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034.pdf
This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss Plaintiff's Complaint, filed by the executors of the Estate of Jeffrey E. Epstein. The defendants argue that the plaintiff's claims for battery and intentional infliction of emotional distress, stemming from alleged sexual assaults in 1999, are time-barred by the applicable statutes of limitations in New York and Florida. They further argue that recent New York legislation extending the statute of limitations does not apply retroactively to already expired claims, and that the plaintiff cannot claim equitable tolling or estoppel. Additionally, the defendants assert that punitive damages cannot be recovered from a decedent's estate under New York or Florida law.
EFTA00021406.pdf
An email thread from July 16, 2019, between SDNY Public Affairs staff discussing a modification to the SDNY website homepage. The sender proposes replacing a 'Sexual Assault in Public Housing' image with a new graphic (attachment named 'Epstein_Homepage.png') that links to a victim/witness page, likely in response to the Jeffrey Epstein case which was active at that time.
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This document is Instruction No. 40 regarding 'Venue' from a legal case (1:20-cr-00330-PAE) filed on December 17, 2021. It instructs the jury that the Government must prove, by a 'preponderance of the evidence,' that an act related to each charged crime occurred within the Southern District of New York, which includes several specified counties. The document clarifies that if the Government fails to meet this burden of proof for any specific charge, the jury must acquit the defendant, Ms. Maxwell, on that charge.
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This document is page 7 of 8 from a court filing (Document 9) dated November 19, 2019, in case 1:19-cr-00830-AT (related to the prosecution of Epstein's guards, Tova Noel and Michael Thomas). It displays a map outlining the jurisdictional boundaries of the Southern District of New York (SDNY) and the Eastern District of New York (EDNY), listing the specific counties included in each district. There are handwritten notes in the bottom right corner that appear to read 'DNO' and 'EDPA'.
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This document is page 9 of a 10-page court filing from November 19, 2019, in case 1:19-cr-00830-AT. It is part of an "Advice of Penalties" form and consists of a map and a list defining the counties that fall under the jurisdiction of the Southern and Eastern Districts of New York federal courts. The document is marked with a Department of Justice Bates number, indicating it was produced as part of a legal proceeding.
DOJ-OGR-00002830.jpg
This legal document, page 9 of a court filing dated March 24, 2021, details a court's analysis of a dispute between the defendant, Schulte, and the Government over the proper 'relevant community' for jury selection. The court sides with the Government, ruling that the appropriate jury pool is the White Plains master wheel, which draws from all counties in the Southern District, rather than just those that supply jurors to Manhattan where the trial is to be held. This decision is based on legal precedent and the statutory composition of the judicial district.
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This document is page 4 of a legal filing dated March 26, 2021, likely relating to the Ghislaine Maxwell trial given the timeline and context of jury selection in the Southern District of New York (SDNY). It outlines the procedural mechanics of the 'Jury Plan,' detailing how master jury wheels are constructed from voter registration lists in specific NY counties (Manhattan, Bronx, Westchester, etc.) to ensure proportionate representation. A footnote clarifies qualification criteria for jurors, including English proficiency, citizenship, and exemptions for hardship or occupation.
DOJ-OGR-00008763.jpg
This document is a page from the jury instructions (Instruction No. 40) for the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 19, 2021. It defines the legal concept of 'Venue' within the Southern District of New York and lists the specific counties included in that jurisdiction. The instruction clarifies that the Government must prove venue by a 'preponderance of the evidence' rather than 'beyond a reasonable doubt,' stating that Maxwell must be acquitted of any specific offense if venue is not established for it.
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This document is page A19 of 46 from an OGE Form 278e financial disclosure filed by Donald J. Trump. It details the ownership structure of several Trump properties, primarily golf clubs in Charlotte, Hudson Valley, Jupiter, and Philadelphia, as well as entities related to properties in Toronto and New York (106 CPS and 845 UN). The document establishes DJT Holdings LLC and The Donald J. Trump Revocable Trust as the primary holding vehicles for these assets. It bears a 'HOUSE_OVERSIGHT' stamp, indicating it was part of a document production to Congress.
HOUSE_OVERSIGHT_010622.jpg
This document is page 6 of 51 from Donald J. Trump's OGE Form 278e financial disclosure. It lists positions he held outside the US government in various LLCs and Corporations (rows 200-247), primarily involving real estate, golf clubs (TNGC), and licensing entities. Most positions show an end date of January 19, 2017, the day prior to his presidential inauguration.
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