DOJ-OGR
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Rick Ricarey
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This document is page 33 of a court filing (Jury Instructions) from December 2021 in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It outlines the four legal elements required to prove Count Six: Sex Trafficking of a Minor. The document specifically specifies that this count relates to a victim named Carolyn during the period of 2001 to 2004.
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This document is a table of contents from a larger legal filing (Document 562) in the federal criminal case 1:20-cr-00330-PAE, filed on December 17, 2021. It lists jury instructions numbered 23 through 53, covering charges such as Sex Trafficking of a Minor, Conspiracy to Violate Federal Laws, and Aiding and Abetting. The document also outlines procedural instructions regarding evidence, witness testimony, and the defendant's rights.
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This legal document, filed on December 17, 2021, is a page from a court proceeding in the case against Ms. Maxwell. The judge is providing guidance on the admissibility of evidence, citing the 2013 case 'United States v. Borrero' as precedent. The court will permit the defense to cross-examine government witnesses about their prior statements that did not implicate Ms. Maxwell in order to impeach their credibility.
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This document is a transcript from a final pretrial conference in case 1:20-cr-00330-PAE, filed on December 10, 2021. Counsel for the government and for the defendant, Ghislaine Maxwell, state their appearances for the record. The court outlines the plan for jury selection, which is scheduled to conclude on "Monday morning, the 29th," and notes that unused jurors are being kept on call at the recommendation of the jury department.
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This legal document is a memorandum of law, likely from the prosecution, arguing for the admission of an exhibit (GX 52) into evidence. It counters a defense objection that the witness, Mr. Alessi, cannot authenticate the exhibit because he has no personal knowledge of its creation. The memorandum cites several legal precedents to support the argument that a document can be authenticated under Rule 901(b)(4) based on its distinctive characteristics or a witness's general familiarity, even without direct observation of its creation.
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This document, a court transcript filed on December 8, 2021, details a discussion about jury selection in Case 1:20-cr-00330-PAE. The speaker, a court official, outlines the process of reviewing prospective juror lists, noting the government's and defense's differing views on excusing jurors. The document also mentions a communication from the defense requesting to modify its previous juror strikes.
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This legal document is a filing by the Government to Judge Alison J. Nathan in a criminal case, dated August 13, 2020. The Government argues that the defendant's request for more detailed charges is premature and should be handled through a formal motion for a bill of particulars after discovery is complete. The filing also expresses significant concern over the defense counsel's recent actions in a related civil case, suggesting they may have violated a protective order by publicly referencing sealed discovery materials.
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This legal document, dated July 27, 2020, is a filing in the criminal case of Ms. Maxwell, addressed to Judge Alison J. Nathan. It discusses the legal standard for a protective order over discovery materials, arguing that restrictions should apply not only to the defense but also to the government's potential witnesses and their counsel. The filing expresses concern that these witnesses, who are also involved in civil litigation against Ms. Maxwell, might use the discovery materials to support their civil cases or in public statements.
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This legal document is a filing by the Government arguing against the defendant's motion to dismiss charges. The Government asserts that the charges are timely under the law, independent of a prior investigation, and that the defendant's claims are baseless. Furthermore, the document argues that the defendant poses an extreme flight risk due to her international ties, financial resources, and French citizenship, noting that France does not extradite its citizens to the U.S.
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This document is page 24 of 33 from a court filing (Document 62) in case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 6, 2020. The text outlines the court's justification for a 'partial closure' of proceedings due to the COVID-19 pandemic, citing legal precedent regarding public access to courts versus health safety concerns. It specifically references COVID-19 statistics in New Hampshire as of July 2, 2020, to support findings of necessity.
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This document is page 13 of a court filing (indictment) from July 6, 2020, in the case against Ghislaine Maxwell. It details Count 16 (Conspiracy) and lists 'Overt Acts,' specifically alleging that between 1994 and 1997, Maxwell and Epstein engaged in group sexual encounters with 'Minor Victim-1' in New York and Florida, and that in 1996, the victim was enticed to travel across state lines for sexual abuse.
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This legal document, page 8 of a filing in case 21-770, argues on behalf of defendant Ms. Maxwell. It claims that preparing for trial from custody is impossible due to pandemic restrictions and an overwhelming 2.7 million pages of discovery. The filing criticizes the Government's response and alleges that newly provided evidence is actually exculpatory Brady material that undermines the prosecution's case.
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This is page 6 of a legal brief filed on April 19, 2021, in Case 21-770 (United States v. Maxwell). The text argues that the lower court failed to ensure the reliability of the government's evidence during bail hearings, citing legal precedents *LaFontaine* and *Martir*. The defense contends that unlike the *Martir* case, Ms. Maxwell actively challenged the government's 'flimsy proffer' through multiple hearings, but the court accepted the government's claims 'blindly' and 'uncritically.'
