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This document is page 20 of a legal filing (Document 18) dated July 10, 2020, in the case United States v. Ghislaine Maxwell. The text argues against the government's assertion that Maxwell is a flight risk, citing her isolation as a protective measure rather than an attempt to flee, and noting that wealth and foreign citizenship alone are insufficient grounds for detention without proof of 'inclination' to flee. It also argues that COVID-19 travel restrictions make flight unlikely and mentions in a footnote that individuals in the media (specifically in the UK) are falsely claiming to have ties to her.
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This document is the conclusion of a legal filing from the U.S. Attorney's office, dated July 2, 2020, in case 1:20-cr-00330-AJN. The government argues that the defendant is an extreme flight risk and that no conditions of bail would ensure their presence in court. Citing several legal precedents, the filing respectfully requests that the defendant's application for bail be denied.
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This legal document is a page from a court filing that discusses the enforceability of an anticipatory waiver of extradition, likely in the context of Ghislaine Maxwell's case. The author argues that the defendant has not provided cases where such waivers are enforceable and cites several past court decisions (e.g., Epstein, Morrison, Stroh) where courts have deemed such waivers unenforceable, invalid until a formal request is made, or an 'empty gesture'. The document contrasts these with cases cited by the defense (e.g., Cirillo, Salvagno) where waivers were considered but were not the central factor in the court's reasoning.
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This document is a 'Table of Authorities' from a legal filing dated June 25, 2018, associated with case number 201cr7-00330-AJN. It lists numerous U.S. federal court cases cited as legal precedent, with decisions spanning from 1985 to 2019. The vast majority of the cases listed are criminal proceedings with the United States as the plaintiff against various individual defendants.
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This document is a "Table of Authorities" from a legal filing, specifically page iii of a larger document. It lists thirteen federal court cases, providing their full citations, the dates of the decisions, and the page numbers within the filing where each case is referenced. All listed cases feature the United States as a party.
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This legal document, filed on July 18, 2019, discusses the legal principles and precedents surrounding the presumption of remand for serious offenses, emphasizing that this presumption is not easily erased and requires deference to Congress's judgment. It highlights that the U.S. Pretrial Services Department, following an interview with Mr. Epstein, issued a report on July 8, 2019, recommending to the Court that Mr. Epstein continue to be remanded, concluding that no conditions could ensure his compliance or public safety.
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This legal document argues for the release of grand jury transcripts with narrowly tailored redactions to protect the identities of victims like Ms. Farmer, citing their strong privacy interests as established in previous cases. However, it argues against redacting the names of third parties who have not been charged or alleged to be involved in the crimes of Epstein and Maxwell, suggesting such an effort "smacks of a cover up" and requires independent court scrutiny.
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This legal document, part of a court filing from July 18, 2019, argues for the pre-trial detention of the defendant, Mr. Epstein. The prosecution asserts that the severity of the charges, which carry a maximum sentence of 45 years, creates a presumption for remand. The document outlines the strength of the evidence, including victim and witness testimony, physical evidence, and reports of witness tampering, and notes Mr. Epstein's prior felony convictions in Florida involving minors.
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This legal document, page 9 of a court filing, argues against a defendant's proposal to hire private security guards as an alternative to pretrial detention. It cites numerous legal precedents from the Second Circuit and other district courts to assert that such arrangements create a conflict of interest, magnify flight risks, and foster unequal treatment based on wealth, which is contrary to the principles of the Bail Reform Act. The document highlights past cases where wealthy defendants on private security details violated the terms of their release.
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This legal document, filed on July 12, 2019, is a memorandum arguing against a defendant's proposal for bail involving home confinement, electronic monitoring, and a private security force. The prosecution contends that these measures are insufficient to ensure the defendant's appearance in court, citing numerous legal precedents that question the security, fairness, and practicality of such "private jail" arrangements. The document asserts that a private security firm cannot replicate the controlled environment of a federal facility and that allowing wealthy defendants to fund their own detention is legally problematic.
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This legal document discusses the timing of grand jury proceedings as a factor in deciding whether to release information to the public. It contrasts the recent case involving Maxwell and Epstein, where victims are still alive and the events are relatively recent, with historical precedents where the passage of time has diminished the need for secrecy. The argument suggests that the circumstances of the Maxwell case, particularly its recency, weigh against the release of grand jury materials.
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This document is page 20 of a legal filing (Doc 809) in the case USA v. Ghislaine Maxwell. The defense argues against unsealing grand jury materials, claiming the Government has not met the 'special circumstances' burden. The text extensively cites the precedent 'In re Biaggi,' arguing that unsealing is only justified to correct misleading public characterizations, and suggests the Government's current motion is a 'diversion' rather than true transparency.
