Court
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
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Documents | Actions |
|---|---|---|---|---|
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person
Juror 50
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Juror candidate |
5
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1 | |
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person
Cynthia Hopkins
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Employee |
1
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1 |
DOJ-OGR-00010435.jpg
This legal document, filed on June 15, 2022, argues against applying the sentencing guideline § 4B1.5 to Ms. Maxwell. The author contends that the guideline is intended only for recidivist sex offenders who pose a continuing danger to the public, which they claim Ms. Maxwell is not. Applying the guideline would allegedly contradict the intent of Congress and the Sentencing Commission, improperly add over 10 years to her sentence, and lead to an absurd result.
DOJ-OGR-00010424.jpg
This legal document, part of a court filing, argues that Ms. Maxwell must be sentenced under the 2003 Guidelines rather than the harsher 2004 Guidelines. It asserts that applying the 2004 Guidelines would violate the Ex Post Facto Clause unless a jury, not the judge, found that her criminal conduct continued past November 1, 2004. Since the jury made no such finding, the court is bound to use the earlier guidelines.
DOJ-OGR-00010423.jpg
This legal document is a filing in the case of Ms. Maxwell, arguing that the 2003 U.S. Sentencing Guidelines should apply to her case, not the harsher 2004 Guidelines. The central dispute is the end date of the criminal conduct, with the defense contending it ceased by 2003 at the latest, before the 2004 Guidelines took effect. The document asserts that this factual determination must be made by a jury, not the court, consistent with the Ex Post Facto Clause.
DOJ-OGR-00010404.jpg
This legal document is a court ruling denying a motion from the Defendant, Maxwell. The Defendant argued that the Government's delay in bringing charges prejudiced her ability to prepare a defense, but the Court found no evidence that the delay was intentional or for tactical advantage. The Court reaffirms its previous rulings and notes that trial testimony provided legitimate explanations for the timing of the indictment.
DOJ-OGR-00010403.jpg
This legal document is a court opinion denying a defendant's post-trial motions. The court rejects the defendant's argument that a witness's (Jane's) testimony caused "ultimate prejudice" leading to improper convictions on Mann Act counts. The court also denies the defendant's claim of prejudicial pre-indictment delay, stating that the defendant failed to meet the stringent two-part legal test required to prove such a claim.
DOJ-OGR-00010400.jpg
This document is a page from a legal filing, likely a response from the prosecution, arguing that the court's jury instructions were proper. It states the court correctly instructed the jury to consider only New York law as the predicate offense for the Mann Act counts and was right to reject the defendant's requests for additional limiting instructions regarding testimony about events in New Mexico and varying ages of consent. The filing asserts that the defendant's claim of potential jury confusion is speculative and implausible.
DOJ-OGR-00010398.jpg
This legal document, part of a court filing, defends the court's decision to reject the defendant's proposed jury instructions. The court argues the requested instructions were unresponsive, redundant, and legally inaccurate, particularly the claim that sexual activity outside New York could not form the basis for the charges. The document asserts that the existing jury charge correctly focused the inquiry on the violation of New York Penal Law Section 130.55, specifically concerning the overt act of transporting the victim, Jane, from Florida to New York for the purpose of sexual abuse.
DOJ-OGR-00010397.jpg
This legal document, filed on April 29, 2022, details a dispute during a trial over how to respond to a note from a deliberating jury. The Defendant proposed several responses, which the Court deemed legally erroneous, including a simple 'no' and later a request to direct the jury to specific lines of an instruction. The core issue revolves around the Defendant's argument concerning the purpose of a return flight in relation to illegal activity and the Court's discretion in guiding the jury.
DOJ-OGR-00010394.jpg
This legal document is part of a court filing arguing that the government's summation during a trial did not constructively amend the indictment. The prosecution consistently maintained that the defendant and an associate, Epstein, transported underage girls like "Jane" to New York with the intent for them to be sexually abused there. The defense counters that a jury note suggests the conviction was based on intent for activity in New Mexico, not New York, and that the court erred by not providing a supplemental instruction to clarify this point.
DOJ-OGR-00010393.jpg
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.
DOJ-OGR-00010390.jpg
This legal document is a court filing from Case 1:20-cr-00330-PAE, dated April 29, 2022. It addresses the Defendant's argument that her conviction was based on a 'constructive amendment' to the indictment, because a jury note suggested they found her guilty of intending a crime in New Mexico, rather than New York as charged. The court refutes this claim, concluding there is no 'substantial likelihood' that the Defendant was convicted of an offense different from the one in the indictment.
DOJ-OGR-00010389.jpg
This legal document, part of a court filing, discusses the legal distinction between a 'constructive amendment' and a 'variance' in a criminal indictment. It cites numerous precedents to argue that for a variance to warrant reversal of a conviction, the defendant must demonstrate 'substantial prejudice'. The document concludes by noting that the Defendant has filed a motion under Rule 33 to vacate the judgment and grant a new trial.
