DOJ-OGR
OrganizationRelationship Network
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Rick Ricarey
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This is a page from a court transcript filed on August 10, 2022, from United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). Defense attorney Mr. Pagliuca explains difficulties in finalizing a witness list because the government rested its case earlier than expected, causing scheduling and travel issues. Prosecutor Ms. Moe counters that the defense was warned repeatedly and demands immediate production of Rule 26 materials, including expert communications, contracts, and witness interview notes.
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This document is a page from the cross-examination transcript of witness A. Farmer (Annie Farmer) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). The questioning focuses on when Farmer hired legal counsel, establishing that she spoke to attorneys in 2016 but formally hired the Boies Schiller firm (specifically Ms. McCawley) prior to meeting with the government in September 2019. The text confirms these attorneys filed both a civil lawsuit and documents for the Epstein Victims Compensation Fund on her behalf.
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This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022, featuring the cross-examination of a witness named A. Farmer. The questioning focuses on a journal entry written by the witness regarding a 'movie theater incident,' specifically highlighting the witness's internal conflict about whether the event was 'weird' or if they were 'justifying' it.
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This document is a page from a court transcript dated August 10, 2022, from a case identified as 1:20-cr-00330-PAE. It features the direct examination of a witness named A. Farmer, who is questioned about a past settlement received from a fund, the dismissal of a lawsuit against Maxwell and Epstein, and whether their civil case is concluded. A. Farmer confirms the civil case is over, they do not expect more money, and have no financial stake in the outcome of the current trial.
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This document is an excerpt from a court transcript dated August 10, 2022, detailing a sidebar discussion in a legal case. Attorneys Ms. Pomerantz and Ms. Menninger, along with 'The Court,' debate the nature and admissibility of a 'prior consistent statement' and its implications for impeaching a witness. The discussion centers on a statement made by an unnamed individual to her mother, 'I wasn't raped,' and whether its elicitation would pose further legal problems.
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This document is a page from a court transcript of the cross-examination of pilot David Rodgers (filed Aug 10, 2022). Defense attorney Mr. Everdell questions Rodgers about flight protocols on Epstein's Gulfstream and Boeing aircraft, specifically confirming that while cockpit doors were closed, Epstein never explicitly instructed Rodgers that he could not leave the cockpit or mingle with passengers.
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This document is page 23 of a court filing (Case 1:20-cr-00330-PAE, Document 674) filed on June 24, 2022. It consists of a single photograph showing an unidentified person in a hospital bed, seemingly unconscious and connected to life support equipment. The page is marked with a Department of Justice Bates number, suggesting it is an exhibit or evidence in a legal case.
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This page is from a legal filing (Document 670) in the case United States v. Ghislaine Maxwell, filed on June 22, 2022. It presents legal arguments regarding sentencing guidelines, specifically U.S.S.G. § 4B1.5 and the Protection of Children from Sexual Predators Act of 1998, arguing that penalties should be increased for patterns of sexual abuse involving minors. The prosecution argues that specific 'background commentary' cited by the defense is not binding and should not override the text of the relevant guidelines intended to ensure severe punishment for such crimes.
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This document is page 31 of a legal filing (Document 670) from the case US v. Ghislaine Maxwell, dated June 22, 2022. The text argues for a sentencing enhancement based on 'undue influence' exerted over a victim named Carolyn. It details how the defendant (Maxwell) groomed Carolyn by exploiting her drug addiction with money, discussing her personal trauma, and directing Virginia (Giuffre) to teach Carolyn how to sexually gratify Jeffrey Epstein.
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This legal document argues that the harsh conditions of Ms. Maxwell's 22-month pretrial detention, described as 'supermax-type' and 'de facto solitary confinement', should be factored into her sentencing. Citing the principle of proportionality, the filing requests a 'hard-time credit' for this unusual hardship and references compensation laws for the wrongfully convicted to illustrate the severity of her confinement.
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This legal document, a page from a court filing, argues that the harsh conditions of incarceration during the COVID-19 pandemic should be considered a mitigating factor for sentencing. It cites multiple precedents from the Southern District of New York (S.D.N.Y.) to support the claim that the pandemic, with its associated lockdowns and health risks, has made prison time significantly more punitive than under normal circumstances. The argument is made in the context of a defendant, Ms. Maxwell, to warrant a downward variance in her sentence.
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This document is a page from a defense sentencing memorandum for Ghislaine Maxwell, filed in June 2022. The defense argues against applying 2004 sentencing guidelines, asserting that Maxwell had ceased participation in the conspiracy by 2002/2003 and was 'replaced' by Sarah Kellen for scheduling duties at the Palm Beach residence. The text cites testimony from Cimberly Espinosa, Juan Alessi, and a witness named Carolyn to support the claim that Maxwell had moved on to a relationship with Ted Waitt and was not involved in Epstein's conduct in late 2004.
