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This document is page xii of a legal filing (Document 79, Case 22-1426) dated June 29, 2023. It serves as a 'Table of Authorities,' listing various legal citations used in the main brief, including United States Code sections, New York Penal Law, Public Laws, Federal Rules of Evidence, and legal treatises, along with the page numbers where they appear.
This document is a page from a court transcript containing victim testimony. The speaker describes severe trauma, death threats, and stalking by Jeffrey Epstein and Ghislaine Maxwell occurring in New York and Florida. The victim details moving to Philadelphia in 1997 to escape, only to be found again, leading to a nervous breakdown and over two dozen hospitalizations.
This document is a page from a court transcript (dated June 29, 2023) containing the testimony of a victim. The witness describes working as a salesperson at Henri Bendel while attending FIT and meeting Ghislaine Maxwell. Maxwell mentioned her boss, Jeffrey Epstein, was close friends with Lex Wexner (owner of The Limited/Henri Bendel). The witness recounts delivering purchases to a hotel where they were introduced to Epstein and sexually assaulted by both Maxwell and Epstein. The testimony also notes the professional and academic fallout, including a job offer at Henri Bendel that would have required the witness to drop out of college.
This document is a page from a court transcript dated June 29, 2023, from the sentencing of Ghislaine Maxwell. It contains the end of a victim impact statement from Ms. Ransome, who directly addresses Maxwell, and the beginning of another statement from Ms. Stein. Ms. Stein recounts moving to New York in 1991, attending FIT, and working at Henri Bendel, where she first encountered Ghislaine Maxwell as a customer.
This document appears to be a page from a victim impact statement or court transcript (Case 22-1426) filed on 06/29/2023. An unnamed survivor describes the long-term psychological effects of their abuse, including isolation, alcoholism, and two suicide attempts. The speaker discusses attending Ghislaine Maxwell's trial in New York, finding solidarity with other testifying victims, and condemns Maxwell as a 'five-star general' of a massive sex-trafficking conspiracy.
A court transcript page detailing the testimony of a victim who was recruited by a woman named Malyshev with promises of attending FIT. The witness describes 7-8 months of sexual abuse by Epstein and Maxwell in New York and the Virgin Islands, including a suicide/escape attempt. The testimony details the grooming methods used, including leveraging the victim's visa status and family history.
This document is a page from a court transcript (likely the sentencing of Ghislaine Maxwell) featuring victim impact statements. It includes the conclusion of one statement promising vigilance against the perpetrator, followed by Ms. Ransome beginning her statement describing how she was recruited by a woman named Natalya after moving to New York to attend FIT. The text also acknowledges written submissions from other victims including Maria Farmer and Ms. Helm.
This legal document argues that a news article alleging juror misconduct is insufficient to warrant an evidentiary hearing. It cites numerous legal precedents from various courts, including the Second Circuit, which have consistently held that unsworn, hearsay, anonymous, or speculative reports do not meet the high evidentiary standard required to investigate such claims.
This document is the conclusion of a Department of Justice Office of Professional Responsibility (OPR) report concerning the handling of the Jeffrey Epstein case. Prompted by a 2018 Miami Herald article, the OPR investigated the 2007 non-prosecution agreement (NPA) orchestrated by the U.S. Attorney's Office for the Southern District of Florida. The report identifies five former federal prosecutors, including former U.S. Attorney R. Alexander Acosta, as subjects of the investigation for their roles in negotiating and executing the controversial deal.
This legal document analyzes the ambiguity of the Crime Victims' Rights Act (CVRA) concerning when victims' rights attach, particularly before formal charges are filed. It notes that at the time of the 2007 Non-Prosecution Agreement (NPA) in the Epstein case, court precedent was sparse and divided, a situation that continued as of the writing of this report. Because the law was not clear, the Office of Professional Responsibility (OPR) concluded that the prosecutors' failure to consult with victims before signing the NPA did not constitute professional misconduct.
This legal document details the aftermath of the Jeffrey Epstein case concerning victims' rights under the Crime Victims' Rights Act (CVRA). Following Epstein's death, a district court denied the victims' (petitioners') motion for remedies, such as rescinding the non-prosecution agreement, deeming the issue moot. The document also covers an appeal by a victim named Wild and the government's legal arguments that its CVRA obligations were not triggered because charges were never filed in the original district.
This DOJ OPR report excerpt details the breakdown of plea negotiations in early January 2008. Epstein's defense team (Sanchez, Starr, Lefkowitz) pressed US Attorney Acosta and Sloman for a 'watered-down resolution' that involved no jail time and no sex offender registration, threatening 'ugliness in DC' regarding alleged leaks. Prosecutor Villafaña prepared contingency plans to restart the investigation, including interviewing victims in New York and abroad, while Criminal Division Chief Robert Senior conducted a full review of the evidence.
This document details the tense negotiations in October 2007 between the U.S. Attorney's Office (Acosta, Sloman, Villafaña) and Epstein's defense (Lefkowitz) regarding the Non-Prosecution Agreement (NPA) addendum and the postponement of Epstein's guilty plea. The text highlights USAO suspicions that Epstein's team was delaying the plea to address a civil lawsuit filed by a victim in New York and alleges Epstein planted false press stories to discredit victims. Acosta agreed to move the plea date from October 26 to November 20, 2007, citing a desire not to dictate schedules to the State Attorney.