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This document appears to be page 12 of a legal filing from August 6, 2021, concerning a defendant named Mr. Robertson (Case 1:17-cr-02949). The text outlines significant challenges to the defense, including the recent withdrawal of initial attorneys, the complexity of the case (involving 24 government witnesses and potential 34-40 year sentence), and severe difficulties in trial preparation caused by COVID-19 restrictions at the Santa Fe County Detention Center. Specifically, the defense cites the inability to review documents effectively via Zoom or through glass partitions.
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This document is page 11 of a court filing (Case 4:17-cr-02949-MV) dated February 3, 2021. It argues for the pretrial release of a defendant named Mr. Robertson under 18 U.S.C. § 3142(i) to allow him to prepare for his trial scheduled for April 5, 2021. The text cites various legal precedents regarding temporary release for defense preparation. Note: While the user requested an 'Epstein-related' analysis, this specific page pertains to a 'Mr. Robertson' and does not contain direct text references to Jeffrey Epstein.
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This document is page 7 of a court order filed on February 6, 2020, regarding 'Mr. Robertson' (Case 1:17-cr-02949-MV). The court discusses the legal standards for detention under 18 U.S.C. § 3142 and finds that Mr. Robertson has successfully rebutted the presumption of detention. Factors cited for his release include his voluntary surrender, family ties, and placement at La Pasada Halfway House.
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This document is a page from a legal filing, likely a motion or a judicial opinion, dated February 5, 2016. It outlines the legal standards for a 'motion to reconsider' in federal court, citing various precedents. The text explains that while not formally recognized by the Federal Rules of Civil Procedure, district courts have inherent discretionary authority to reconsider non-final orders, but the scope for doing so is narrow and limited to specific grounds such as new law, new evidence, or correcting clear error.
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This document serves as Exhibit M (Doc. 159) within a court case (Case 21-770), dated April 1, 2021. It refers to a letter authored by Ghislaine Maxwell concerning the conditions at the Metropolitan Detention Center (MDC). The document is identified with a DOJ-OGR Bates number.
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This legal document is a court order from March 22, 2021, reaffirming the decision to detain a defendant. The Court concludes that the Government has shown the defendant is a flight risk and that no proposed conditions can reasonably assure her appearance. The Court's assessment of the factors under 18 U.S.C. § 3142(g), including the presumption of detention and the weight of the evidence, remains unchanged despite the defendant's new arguments.
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This legal document is a filing by the Government arguing that the Court should reject the defendant's proposed monitorship condition for her release from detention. The Government contends the proposal is insufficient because the defendant has a history of lacking candor about her finances, possesses significant international ties, and would retain control over substantial unrestrained assets, such as a $2 million townhouse in London. The filing emphasizes that the defendant remains a flight risk, a concern heightened by the previously established difficulty and length of any potential extradition process.
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This document is a cover page for Exhibit H, which is identified as Doc. 106, an "Opinion & Order" within the legal proceedings of Case 21-770. The document was filed on April 1, 2021, and is marked as page 68 of 165 in a larger set of documents.
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This legal document, part of a court filing, argues on behalf of Ms. Maxwell for bail. It refutes the government's claims by stating that her relationship with her spouse is a strong tie to the country, and that discussions of divorce were a protective measure, not indicative of a weak bond. The document also asserts that Ms. Maxwell has been fully transparent about her and her spouse's finances, accusing the government of baselessly claiming she was deceptive rather than challenging the accuracy of the financial reports provided.
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This legal document discusses the corroboration of victims' accounts against a defendant involved in Epstein's criminal scheme to sexually abuse minors. It addresses the defense's arguments regarding the sufficiency of evidence and witness testimony, asserting that multiple victims will provide consistent testimony about the defendant's role in grooming and enticing minor girls. The document also notes that the defendant has abandoned certain legal challenges related to bail after receiving discovery.
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This document is page 6 of a court filing (Document 100) from case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on December 28, 2020. It details the procedural history following the defendant's arrest on July 2, 2020, specifically focusing on the July 14, 2020 bail hearing where the defense argued for release based on family ties, offers of private security, and cooperation with the government following Jeffrey Epstein's arrest. The text includes transcripts of defense counsel offering to provide further financial verification and suretor information to satisfy the court's concerns regarding flight risk and financial transparency.
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This document is the table of contents for a legal memorandum filed by the government on June 28, 2020. The memorandum is in opposition to a defendant's renewed motion for release in case 1:20-cr-00330-AJN. The contents outline the government's arguments, including the nature of the offense, the strength of the evidence, the defendant's characteristics, and the conditions of confinement.
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