DOJ-OGR
OrganizationRelationship Network
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Rick Ricarey
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This document is the table of contents for a legal filing (Document 621) in case 1:20-cr-00330-PAE, filed on February 25, 2022. The filing outlines legal arguments against a defendant's motions to vacate their conviction, dismiss the indictment due to alleged pre-trial delays, and for a judgment of acquittal. The document structures the arguments, including discussions on applicable law and specific counts of the indictment.
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This is the final signature page (page 21) of a court document (Document 620) filed in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The document was signed by U.S. District Judge Alison J. Nathan on February 24, 2022, in New York, and filed the following day. The page includes a Department of Justice Bates stamp (DOJ-OGR-00009562).
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This document is page 19 of a court order filed on February 25, 2022, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Court denies the Defendant's request for pre-hearing discovery, characterizing it as a 'fishing expedition.' Additionally, the Court rules that 'Juror 50' will be provided a copy of his completed jury questionnaire and that the document must be unsealed (docketed), rejecting the Defendant's argument that this would taint the juror's testimony.
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This document is page 14 of a court order filed on February 25, 2022, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The court is rejecting the Defense's argument that Federal Rule of Evidence 606 (regarding juror competency as a witness) violates Maxwell's constitutional rights to due process and confrontation. The judge rules that Juror 50 was a factfinder, not a witness against the defendant, and cites Supreme Court precedents (Crawford, Tanner) to uphold the limitations on using juror affidavits to impeach a verdict.
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This page is from a court order filed on February 25, 2022, in the case against Ghislaine Maxwell. It discusses the legal standards for a post-trial evidentiary hearing regarding juror misconduct, specifically citing precedents like 'Ventura' and 'Guzman Loera.' The Court rules that it will conduct a hearing to investigate whether 'Juror 50' provided false answers to Question 48 on the jury questionnaire, which asked about personal or family history of sexual harassment or abuse.
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This document is page 2 of a legal filing (Document 617) in Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on February 24, 2022. The text argues against the defendant's claim that 'Juror 50's' motion to intervene constitutes a discovery request, clarifying that the juror is seeking access to his own questionnaire which he swore under penalty of perjury. The filing argues that the motion is a judicial document that should not remain sealed, noting the defendant's arguments regarding privacy and potential prejudice lack merit.
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This document is a placeholder page from a court filing, likely related to the United States v. Maxwell criminal case (based on the Case 1:20-cr-00330 fragment visible in the distorted header) or related civil litigation. It indicates that pages A-6044 through A-6073 were intentionally omitted from the record. The document bears the Bates stamp DOJ-OGR-00009524.
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This is a page from a court transcript (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) filed on February 24, 2022. The dialogue involves 'The Court' and attorney Mr. Shechtman discussing the conduct of lawyers named Brune and Richard. The debate centers on whether the lawyers' 'lack of candor' was due to carelessness or a strategic decision to 'game the system' and conceal information from the court.
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This document is a placeholder page from a legal filing, Case 1:20-cr-00330-PAE, filed on February 24, 2022. The page indicates that pages A-5874 through A-5902 were intentionally left blank. A Department of Justice (DOJ) Bates number is present in the footer.
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This document is an exhibit (A-5849) filed on Feb 24, 2022, in the Ghislaine Maxwell case (1:20-cr-00330-AJN), but originates from a 2012 filing in the 'United States v. Daugerdas' case (1:09-cr-00581-WHP). The text analyzes the ethical conduct of lawyers from the firm Brune & Richard regarding their knowledge of misconduct by 'juror Conrad' and whether they had a duty to disclose information discovered in March and May 2011. It concludes that the lawyers did not have 'actual knowledge' requiring disclosure under Rules 3.3(b) and 3.5(d).
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This document is a page from a court transcript (Case 1:20-cr-00330-AJN) filed on February 24, 2022. It features testimony from a witness named Edelstein regarding a discussion with Ms. Trzaskoma about Juror No. 1. They debated whether the juror was a suspended lawyer named Catherine Conrad but concluded at the time that it was 'inconceivable' based on voir dire responses, specifically regarding education.
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This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on February 24, 2022. It features the redirect examination of a witness named Brune, who is being questioned by the Judge about why his firm did not disclose knowledge regarding 'Juror No. 1.' Brune argues that the information was easily accessible via Google and assumed the government had also found it, specifically mentioning a letter the government received and a 'Westlaw report.'
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This is a page from a court transcript involving the direct examination of a witness named Brune. The testimony focuses on the staffing of Brune's legal team, identifying Nancy as a paralegal, Ken Renta as the managing clerk responsible for filings, and Dennis Donahue as a jury consultant hired specifically for the case who was present during voir dire. The document is part of a larger filing (Case 1:20-cr-00330) dated February 24, 2022.
