DOJ-OGR
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Rick Ricarey
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This document is an excerpt from a legal policy manual (likely the Justice Manual), filed as Exhibit SA-277 in the Ghislaine Maxwell case (1:20-cr-00330-AJN). It outlines the Department of Justice's protocols for 'Services to Crime Victims,' specifically detailing the responsibilities of officials to notify victims regarding their rights, the right to counsel, the right to attend trials, and schedule updates for court proceedings via the Victim Notification System (VNS).
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This document is a table of contents from a legal filing in Case 22-1426, dated June 29, 2023. It lists key documents in the case, including an OPR Report from November 2020, a District Court Opinion & Order from February 2022, and a Sentencing Transcript from June 2022, along with their corresponding page numbers in the larger document.
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This legal document page from April 2021 details events from December 2007 related to the Jeffrey Epstein case. It focuses on the decision by the U.S. Attorney's Office (USAO), led by Acosta, to defer to the State Attorney's Office on the matter of notifying victims about Epstein's state court proceedings. The text includes a quote from a proposed communication outlining this deference and Acosta's subsequent explanation to the Office of Professional Responsibility (OPR) that he trusted the state to fulfill its legal obligations to victims.
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This legal document details the federal handling of victim notification in the Jeffrey Epstein case in late 2007, specifically around his state plea hearing. It reveals that federal officials, including Villafaña, did not inform new victims of the Non-Prosecution Agreement (NPA) because they believed Epstein would still be federally charged. The document also outlines the coordination and communication challenges between the U.S. Attorney's Office and the State Attorney's Office regarding who was responsible for notifying victims for the state court proceedings.
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This document details an investigation into the origins of a two-year sentence proposal for Jeffrey Epstein, contrasting the differing recollections of prosecutors Acosta, Lourie, Menchel, and Sloman with documentary evidence. The record shows no indication that Epstein's team initially proposed the two-year term; in fact, they argued against any federal prosecution just before the offer was made. The document also outlines alternative, harsher sentencing options the U.S. Attorney's Office considered, such as a plea to a federal offense with a much longer sentence or a conspiracy charge, and why those options were ultimately rejected.
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This document details the legal wrangling in October 2007 regarding the Non-Prosecution Agreement (NPA) for Jeffrey Epstein. It highlights the friction between government attorneys (Villafaña, Sloman) and defense counsel (Lefkowitz, Sanchez) over the interpretation of victim compensation procedures (§ 2255) and the role of a special master. Notably, Villafaña expresses frustration with the defense's attempts to limit victim lawsuits, at one point asking her supervisor, "Can I please just indict him?"
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This document outlines the specific terms of the Non-Prosecution Agreement (NPA) between the USAO and Jeffrey Epstein, including deadlines for his guilty plea (Oct 2007) and self-reporting (Jan 2008). It explicitly grants immunity to 'any potential co-conspirator' and four assistants, waives Epstein's appeal rights, and notes the parties' intent to keep the agreement private. The document also details a communication from Epstein's lawyer, Lefkowitz, expressing concern over media leaks after the New York Post reported on the 18-month plea deal.
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This document outlines the specific terms of the Non-Prosecution Agreement (NPA) between the government and Jeffrey Epstein, requiring a guilty plea to state charges involving minors and a two-year prison sentence. It details the legal statutes violated (Florida statutes regarding lewd battery, solicitation, and sexual activity with minors) and stipulates that federal investigations would close upon his state sentencing. The document also includes a narrative section describing the contentious negotiation process between July and September 2007, noting the prosecution's frustration with defense tactics.
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This legal document details internal conflict within the U.S. Attorney's Office regarding the prosecution of Epstein. It describes prosecutor Villafaña's unsuccessful attempt to meet with her superior, Acosta, a contentious email exchange with her colleague Menchel that was later reviewed by the Office of Professional Responsibility (OPR), and her efforts to obtain computer evidence from Epstein's home. The document highlights disagreements on strategy and procedure among the prosecutors handling the case.
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This document is a table of contents for a 'Special Appendix' filed in legal case 22-1426 on February 28, 2023. It lists two key legal filings contained within the appendix: a 'Judgment of the Clerk' from June 29, 2022, and a 'Notice of Appeal' from July 7, 2022, indicating their respective page numbers.
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This document is a separator or title page within a larger legal filing (Case 22-1426) dated February 28, 2023. It marks the beginning of a section titled 'SPECIAL APPENDIX' and contains a Department of Justice Bates stamp.
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This is page 4 of a legal filing from September 24, 2020, in Case 20-3061. Ms. Maxwell's legal counsel requests permission to file several documents under seal, including an unredacted opening brief, Appendix Volume 2 (which is entirely confidential), and a response to the government's opposition. The document notes that the government does not oppose this motion.
