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This legal document page addresses two arguments from the defendant, Maxwell. First, it refutes her claim of 'substantial prejudice' from evidence of her conduct in New Mexico, noting she received the evidence weeks before trial. Second, it introduces Maxwell's argument that her sentence was procedurally unreasonable due to a leadership enhancement, an argument the court states it will disagree with.
This legal document, page 22 of a larger filing, argues against the claim that evidence presented at trial prejudicially varied from the indictment against a defendant named Maxwell. It cites several legal precedents (including Dove, Salmonese, and Parker) to define the high standard for proving such a variance, asserting that the defendant was not misled and their rights were not violated. The document concludes that, similar to a previous argument about constructive amendment, the evidence at trial did not prove facts outside the scope of the indictment.
This document is page 20 of an appellate court ruling (Case 22-1426, filed 12/02/2024) regarding Ghislaine Maxwell. The court is affirming the District Court's denial of Maxwell's motion claiming a 'constructive amendment' or 'prejudicial variance' to her indictment, specifically regarding testimony about sexual abuse in New Mexico. The text cites legal precedents involving the Fifth Amendment's Grand Jury Clause and standards for indictment.
This document is Page 2 of an appellate court decision filed on December 2, 2024, affirming the conviction of Ghislaine Maxwell. The court rejected Maxwell's five arguments on appeal, including her claim that Jeffrey Epstein's Non-Prosecution Agreement in Florida protected her from prosecution in New York. The court affirmed the June 29, 2022, judgment of conviction for sex trafficking and conspiracy charges.
This page from a legal filing (likely a government appellate brief) argues that Ghislaine Maxwell's sentence was procedurally reasonable. It details that Maxwell transported a victim named 'Jane' to New York for sexual abuse and that abuse also occurred at Epstein's ranch in New Mexico. The document confirms Maxwell's sentence of 240 months imprisonment, which was slightly above the calculated guideline range of 188-235 months.
This page is from a legal document (likely an appellate brief or opinion) stamped September 17, 2024, discussing the case of Ghislaine Maxwell. The text argues that there was no prejudicial 'variance' between the indictment and the evidence presented at trial, asserting that Maxwell was properly convicted of conduct charged by the grand jury. It cites several Second Circuit precedents to support the standard for legal variance and prejudice.
This page is from a legal opinion (likely the Second Circuit Court of Appeals, given the citations) affirming a District Court's denial of Ghislaine Maxwell's motion. Maxwell argued that testimony regarding sexual abuse in New Mexico constituted a 'constructive amendment' or 'prejudicial variance' from the original indictment, violating the Fifth Amendment. The court reviews the denial *de novo* and rejects Maxwell's argument.
This document is a page from a legal filing that critiques the reasoning of a prior court decision, 'Annabi'. The author argues that 'Annabi' departed from the established legal doctrine that a plea agreement with a specific U.S. Attorney's Office (USAO) only binds that office, not the entire U.S. government, unless explicitly stated otherwise. The text cites numerous other cases in its footnotes to support this traditional, more limited interpretation of such agreements.
This legal document page outlines the timeline of legal actions involving Epstein and Maxwell following Epstein's 2008 Non-Prosecution Agreement (NPA). It details Epstein's 2019 indictment and death, followed by Maxwell's indictment and a subsequent superseding indictment by the SDNY in 2021. The core of the text describes Maxwell's unsuccessful motion to dismiss her indictment by leveraging the language of Epstein's NPA, a motion which the District Court denied.
This document is page 2 of a legal brief filed on November 1, 2024 (Case 22-1426). It argues that the legal precedent set in 'Annabi' should be overruled or limited because it creates unfairness in plea negotiations. The text specifically argues that a plea agreement negotiated in the Eleventh Circuit (likely referencing the Jeffrey Epstein 2008 Florida non-prosecution agreement) should bind the 'United States' globally, preventing prosecution in other districts for the same conduct.
This legal document, part of an appeal, addresses Ghislaine Maxwell's claims that her trial was unfair and her sentence unreasonable. The court rejects her argument that evidence of her conduct in New Mexico was prejudicial, noting the evidence was disclosed weeks before trial. The document also affirms that her 240-month sentence, which included a leadership enhancement, was procedurally reasonable.
This legal document, page 22 of a filing dated September 17, 2024, argues against the claim that evidence presented at trial prejudicially varied from the indictment against a defendant named Maxwell. It cites several legal precedents (including Dove, Salmonese, and Parker) to establish the high standard required to prove such a variance and resulting prejudice. The document concludes that the evidence at trial did not prove facts different from those in the indictment, thereby refuting the defendant's claim.
This document is page 20 of a legal filing (likely an appellate opinion) dated September 17, 2024. It details Ghislaine Maxwell's appeal regarding a 'constructive amendment' or 'prejudicial variance' of her indictment, specifically concerning testimony about sexual abuse in New Mexico. The court affirms the District Court's denial of Maxwell's motion.
