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CAROLYN
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This document is a 'Statement of the Issues Presented for Review' from an appellate brief (Case 22-1426, dated Feb 28, 2023). It outlines four main legal arguments for appeal: the misapplication of a non-prosecution agreement, errors regarding statutes of limitations, juror misconduct involving concealed history of sexual abuse, and a constructive amendment of the indictment regarding venue (New Mexico vs. New York) and state law.
This document is page 15 of a legal filing (Case 22-1426, Document 59), dated February 28, 2023. It appears to be a Table of Authorities, listing various legal statutes, congressional reports, and a news article from the Independent newspaper concerning a juror in the Ghislaine Maxwell trial.
This document is page 'ix' from a legal filing, specifically Document 59 in Case 22-1426, dated February 28, 2023. It serves as a table of authorities, listing numerous U.S. court cases with their legal citations and corresponding page references within the larger document. The cases cited span from 1926 to 2017 and originate from various federal district and circuit courts.
This document is a table of contents from a legal filing dated February 28, 2023, related to Case 22-1426. It outlines the arguments for an appeal on behalf of 'Maxwell', alleging multiple errors by the District Court, including the handling of 'Juror 50' in a post-trial hearing, constructively amending the indictment, and applying an incorrect sentencing guideline. The filing seeks to have the sentence vacated and the case remanded for resentencing.
This legal document is a page from a court filing arguing against a defendant's claim of prejudice due to the death of potential witnesses. The prosecution contends that the defendant's assertions about what these witnesses (architects and a housekeeper) would have testified are speculative and unsubstantiated. It further argues that other witnesses, such as Juan Alessi, Larry Visoski, and David Rodgers, were available and did testify about similar matters, like renovations at Epstein's residences, meaning the information was obtainable through other means.
This document is page 41 of a court ruling (likely denying a motion to dismiss) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The text discusses the legal standard for 'pre-indictment delay' and 'lost evidence,' specifically refuting the Defendant's claims that lost government property records and flight manifests (delivered by pilot Larry Visoski to Epstein's NY office) prejudiced her defense. The court argues the Defendant failed to prove these records were unavailable through other means or that their absence was caused by the government's delay.
This legal document is a court's analysis of a defendant's claim that missing evidence—such as financial records, phone records, and flight manifests—was prejudicial to her case. The court rejects this argument, stating the defendant failed to demonstrate what the absent documents would have shown or how they would have been beneficial, concluding the claims are purely speculative. The court notes that the missing evidence could just as easily have further substantiated the government's case.
This document is a page from a legal filing (Document 657 in Case 1:20-cr-00330-AJN) addressing the Defendant's (Ghislaine Maxwell) claim that delay in prosecution caused prejudice to her defense. The text argues the defendant failed to prove substantial prejudice but outlines her specific claims regarding lost evidence, including flight records, financial documents, phone records, and property records. It specifically names deceased witnesses the defense claims were unavailable: architects Albert Pinto and Roger Salhi, and property manager Sally Markham.
This legal document page details the court's reasoning for rejecting the Defendant's proposed jury instructions. The court argues that it correctly instructed the jury on the sole predicate offense under New York Penal Law, avoiding confusion that the Defendant's proposals regarding other jurisdictions' laws and specific witness testimonies (from Kate, Annie, and Jane) would have created. The document concludes that the Defendant's claim of potential jury error, specifically regarding conduct in New Mexico versus New York, is speculative and implausible.
This document is a page from a legal filing (likely a Government brief or Court Opinion) in the case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It discusses the Court's rejection of the Defendant's requests regarding jury instructions, specifically concerning 'travel to New York' and the age of consent laws in New Mexico, the UK, and Florida. The text argues that the Court's instructions were legally sound and that the Defendant's proposals would have confused the jury.
This legal document is a page from a court filing arguing against the defendant's (Maxwell's) appeal regarding jury instructions. The filing asserts that the trial court correctly rejected the defendant's proposed instruction because it was unresponsive, redundant, and legally inaccurate. The core issue revolves around whether sexual activity outside of New York could form the basis for a conviction, with the filing arguing that the existing jury charge sufficiently clarified that the violation had to be under New York Penal Law.
This page from a legal filing (Case 1:20-cr-00330-AJN, likely the Ghislaine Maxwell trial) discusses a dispute over a jury note regarding 'Count Four.' The argument centers on whether the jury could convict based solely on conduct in New Mexico versus the required New York law violation. The text details a debate over the placement of a comma in the jury's note and the Court's subsequent instruction to the jury to focus on New York law.
This document is a page from a legal ruling (likely denying a new trial) in the case United States v. Ghislaine Maxwell. It discusses a jury note asking for clarification on 'Count Four' regarding whether aiding a victim's ('Jane') return flight constitutes guilt if the defendant did not aid the initial flight to New Mexico for sexual activity. The Court rejects Maxwell's argument that the jury instruction was unclear or that it constructively amended the indictment, noting that Jane testified about numerous flights on both Epstein's private plane and commercial airlines.