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This is a court filing from September 24, 2020, in the United States Court of Appeals for the Second Circuit (Case 20-3061). Ghislaine Maxwell, through her attorneys Haddon, Morgan and Foreman, P.C., submits an unopposed motion to file three specific documents under seal: her unredacted opening brief, Appendix Volume 2, and an unredacted response to a government opposition motion. The document originates from an appeal of the case in the Southern District of New York.
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Page 2 of a legal letter addressed to Judge Alison J. Nathan dated August 24, 2020. The document argues against the government's characterization of Ms. Maxwell's defense strategy and disputes the government's claim that their issuance of subpoenas was 'standard practice,' citing case law (Martindell) to argue that the procedure used was improper. The document contains significant redactions.
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This is page 2 of a legal filing addressed to Judge Alison J. Nathan dated August 21, 2020, in case 1:20-cr-00330 (United States v. Ghislaine Maxwell). The text presents legal arguments supporting the continued sealing of documents related to grand jury proceedings and ex parte applications, citing various legal precedents regarding the First Amendment right of access versus the necessity of grand jury secrecy. A footnote mentions an April 2019 order that allows for limited exceptions to these sealing orders for discovery purposes.
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This document is the signature page of a court order, case number 1:20-cr-00330-AJN, filed on July 30, 2020. The order, signed by United States District Judge Alison J. Nathan in New York, states that Defense Counsel may apply to the Court for modifications. The document includes appendix and DOJ tracking numbers in the footer.
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This document is page 10 of a legal order, likely a protective order, filed on July 30, 2020. It details strict rules for the Defendant and their legal team regarding the handling of confidential discovery materials, prohibiting dissemination, copying, and public filing without explicit authorization from the Government or the Court. The order specifies that materials must be reviewed in the presence of counsel and may be inspected under the protection of law enforcement.
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This document is a page from a legal filing (Case 1:20-gp-00330-AJN) dated July 30, 2020, that establishes rules for handling "Highly Confidential Information." It defines this information as including nude or sexualized depictions, outlines the process for the Government to designate it, and details the procedure for Defense Counsel to challenge such designations with the Court. The document strictly limits the use of this information to the defense of the current criminal action.
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This is a page from a legal document, likely a protective order from case 20-cr-00330-AJN, filed on July 28, 2020. It defines how materials produced by the Government during discovery are to be designated and handled as "Confidential Information," particularly to protect the identities of victims and witnesses. The document also outlines the process for Defense Counsel to challenge these confidentiality designations.
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This document is a page from a Protective Order in a criminal case (Case 20-cr-00330-AJN), filed on July 27, 2020. It outlines strict rules for handling discovery materials, specifying that they can only be used by authorized individuals (such as the defense team and potential witnesses) for the sole purpose of preparing for the trial. The order explicitly prohibits all parties from posting any discovery information on the Internet and requires encryption for materials shared via non-electronic mail methods.
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This document is a court order, filed on July 27, 2020, that sets forth the rules for handling discovery materials in a criminal case. It strictly limits the use of these materials by the defendant and her defense counsel to the defense of the current criminal action. The order prohibits unauthorized copying, transmission, and distribution, specifying that disclosure is only permitted to a defined group of "Designated Persons," such as the defense team's investigative and paralegal staff.
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This legal document, dated July 27, 2020, is a filing to Judge Alison J. Nathan regarding a protective order in the criminal case against Ms. Maxwell. The government argues that restrictions on the use of discovery materials—prohibiting their use in civil proceedings or posting online—should apply not only to Ms. Maxwell and her defense but also to the government's potential witnesses and their counsel. This is requested due to concern that witnesses, who are involved in separate civil litigation with Maxwell, will use the discovery materials to support their civil cases or in public statements.
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This legal document, filed on July 8, 2020, outlines allegations against the defendant, Ghislaine Maxwell. It states that beginning in at least 1994, Maxwell enticed and groomed multiple minor girls for sexual abuse by Jeffrey Epstein. The document details the methods used, which included befriending the victims, normalizing sexual abuse, and being present during the acts to make the victims more comfortable.
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This page is from a legal brief (Case 20-3061, Document 60) filed on September 24, 2020. It argues that if Ms. Maxwell cannot appeal Judge Nathan's order via the 'collateral order doctrine,' the appellate court should instead issue a 'writ of mandamus' to modify the protective order. The document outlines legal precedents and the three specific conditions required to issue such a writ.
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This document is page 14 of a legal filing from September 24, 2020, concerning Ghislaine Maxwell's appeals. It outlines the procedural posture of two related appeals: one regarding Judge Preska's order unsealing deposition materials in the civil case (Giuffre v. Maxwell), and the current appeal regarding Judge Nathan's denial of a motion to modify a criminal protective order. Maxwell has moved to consolidate these two appeals.
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