This legal document, page 75 of a filing dated June 29, 2023, presents arguments defending the conviction of Maxwell. It counters Maxwell's claims by stating the jury's verdict was plausible and not based on speculation, and that there was no variance between the indictment and the trial proof regarding events in New Mexico. The document asserts Maxwell had 'fair and adequate notice' of the charges, citing the government's disclosure of an interview with the victim, Jane, weeks before the trial.
This legal document, part of an appeal (Case 22-1426), argues against Ghislaine Maxwell's interpretation of a jury note from her trial. The prosecution contends the jury's question about her guilt based on events in New Mexico was a valid inquiry into her intent, not a misunderstanding of the law. The document also refutes Maxwell's claim of insufficient evidence regarding her arrangement of a victim's (Jane's) return flight from New Mexico, suggesting the jury could have reasonably convicted her on that basis despite a lack of specific documentary proof.
This page from a Department of Justice appellate brief argues against Ghislaine Maxwell's appeal regarding jury instructions. The document asserts that Judge Nathan correctly handled an ambiguous jury note concerning flight evidence and 'aiding and abetting' liability. It specifically references testimony by a victim named 'Jane' regarding flights on Epstein's private plane and commercial carriers to New York for the purpose of sexual activity.
This document appears to be a page from a legal appellate brief filed on June 29, 2023, related to the case of Ghislaine Maxwell (Case 22-1426). The text argues that there was no prejudicial variance in the trial, asserting that the jury did not convict Maxwell solely based on the transport of a victim named 'Jane' to New Mexico, but rather on intentions to violate New York law. It cites various legal precedents regarding 'variance' and 'constructive amendment' in indictments.
This legal document excerpt from a court case details a judge's decision to reject a jury instruction proposed by the defendant, Maxwell. Judge Nathan ruled that Maxwell's requested instruction was incorrect, explaining that alleged sexual activity with the victim, Jane, in New Mexico could be relevant to proving intent for the charges under New York law. The judge ultimately decided to redirect the jury back to the original charge rather than adopt the defense's proposed language.
This legal document details a specific event during the jury deliberations in the trial of Maxwell. The jury sent a note to Judge Nathan questioning whether Maxwell could be found guilty on Count Four if she only aided in the victim Jane's return flight, not the initial flight to New Mexico where the criminal intent was allegedly formed. Judge Nathan found the question too complex and referred the jury back to the original instructions, prompting Maxwell to file a letter that night challenging the judge's response.
This legal document, part of Case 22-1426, details the Government's arguments during the trial of Maxwell, focusing on the legal requirement that the criminal conduct was directed at New York. The prosecution argued that transporting victims like Jane to New York and intending for abuse to occur there was sufficient for conviction, even if the abuse itself happened elsewhere. The document also mentions the District Court's jury instructions, which focused on Maxwell's intent for sexual activity to take place in New York.
This page from a 2023 appellate filing (likely by the government) argues that Ghislaine Maxwell's convictions on Counts Three and Four properly qualify as offenses involving sexual abuse of a child, citing testimony from a victim named 'Jane.' It also begins a section defending the District Court's decision regarding 'Juror 50,' who failed to disclose his own history of childhood sexual abuse during jury selection.
This document is page 43 (PDF page 56) of a government legal brief filed on June 29, 2023, in the appeal case of United States v. Maxwell (Case 22-1426). The text argues against Maxwell's claim that Counts Three and Four do not constitute offenses involving the sexual abuse of a child because no completed sex act occurred. The government argues that under 18 U.S.C. § 3283 and § 3509(k), the definition of sexual abuse is broader and includes employment, persuasion, and enticement.
This document appears to be a page from a legal filing detailing the sexual abuse of a minor named Carolyn by Jeffrey Epstein and the facilitation of that abuse by Ghislaine Maxwell and Virginia (Giuffre). It describes how Virginia introduced 14-year-old Carolyn to the pair at Epstein's Palm Beach villa in 2001 and instructed her on how to perform sexual massages. The text details specific acts of sexual violence committed by Epstein against Carolyn between the ages of 14 and 18 and notes Maxwell's role in scheduling these encounters.
This page from a 2023 court filing details the sexual abuse of two victims, 'Kate' and Annie Farmer. It describes how Ghislaine Maxwell facilitated Epstein's abuse of Kate in Palm Beach by providing a schoolgirl outfit and normalizing the encounter, and how Epstein groomed Annie Farmer at his Manhattan townhouse before she was sent to his New Mexico ranch in 1996.
This page from a legal document outlines allegations that Maxwell and Epstein conspired to groom and sexually abuse young girls at Epstein's properties in New York, Florida, and New Mexico. It details the evidence presented at trial, which included testimony from victims and employees, flight logs, and other records. The document also specifies that Maxwell and Epstein had a close, intimate relationship starting around 1991, with Maxwell serving as his girlfriend until the early 2000s.
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