torres*, *Daugerdas*, and *Greer*. It specifically discusses a scenario where a juror might be dismissed if their past experiences (such as structuring cash transactions) are too similar to the incidents giving rise to the trial.

Legal filing (court memorandum/brief)
2025-11-20

DOJ-OGR-00009038.jpg

This legal document, part of a court filing from February 24, 2022, defines and analyzes the concept of "implied bias" as a basis for challenging potential jurors. It cites numerous legal precedents to explain that implied bias is presumed by law, regardless of a juror's stated impartiality, especially when a juror's personal experiences are similar to the issues being litigated. The document provides examples from past cases, such as jurors who were victims of crimes similar to those in the case they were hearing.

Legal document
2025-11-20

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This document is page 4 of a legal filing (Document 613) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. It is a 'Table of Authorities' listing various legal precedents (cases) cited in the main document, ranging from 1933 to 2022. Notably, it cites 'Brown v. Maxwell' (2019), a case directly involving the defendant.

Legal filing (table of authorities)
2025-11-20

DOJ-OGR-00010353.jpg

This legal document is a court opinion from Case 1:20-cr-00330-PAE, filed on April 1, 2022. The court analyzes and rejects the Defendant's (Maxwell's) argument that Juror 50 was biased due to dishonest answers on a jury questionnaire. The court distinguishes this case from precedents involving deliberate deception, crediting Juror 50's explanation that his nondisclosure was an 'inadvertent mistake' resulting from personal distractions and 'skimming' the form.

Legal document
2025-11-20

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This legal document argues against the defendant's assertion that a juror's similar life experiences should automatically presume bias, requiring their removal. It cites multiple legal precedents (from the Second, First, Seventh, and other circuits) to support the position that only "extreme situations" warrant such a presumption. The document contends that similarity of experience is just one of many factors to be considered and is often insufficient on its own to justify a juror's dismissal for cause.

Legal document
2025-11-20

DOJ-OGR-00009729.jpg

This document is a page from a legal filing that defines and discusses the concept of "implied bias" in the context of jury selection. It cites several legal precedents (Torres, Haynes, Sampson, etc.) to explain that implied bias is presumed by law and is determined by the juror's circumstances, not their stated ability to be impartial. The text highlights that bias can be implied when a juror's personal experiences are similar to the issues being litigated, providing examples from cases involving murder and burglary.

Legal document
2025-11-20

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This document is page 147 of a court filing (Document 204) from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal analysis regarding perjury charges, specifically discussing the legal standard for 'fundamental ambiguity' in questioning. The text cites various precedents to argue that a perjury count stands unless a question is so ambiguous that people of ordinary intellect cannot agree on its meaning, noting that simple amenability to multiple meanings is not a sufficient defense.

Court filing (legal brief/opinion)
2025-11-20

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This document is a page from a legal filing (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) dated October 29, 2021. The text argues for the admissibility of expert testimony regarding 'grooming' and the psychological relationship between sexual abuse victims and perpetrators, citing numerous appellate court precedents (9th, 8th, 10th, 5th, and 2nd Circuits) to support the validity/relevance of such testimony. The filing notes that the defendant is attempting to rely on a single contrary case from the District of Maine.

Legal filing (court opinion/memorandum)
2025-11-20

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This document is page 9 of a legal filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The text presents a legal argument citing precedents (Katz, Campagnuolo, Wicker) regarding discovery violations, willful misconduct, and the suppression of evidence as a sanction. The filing argues that the government failed to comply with a disclosure order issued months prior and criticizes the government's bad faith in seeking reconsideration rather than compliance.

Legal filing / court order excerpt
2025-11-20

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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.

Legal document
2025-11-20

DOJ-OGR-00005581.jpg

This legal document is a portion of a court filing arguing against the defense's interpretation of Brady material. The author contends that the cases cited by the defense (such as Kyles, Bowen, and Lindsey) concern the withholding of directly exculpatory evidence and do not support the defense's attempt to introduce irrelevant information to attack the general 'thoroughness' of the investigation. The document uses precedent from Watson v. Greene to argue that these cases offer no guidance on what evidence must be admitted at trial for cross-examination purposes.

Legal document
2025-11-20

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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.

Legal court filing (defense motion/memorandum)
2025-11-20

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This document is a Table of Authorities from a legal filing in case 1:20-cr-00330-PAE, filed on October 29, 2021. It lists legal precedents, including numerous 'United States v.' cases from various circuit courts, Federal Rules of Criminal Procedure, Federal Rules of Evidence, and amendments to the U.S. Constitution. The table indicates the page numbers within the parent document where each authority is cited.

Legal document
2025-11-20

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This handwritten legal document argues that Congress intentionally excluded specific child abuse definitions found in ยง 3509(a) when making technical corrections in 1994, suggesting these definitions apply to civil reporting rather than criminal statutes. The text cites legal precedents such as *Ibarra v. Holder*, *Jama v. Immigration & Customs Enforcement*, and *Brown v. Gardner* to support principles of statutory interpretation regarding congressional intent and context.

Legal filing / handwritten legal argument
2025-11-20

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This document discusses the application of the Crime Victims' Rights Act (CVRA) regarding victim notification, resentencing, and attendance at trials, particularly in cases with multiple victims like the Oklahoma City bombing. It outlines proposed rules for handling victim rights when large numbers make standard procedures impracticable and addresses the victim's right to be heard on issues directly affecting them. Extensive footnotes provide legal citations and commentary on relevant statutes and case law.

Legal review / law journal article page
2025-11-19
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