This legal document details communications among prosecutors Acosta, Villafaña, and Lourie in August 2007 regarding the Epstein investigation. The prosecutors debated strategy concerning defense counsel's efforts to delay litigation and prevent the government from obtaining computer evidence. Ultimately, Acosta decided to meet with the defense, postponing investigative steps and deadlines, believing it was better to keep the matter within the USAO rather than letting it escalate to the main Department of Justice.
This document contains a letter dated August 3, 2007, from Matthew Menchel of the U.S. Attorney's Office to Lilly Ann Sanchez, counsel for Mr. Epstein. The letter presents a non-negotiable two-year incarceration plea offer with an August 17 deadline. Accompanying text explains Menchel's rationale for the offer and its firm deadline to the Office of Professional Responsibility (OPR), and notes that the letter was sent on Menchel's last day at the USAO, a timing he described as a 'total coincidence'.
This document is a page from a DOJ OPR report detailing internal communications between federal prosecutors (Lourie, Menchel) regarding the initial prosecution memorandum for the Jeffrey Epstein case. It highlights the prosecutors' concerns about Epstein's high-profile defense team, the belief that state prosecutors intentionally sabotaged the case in the grand jury, and strategic discussions about selecting 'clean' victims to ensure a successful indictment. The document also notes Acosta's lack of recollection regarding reading the specific prosecution memo, citing his reliance on senior staff.
This legal document details the aggressive tactics used by Jeffrey Epstein's legal team, including a threat by attorney Alan Dershowitz to 'destroy' witnesses. It also explains the Florida State Attorney's Office's decision to present the case to a grand jury, citing a conflict of interest involving prosecutor Krischer's husband and Epstein's lawyer, Jack Goldberger, as well as the complexities of the case and the victim-witnesses.
This legal document outlines the events following Jeffrey Epstein's death on August 10, 2019, including the dismissal of his federal indictment in New York and the progression of a Crime Victims' Rights Act (CVRA) lawsuit in Florida. It details a specific victim's appeal and the government's arguments. The document also describes the initiation of an investigation by the Department of Justice's Office of Professional Responsibility (OPR) into potential prosecutorial misconduct, prompted by a Miami Herald report and a formal request from Senator Ben Sasse.
This legal document argues that Maxwell's conviction on Count Four (substantive transportation) was likely improper. The argument posits that the jury convicted her based on arranging a return flight for 'Jane' from New Mexico after the alleged sexual abuse had already occurred, and the Court's refusal to provide a clarifying instruction allowed this. This potential error also casts doubt on the validity of the conviction for a related conspiracy charge, Count Three.
This legal document argues that there is a substantial likelihood that the defendant, Maxwell, was convicted on Counts Three and Four based on conduct that was not charged in the indictment, specifically conduct in New Mexico. The filing contends that the jury was not properly instructed that the charged offense required travel from Florida to New York, potentially leading to an improper conviction based on uncharged acts. This would constitute a constructive amendment of the indictment.
This legal document, dated February 28, 2023, is a page from a court filing discussing a legal argument related to a criminal case. It outlines the requirements for a "constructive amendment claim," citing the precedent set in *United States v. D'Amelio*. The context is an appeal or motion by a defendant named Maxwell, who was charged under Count Four with transporting a person named Jane across state lines for sexual activity in violation of New York Penal Law.
This legal document, dated February 28, 2023, discusses the conviction of Maxwell on Count Four, which was based on Jane's testimony about sexual activity with Epstein in New Mexico. It argues that the Court's failure to address the jury's misunderstanding, as revealed by a 'Jury Note' concerning the transportation count, warrants vacating Maxwell's convictions on Counts Three and Four and granting a new trial. The document highlights the distinction between the original indictment and the basis for conviction, implicitly linking the 'defendant' in the jury note to Maxwell.
This document is page 73 of a legal appellate brief filed on February 28, 2023, related to the Ghislaine Maxwell case (Case 22-1426). The text argues that the trial court erred regarding 'Juror 50,' claiming the juror had a bias regarding sexual abuse memories that should have disqualified them. It also argues 'Point IV,' stating the court constructively amended the indictment by allowing the jury to convict Maxwell on Count Four based on activity in New Mexico (testified to by 'Jane') that was not a violation of New York law.
This page is from a legal brief (Case 20-3061, Document 82) filed on October 2, 2020. The text argues against Ghislaine Maxwell's attempt to use a writ of mandamus to modify a Protective Order, citing that such writs are 'extraordinary remedies' reserved for exceptional circumstances like judicial abuse of power. It references legal precedents (Cheney, Glotzer) to support the argument that pretrial discovery orders are generally not reviewable on direct appeal.
This document, dated September 28, 2020, is a legal argument asserting that a writ of mandamus is necessary to address inconsistent decisions by judges in the Southern District of New York concerning Ms. Maxwell's motion to consolidate. It concludes by recommending that the Court deny the government's motion to dismiss the appeal, emphasizing that deposition material will become moot once unsealed.
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