This page from a legal filing (dated April 1, 2021) argues for the temporary release of a defendant (likely Ghislaine Maxwell, based on the case number context) by citing legal precedents established during the COVID-19 pandemic. It references *United States v. Clark* and *United States v. Robertson* to establish that courts have granted release under 18 U.S.C. § 3142(i) when incarceration impedes the defendant's ability to prepare their defense. A footnote notes that the 10th Circuit stayed the release order in the *Robertson* case pending appeal.
This document is page 18 of a legal filing (Case 21-58) dated April 1, 2021. It presents legal arguments for temporary release under 18 U.S.C. § 3142(i), citing the COVID-19 pandemic's impact on a defendant's ability to communicate with counsel and prepare a defense. The text analyzes case precedents *United States v. Clark*, *Stephens*, and *United States v. Robertson*, highlighting that even defendants with serious charges (like Robertson) were released to prepare for trial during the pandemic.
This is page 6 of 10 from a defense motion filed on October 29, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The document argues that specific witnesses (whose names are redacted) should be precluded from offering 'overview' testimony or expert opinions because the government failed to provide the required pretrial disclosures under Federal Rule of Criminal Procedure 16(1)(G). The text cites *United States v. Brooks* to argue that overview testimony by government agents can improperly influence the jury by introducing credibility assessments or hearsay not in evidence.
This document is page 23 (Bates HOUSE_OVERSIGHT_017737) of a legal text, specifically from the 2005 B.Y.U. Law Review, bearing the name David Schoen. It outlines proposals and rationales for modifying Federal Rules of Criminal Procedure 15 and 17 to enhance victims' rights, specifically regarding their right to attend pre-trial depositions and their right to receive notice before their confidential information is subpoenaed.
This document is an excerpt from a 2007 Utah Law Review article (page 71 of 78 in the exhibit) discussing the Crime Victims' Rights Act (CVRA). It argues that the Advisory Committee's proposed rules improperly limit the venue for asserting victims' rights to cases where prosecution is already underway, potentially failing to protect victims during the investigation phase (pre-charge) when rights to fairness and dignity might be violated by federal agents. The document bears the name of attorney David Schoen and a House Oversight Bates stamp, suggesting it was part of an investigation file, likely regarding the handling of the Epstein case and the non-prosecution agreement.
This document is page 65 of a 2014 law review article detailing the history of the Crime Victims' Rights Act (CVRA). It explains that in April 2004, advocates shifted focus from a constitutional amendment to federal legislation due to the difficulty of obtaining a supermajority. The text discusses the limitations of the 1990 Victims' Rights and Restitution Act and cites various legal scholars and Senators (Kyl, Leahy, Feinstein) regarding the legislative history. This document appears in the House Oversight collection likely as background material regarding the legal framework relevant to the Epstein case's non-prosecution agreement.
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