This document is a legal filing (likely an appellate brief response) from April 2022 summarizing testimony from a victim identified as 'Jane' regarding the criminal conduct of Ghislaine Maxwell ('the Defendant') and Jeffrey Epstein. It details how Jane met the pair at a summer camp, was groomed, and transported via private and commercial flights to properties in Florida, New York, and New Mexico for sexual activity starting when she was 14. The text highlights Maxwell's role in arranging travel and participating in the scheme to transport underage girls across state lines for illegal sexual acts.
This legal document, part of a court filing, discusses limiting instructions given to a jury. The instructions clarified that the testimony of two witnesses, Kate and Annie, could not be the sole basis for conviction on certain counts because their experiences either involved someone not legally a victim under the specific charges (Kate) or occurred in a different jurisdiction (Annie in New Mexico). The court aimed to focus the jury's attention on the specific alleged crime: the transport of a minor, Jane, to New York for sexual activity illegal under New York law.
This legal document, filed on April 29, 2022, discusses the jury instructions given in a criminal trial. It details how the Court instructed the jury that the Defendant's charges under the Mann Act were predicated on specific violations of New York Penal Law Section 130.55, which criminalizes sexual contact with a person under seventeen. The document confirms the Court clarified this point and specified overt acts from the indictment, including one from 1996, to guide the jury's deliberations.
This document is page 24 of a court ruling (filed April 29, 2022) in the case against Ghislaine Maxwell (referred to as the Defendant). It addresses a defense motion regarding a 'constructive amendment,' specifically discussing whether the jury improperly convicted the Defendant based on intent for sexual activity in New Mexico (involving a victim named 'Jane') rather than New York, as charged in the indictment involving a scheme with Jeffrey Epstein.
This legal document is a court filing that denies a defendant's motions for acquittal and to vacate convictions related to the Mann Act. The court found sufficient evidence from witness testimonies (including from 'Carolyn', 'Annie', and 'Kate') to conclude that the defendant conspired with Epstein to transport minors to locations like New York, New Mexico, and the Caribbean for illegal sexual activity. The defendant's actions, such as paying for sexualized massages and inviting girls to travel, were considered part of this conspiracy, justifying the jury's conviction.
This legal document, a page from a court filing dated April 29, 2022, outlines the court's conclusion that trial evidence supported a guilty verdict for the Defendant on Count Three, conspiracy to transport minors for illegal sexual activity. The document summarizes testimony from victims 'Jane' and 'Annie,' who described being groomed and taken on trips to New York and New Mexico by the Defendant and co-conspirator Epstein. The court found this and other evidence sufficient to prove the Defendant's guilt beyond a reasonable doubt.
This legal document is a court's conclusion that sufficient evidence exists for a jury to find the Defendant guilty on counts of transporting a minor and sex trafficking. The conclusion is based on the testimony of a victim, "Jane," who stated the Defendant facilitated her travel with Jeffrey Epstein from Palm Beach to New York, assisted her in boarding flights, and was present during Epstein's sexual abuse of her when she was a minor.
This legal document is a court opinion from case 1:20-cr-00330-AJN, filed on April 29, 2022. The Court is addressing a post-trial Rule 29 motion for acquittal filed by the defendant, Maxwell. The Court denies the motion for the remaining counts (Three, Four, and Six), after noting the jury acquitted on Count Two and the Court deemed Counts One and Five multiplicitous. The document specifically begins to analyze Count Four, which involves the transportation of a minor named Jane for sexual activity in violation of New York law between 1994 and 1997.
This document is a page from a legal ruling (likely the Maxwell case, 1:20-cr-00330) discussing legal arguments regarding conspiracy counts, overt acts, and the interdependence of crimes. It analyzes whether the abuse of specific victims (Carolyn, Jane, Annie) constituted one common conspiracy or distinct conspiracies involving the Defendant and Epstein. The text references legal precedents and the timing of the Trafficking Victims Protection Act enactment in 2000.
This legal document details how the Defendant and Epstein used financial gifts and payments as a grooming tactic to gain victims' trust and facilitate sexual abuse. It cites testimony from a victim named 'Jane' about receiving money and payments for lessons, and mentions promises made to another victim, 'Annie'. The document also discusses the geographic scope of the conspiracy, noting that sexual conduct occurred not only in New York and Florida but also in New Mexico and London, involving other victims like Carolyn and Virginia Roberts.
This legal document analyzes two counts from an indictment against an unnamed Defendant. Count Three alleges a conspiracy from 1994-2004 to transport minors across state lines for sexual activity, based on testimony from victims Jane, Carolyn, and Annie Farmer. Count Five alleges a conspiracy from 2001-2004 for trafficking individuals for commercial sex acts, based on evidence related to Carolyn and Virginia Roberts. The Defendant argues, and the Court appears to agree, that Count Five is a subset of Count Three.
This Reuters news article reports on the perspectives of jurors from the Ghislaine Maxwell trial. Juror Scotty David describes how another juror, Carolyn, was influenced by a fellow juror's story of growing up in a similar socioeconomic background, leading her to believe girls in her neighborhood could have been victimized by people like Epstein and Maxwell. David also states his own conviction that Maxwell was complicit and not merely a scapegoat for Epstein.
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