DOJ-OGR-00010388.jpg
This document is a page from a legal filing dated April 29, 2022, in which a court outlines the applicable law regarding constructive amendments to a grand jury indictment. The court explains that under the Fifth Amendment, a defendant can only be tried on the charges in the indictment, and details the legal standard for determining if the trial evidence or jury instructions improperly altered the "core of criminality" of the alleged crime. The court cites numerous precedents from the Second Circuit to support its analysis before denying the defendant's motion.
DOJ-OGR-00010385.jpg
This legal document details testimony from a witness named Carolyn, who states that the Defendant arranged for her to perform sexualized massages for Epstein while she was a minor between 2001 and 2004. The document outlines specific incidents, including one where the Defendant assaulted Carolyn at age fourteen, and mentions corroborating evidence from her boyfriend Shawn and physical evidence like phone messages. A footnote adds further evidence related to another victim, Virginia Roberts, including testimony from Juan Alessi and flight records, to support a conspiracy charge against the Defendant.
DOJ-OGR-00010381.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 29, 2022, argues that two counts against the defendant (Count Three and Count Five) are multiplicitous and constitute double jeopardy. The argument is based on the government's own trial presentation, which framed the defendant's actions with co-conspirator Epstein as a single, decade-long conspiracy or "scheme." Citing legal precedents like Korfant and Josephberg, the document contends the proper remedy is for the court to enter judgment on only one of the two counts.
DOJ-OGR-00010362.jpg
This legal document is a court's conclusion regarding a defendant's motion to find a juror, Juror 50, biased. The defendant argued the juror's failure to disclose a personal history of sexual abuse during jury selection showed an inability to be impartial. The Court rejects this argument, finding that the juror's omission was due to inattention rather than a deliberate lie or perjury, and therefore denies the defendant's motion.
DOJ-OGR-00010354.jpg
This legal document is a court's analysis of a defendant's (Maxwell) challenge to the impartiality of Juror 50. The court finds Juror 50's testimony credible and determines he did not deliberately lie to be selected, distinguishing his situation from a precedent case (Sampson) involving extensive dishonesty. The court also addresses Maxwell's argument that Juror 50 was biased due to similarities between his personal history of sexual abuse and the trial's subject matter, noting the defendant's nuanced argument for implied or inferred bias.
DOJ-OGR-00010317.jpg
This legal document analyzes the conduct of Juror 50 during and after the Ghislaine Maxwell trial. It highlights Juror 50's public revelation of his jury service on social media and his multiple false statements to the Court regarding his impartiality and willingness to follow instructions. The document argues that these actions demonstrate Juror 50's bias and inability to serve as an unbiased juror, providing grounds for a cause challenge.
DOJ-OGR-00010314.jpg
This legal document, from the law offices of Bobbi C. Sternheim, argues that 'Juror 50' demonstrated bias by providing false answers on a juror questionnaire. The filing disputes the juror's explanations for his answers—such as being rushed or no longer identifying as a victim of past abuse—as not credible, citing his own testimony and the content of the questionnaire itself as evidence.
DOJ-OGR-00010304.jpg
This legal document is page 14 of a court filing, arguing against a defendant's motion claiming juror bias. The author contends that there is no evidence of actual bias from Juror 50, citing the juror's statements, the jury's diligent five-day deliberation, and the resulting split verdict. The document also dismisses the claim of implied bias, stating that the circumstances do not meet the narrow criteria established by the Second Circuit.
DOJ-OGR-00010302.jpg
This legal document analyzes the credibility of Juror 50, concluding he should not be struck for cause. It argues that his prior experience with sexual abuse did not impede his ability to be a fair juror and that his subsequent press interviews were a result of naivety, not deception. The document cites the juror's own testimony and demeanor to support the claim that his failure to disclose information was an inadvertent error.
DOJ-OGR-00010300.jpg
This legal document, part of case 1:20-cr-00330-PAE, argues that a juror, identified as Juror 50, did not deliberately lie on a questionnaire but rather made an "honest mistake." A hearing established that the juror was not biased, approached his service with an open mind, and would not have been dismissed for cause even if he had answered correctly. Therefore, the document concludes that the defendant's motion for relief based on the juror's alleged misconduct should be denied.
DOJ-OGR-00010299.jpg
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.
DOJ-OGR-00010298.jpg
This legal document argues that Juror 50 did not intentionally lie on a jury questionnaire when he failed to disclose childhood sexual abuse. The filing explains that the juror did not consider the unprosecuted abuse a "crime" and did not initially consider his estranged stepbrother, the abuser, to be a "family member" in the context of the questions. The document contends that a lay juror's interpretation of such questions should not be held to the strict standard of a trained lawyer.
DOJ-OGR-00010296.jpg
This legal document, filed on March 15, 2022, analyzes the testimony of Juror 50 regarding his answers on a jury questionnaire, specifically Question 48. Juror 50 explains that any inaccuracies were unintentional, attributing them to distractions and a desire to finish quickly, rather than a deliberate attempt to be selected for the jury. The document cites legal precedents to argue that the juror's credibility is not diminished, as jurors are not held to the same standards as lawyers.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2009-09-17 | Received | Burman, Critton, ... | Court | $138.80 | Invoice for cancelled deposition services (Appe... | View |
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