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This page from a court order (Case 1:20-cr-00330-PAE) rejects the Defendant's (Ghislaine Maxwell) argument that she was prejudiced by the inability to call deceased witnesses, specifically two architects and a housekeeper. The court rules that this argument is speculative and unsubstantiated because other available witnesses, including Juan Alessi, Larry Visoski, and David Rodgers, testified at trial covering similar topics regarding Epstein's residences, renovations, and private aircraft.
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This legal document is a portion of a filing, likely from the prosecution, arguing against a Defendant's claim of prejudice due to a delay in prosecution. The prosecution asserts that the Defendant has failed to meet the high legal standard for proving prejudice, citing case law. The Defendant's claims are based on the loss of documentary evidence (flight, financial, phone, and property records related to Epstein) and the deaths of four potential witnesses (architects Albert Pinto and Roger Salhi, and property manager Sally Markham).
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This page details the Government's evidence regarding the Defendant (Maxwell) and Epstein's criminal scheme, focusing on the testimony of a victim named Jane. It describes how Jane was groomed and trafficked across state lines, including trips to New York, Florida, and New Mexico, for sexual activity with Epstein, facilitated by the Defendant.
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This legal document, page 8 of a filing in case 1:20-cr-00330-PAE dated April 29, 2022, analyzes the legal distinctions between two conspiracy charges, Count Three and Count Five. The author argues that despite being charged under the same statute, the counts are not multiplicitous because they have different statutory objectives, legal definitions (e.g., of a 'minor'), and required elements of intent, citing precedents like Macchia, Estrada, and Villa. The document refutes the Government's claim that a single distinguishing factor is dispositive in this analysis.
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This legal document argues that a juror, identified as Juror 50, should not be found to lack credibility for an inaccurate answer on a jury questionnaire. The author contends the juror's response was an honest mistake based on a reasonable interpretation of the question regarding his 'former stepbrother' and was not a deliberate attempt to get on the jury. The document cites legal precedents to support the idea that a fair, not perfect, trial is what is required, and an honest juror mistake does not invalidate the trial's outcome.
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This legal document details the testimony of Juror 50 regarding an inaccurate answer he provided on a jury questionnaire. Juror 50 claims the error was an "inadvertent mistake" caused by skimming the question too quickly and being distracted by the environment in the courthouse. The document contrasts the juror's explanation with the defendant's legal argument that the juror's actions satisfy the first prong of the McDonough test for juror dishonesty.
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This document is page 12 of a defense filing (Document 647) dated March 11, 2022, in the case against Ghislaine Maxwell. The text argues that the jury instructions were insufficient and led to a 'constructive amendment' of the indictment, potentially allowing the jury to convict Maxwell based on activity in New Mexico rather than the required New York jurisdiction. It highlights a 'Jury Note' demonstrating the jury's confusion regarding Count Four and the application of New York Penal Law Section 130.55.
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This document is the Table of Contents for a legal filing (Document 647) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on March 11, 2022. The filing outlines arguments that the Court erred in its response to a jury note regarding intent requirements for Count Four and argues that the three conspiracy counts are multiplicitous because they stem from a single criminal scheme. It concludes with a request for the Court to grant Maxwell's other motions.
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This document is a placeholder page from a legal filing, specifically page 105 of 117 in Document 646-32, filed on February 22, 2022, for Case 1:20-cr-00033-ABJ. The page states that pages A-6044 through A-6073 were intentionally left blank. A Department of Justice identifier, DOJ-OGR-00010203, is present in the footer.
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This document is the cover page for "Exhibit G," filed as part of a legal proceeding. It contains metadata from two separate court cases: Case 1:09-cr-00581-WHP, filed on March 15, 2013, and Case 1:20-mc-00389-AEN, filed on March 22, 2022. The page is marked with Bates numbers A-6041 and DOJ-OGR-00010200.
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This document is a page from a court transcript in the case 'United States of America v. David Parse.' It records the opening of oral arguments regarding Parse's motion for a new trial based on ineffective assistance of counsel. Defense attorney Paul Shechtman and prosecutors Nanette Davis and Stanley J. Okula, Jr. are present. While part of a larger batch of documents (indicated by the DOJ-OGR Bates stamp) often associated with Epstein-related releases, the text specifically concerns the trial of David Parse.
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This document is a page from a deposition transcript involving a witness named Edelstein. The questioning focuses on a Westlaw report, a Bronxville address, and the identification of Robert Conrad (an immigration judge) as the father of Catherine Conrad and 'head of household.' The witness also acknowledges seeing email traffic referencing Robert Conrad later in the process.
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This document is a page from a court transcript (filed March 24, 2022) featuring the direct examination of a witness named Ms. Brune. The questioning focuses on the ethical obligations of a female partner at Brune's law firm, establishing that she has independent obligations to the Court despite Brune's supervisory role. The testimony also references the review of email traffic leading up to the submission of a letter on July 21st.
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