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This document is page 86 of a 130-page index for a court transcript from the case of United States v. Paul M. Daugerdas, et al., dated February 15, 2012. It alphabetically lists keywords from 'production' to 'recovery' and provides the specific page and line numbers where these terms appear in the full transcript. The document is identified by the Bates number DOJ-OGR-00009295 and was produced by Southern District Reporters.
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This document is a page from a report by the DOJ's Office of Professional Responsibility (OPR), filed as an exhibit in the Ghislaine Maxwell case (1:20-cr-00330-PAE). It outlines the analytical framework and legal standards OPR uses to determine if a Department attorney has committed 'professional misconduct,' exercised 'poor judgment,' or merely made a 'mistake.' It specifically defines the thresholds for intentional violation and reckless disregard of obligations.
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This document details the plea negotiations in September 2007 between the USAO (represented by Villafaña, Acosta, and others) and Epstein's defense team. It outlines the drafting of a Non-Prosecution Agreement (NPA) proposing a 20-month jail sentence (reducible to 17 months with 'gain time') and notes a critical meeting on September 12 involving the State Attorney's Office to discuss state charges. The text also reveals internal USAO strategy, including preparing a revised indictment in case negotiations failed.
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This is page 168 of a legal filing (Document 204) from the case United States v. Ghislaine Maxwell, filed on April 16, 2021. The Government argues that perjury counts (Counts Five and Six) should be tried jointly with the sex trafficking counts (Counts One through Four) because they involve the same evidence and separating them would waste judicial resources and traumatize victims by forcing them to testify twice. The text explicitly references Epstein's scheme to abuse underage girls and Maxwell's alleged participation in recruiting girls for sexual massages.
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This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents an argument that a jury could find the defendant's testimony to be false. The prosecution argues that the defendant, likely Maxwell, falsely claimed to be unaware of any minors at Jeffrey Epstein's properties besides Giuffre, contradicting an indictment alleging interactions with 'Minor Victim-1'. The document refutes the defense's claims that the questions were ambiguous or improper, citing the defendant's own statements that the events in question 'never happened'.
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This document is page 152 of a legal filing (Document 204) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against dismissing a perjury count, stating that the defendant's denial of knowledge regarding Epstein's scheme to recruit underage girls for sexual massages was not due to fundamental ambiguity in the questioning. It includes a transcript excerpt from a deposition where Giuffre's counsel asks the defendant to list girls under 18 she brought to Epstein's house, to which Mr. Pagliuca objects.
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This document is a legal filing (page 122 of 239) by the Government opposing Ghislaine Maxwell's motion to suppress evidence and dismiss Counts Five and Six. The Government argues that suppression is unwarranted because the contested materials, specifically Maxwell's 2016 deposition transcripts, were already unsealed in civil litigation by Judge Preska and affirmed by the Second Circuit, making them subject to 'inevitable discovery.' Footnote 42 discusses the defendant's failed attempt to modify a protective order to use criminal discovery materials in her civil case.
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This document page is from a government filing in the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE), arguing that the prosecution did not improperly use civil discovery materials or mislead the court. The government distinguishes its actions from the 'Chemical Bank' precedent, noting that while AUSA-1 met with the law firm Boies Schiller in February 2016, no action was taken then, and the actual investigation began in November 2018 independent of improper influence.
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This document is a page from a 2021 court filing detailing the procedural history regarding the unsealing of documents in the Giuffre v. Maxwell civil case. It describes Magistrate Judge Netburn's 2019 denial of a Government application to modify a protective order, citing a lack of compelling need, and notes the subsequent reassignment of the case to Judge Preska, who ordered materials unsealed in July 2020.
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This court document outlines the procedural history of the civil litigation between Virginia Giuffre and Ghislaine Maxwell, including deposition dates in 2016 and a settlement in 2017. It details how the USAO-SDNY formally opened its investigation into Jeffrey Epstein and co-conspirators in late November 2018, explicitly crediting Julie K. Brown's reporting in the Miami Herald as the catalyst. The document also clarifies that a specific prosecutor, 'AUSA-1', was not involved in opening this 2018 investigation.
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This legal document is a portion of a government filing arguing against a defendant's motion to dismiss charges based on pre-indictment delay. The government asserts that the defendant has failed to meet the two-prong test required by the Second Circuit: demonstrating actual prejudice and proving the delay was for an improper government purpose. The filing cites several legal precedents to support its position that the defendant's due process claim is meritless and should be denied.
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This legal document, part of a court filing from April 16, 2021, argues against using a 'categorical approach' to interpret the phrase 'offense involving' in Section 3283. It cites several legal precedents, most notably Weingarten v. United States, to counter an argument made by an individual named Maxwell. The document asserts that Congress intended a broad application of the statute and that the categorical approach, typically used in sentencing or immigration contexts, is not appropriate here.
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