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This document is a Table of Authorities from a legal filing in case 1:20-cr-00330-AJN, filed on February 4, 2021. It lists numerous legal cases, a federal statute (18 U.S.C. § 1623), and various Federal Rules of Civil and Criminal Procedure that are cited as legal precedent within the associated court document. The cases listed involve parties such as Giuffre, Dershowitz, Maxwell, and the United States government.
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This legal document, part of a court filing, discusses the legal arguments concerning the enforceability of an anticipatory waiver of extradition in the case of Ghislaine Maxwell. The text cites various legal precedents, noting that while some defendants have offered such waivers, courts have often not ruled on their enforceability or have deemed them unenforceable, as in the Epstein case where it was called an "empty gesture." The document highlights the significant legal uncertainty surrounding whether a foreign country would enforce such a waiver, making it a contentious point in the defendant's case against extradition to the United States.
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This legal document, part of a court filing, discusses the enforceability of an anticipatory waiver of extradition in the case of Ghislaine Maxwell. It contrasts different legal precedents, citing cases where such waivers were considered unenforceable or an 'empty gesture' (e.g., United States v. Epstein) against others where they were conditions of release, though their enforceability was not explicitly determined. The document highlights the legal ambiguity surrounding whether a foreign country, like France, would honor such a waiver.
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This legal document argues that pre-release waivers of extradition are unenforceable and meaningless because any defendant who flees will inevitably contest the waiver's validity. The author cites numerous court cases, including United States v. Epstein, to support the claim that such waivers are merely an "empty gesture." The document also refutes the defense's counterarguments by distinguishing the specific factual circumstances of the cases they rely upon.
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This legal document is a portion of a government filing arguing against a defendant's (Thomas) motion for discovery. The government contends that searching for certain records from the BOP, CIA, and Vice President's office would be an undue burden and that a draft Inspector General report is not subject to disclosure because it is not material to the defense and is protected by deliberative process privilege. The government states the report is not yet complete and the prosecution team has no involvement in its creation.
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This document is the concluding page of a legal motion (Document 33, Case 1:19-cr-00830-AT) filed on April 9, 2020. Attorney Montell Figgins, representing defendant Michael Thomas, requests that the court grant their Motion to Compel, arguing that requested reports are subject to Brady disclosure and should be produced within 45 days of the court's order.
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This legal document, a court filing from April 9, 2020, argues that the government must produce all relevant and exculpatory evidence to the defendant, Mr. Thomas, for trial preparation. Citing the Brady doctrine and cases like United States v. Bagley, it asserts that the government has an affirmative duty to disclose evidence favorable to the defendant, including information that can impeach prosecution witnesses, and that the court should compel this discovery.
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This document is a 'Table of Authorities' from a legal filing in case 1:19-cr-00830-AT, filed on April 9, 2020. It lists numerous court cases used as legal precedent, with the majority being criminal cases where the 'United States' is a party against various individuals. The cases cited span from 1963 to 2007 and originate from various federal courts across the country.
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This document is the conclusion of a legal filing from the U.S. Government, dated July 2, 2020, submitted by Acting U.S. Attorney Audrey Strauss. The prosecution argues that the defendant is an extreme flight risk and, citing several legal precedents, requests that the court deny any application for bail. The document was signed by Assistant U.S. Attorney Alison Moe.
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This legal document, filed on April 16, 2021, is a government response in a criminal case. The prosecution argues that evidence concerning 'Minor Victim-3' is admissible to prove a conspiracy, even though a direct charge based on her testimony is time-barred because she turned 25 before 2003. The government asserts that the charges remain timely due to the involvement of 'Minor Victim-1' and 'Minor Victim-2' and distinguishes the current case from a cited precedent (*Hsia*) by stating the alleged conduct, grooming a minor for Jeffrey Epstein, is central to the conspiracy.
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This legal document, part of a court filing, argues on behalf of Ms. Maxwell by citing several past U.S. court cases where defendants waived extradition rights to demonstrate they were not a flight risk. It then introduces expert reports, specifically one from U.K. barrister David Perry, which conclude it is highly unlikely Ms. Maxwell could successfully resist extradition from the U.K. or France back to the United States, further supporting the argument that she is not a flight risk.
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This document is page 3 of a Government filing (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) dated October 15, 2021. The Government argues that the defense's proposed deadline of November 15, 2021, for filing Rule 412 motions (regarding the admissibility of victims' sexual behavior) is impractical as it conflicts with jury selection and the Thanksgiving holiday. The Government requests an earlier deadline to allow sufficient time for investigation and *in camera* hearings.
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This is Page 3 of a legal filing (Document 351) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 15, 2021. The Government argues that the Defense's proposed deadline of November 15, 2021, for filing Rule 412 motions (concerning the admissibility of evidence regarding a victim's sexual behavior) is too close to trial, specifically conflicting with jury selection and the Thanksgiving holiday. The Government requests an earlier deadline to ensure victims have sufficient notice and the Court has time to resolve sensitive issues.
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