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This document details a potential mistrial claim for Ghislaine Maxwell based on revelations from juror Scotty David, who was a victim of child sex abuse and shared his experience with fellow jurors. Legal experts discuss the implications of David's disclosure and the possibility of Maxwell's convictions being quashed if proper disclosure protocols were not followed during jury selection.
This document is a court exhibit (Document 615-3, filed 02/24/22) consisting of a printout of a Daily Mail article published on January 5, 2022. The article features an exclusive interview with Scotty David, a juror in the Ghislaine Maxwell trial, who discusses the jury's deliberations, his perception of Maxwell as a 'predator' as guilty as Epstein, and how his own experience with sexual abuse helped the jury understand the nature of traumatic memory.
This legal document, filed on February 24, 2022, is part of Ms. Maxwell's defense, arguing against the reliability of her accusers' memories. It highlights similarities between the claims of accusers (Jane, Carolyn, Kate, Annie Farmer) and those of Juror No. 50, who also claims to be a victim of abuse. The document focuses on Juror No. 50's assertion that his memory can be 'replayed like a video,' directly contradicting the expert testimony of Dr. Loftus, who stated that memory is a constructive process, thereby questioning the validity of such memory claims and suggesting potential juror bias.
This document is the cover page for a Memorandum of Law filed on February 24, 2022, in the case of USA v. Ghislaine Maxwell. It was filed by attorney Todd Spodek on behalf of 'Juror 50', who is seeking to intervene in the case to release a sealed jury questionnaire and transcript.
This document is page 4 of a legal filing (Document 604) in case 1:20-cr-00330-PAE, filed on February 17, 2022. The filing party, NACDL, argues for the importance of its perspective in the case, citing legal precedents like Skilling v. United States regarding jury selection and other cases concerning the role of amicus curiae (friends of the court). The document aims to persuade the court to consider its suggestions on ensuring juror honesty and establishing a fair framework for the proceedings.
This legal document argues that the defense was hindered by the unavailability of contemporaneous phone and property records for Epstein, Ms. Maxwell, and accusers. It cites two examples: the inability to challenge Carolyn's testimony that Maxwell called her to set up appointments, and the inability to rebut accuser Jane's testimony about the timing of her sexual abuse at Epstein's New York townhouse, which she described in detail.
This legal document outlines the defense's argument that it was hindered by the unavailability of old records. Specifically, incomplete travel records from Shoppers Travel prevented them from challenging the testimony of witnesses Annie Farmer and Jane regarding their travel with Epstein. Furthermore, the lack of bank and credit card records from the 1990s and 2000s meant the defense could not contest the government's claims about a $30 million payment from Epstein to Ms. Maxwell or verify other key dates.
This legal document discusses the significance of flight records in a trial, arguing that contemporaneous passenger manifests and travel records were crucial for verifying accusers' timelines. It highlights the inadequacy of the flight logs kept by David Rodgers, which were incomplete and used generic identifiers. The document also references testimony from Cimberly Espinosa and Annie Farmer regarding travel arrangements made by Epstein, including flights for accuser 'Jane' when she was 16 and a trip for Annie Farmer to New Mexico.
This document is page 28 of a legal filing (Document 600) in the case US v. Maxwell, filed on February 11, 2022. It outlines the government's theory that Epstein and Maxwell operated a single criminal conspiracy using a specific 'playbook' to groom vulnerable minors across multiple locations (NY, Palm Beach, NM, USVI). The text cites trial transcripts regarding four specific accusers (Jane, Annie, Carolyn, Kate) and describes the targeting of children from single-mother households.
This legal document is a motion arguing for the convictions of Ms. Maxwell on Counts One, Three, and Four to be vacated. The defense contends that the jury was improperly influenced by evidence of conduct in New Mexico involving a person named 'Jane', which was not part of the original indictment. This created a 'constructive amendment' or a prejudicial 'variance' between the indictment and the proof at trial, warranting a new trial on these counts.
This legal document analyzes a jury's deliberation, focusing on how flight logs kept by Epstein's pilot, Dave Rodgers, were used to corroborate testimony from a victim named Jane. The jury appears to have found no corroborating evidence for Ms. Maxwell's involvement in Jane's trips to New York, but did find evidence in the flight logs that Maxwell was a passenger on a trip with Jane to New Mexico. This distinction led the jury to focus its evaluation on Ms. Maxwell's involvement in the conduct that occurred in New Mexico.
This legal document, part of a court filing, argues that Ms. Maxwell's conviction on Count Four was likely improper. The argument centers on a note from the jury, which suggests they based the conviction on sexual abuse that victim 'Jane' experienced in New Mexico, facilitated by Maxwell. However, the charge required the intended sexual activity to be a violation of New York Penal Law, a condition the New Mexico events did not satisfy.
This legal document argues that there is a substantial likelihood that Ms. Maxwell was improperly convicted on Mann Act counts. The defense contends the conviction may have been based on testimony about conduct in New Mexico, which does not violate New York law, thereby constituting a 'constructive amendment' of the indictment that broadened the charges beyond what was originally presented by the government.
This legal document, filed on February 11, 2022, distinguishes between a 'constructive amendment' and a 'variance' in a criminal indictment, citing several legal precedents. It argues that the central element, or 'core of criminality,' of the Mann Act charges against Epstein and Ms. Maxwell was a clear scheme to entice underage girls to travel to New York for the purpose of violating New York law.
This legal document, filed on February 11, 2022, details the defense's request for an additional jury instruction concerning Mann Act counts, arguing against conviction based solely on New Mexico conduct. The Court declined this instruction, and the jury subsequently convicted Ms. Maxwell on Count Four, with charges also in Counts One and Three. The document also cites applicable law regarding constructive amendments, defining them and explaining their impact on a defendant's Grand Jury Clause rights.
This legal document from a court case, filed on February 11, 2022, details arguments over jury instructions concerning whether an offense must be a violation of New York law, even if events occurred in New Mexico. It highlights a specific note from the deliberating jury asking for clarification on Count Four, questioning if defendant Ms. Maxwell could be convicted for aiding a victim's (Jane's) return flight if the criminal intent was tied to the initial flight to New Mexico. The court declined to provide clarifying instructions, referring the jury back to the original charge.
This legal document, filed on February 11, 2022, discusses the background facts regarding jury instructions for Mann Act counts in a criminal case against Ms. Maxwell. It establishes that a conviction required proving an intent to violate a specific New York law (Penal Law § 130.55) and includes a court transcript clarifying this point, particularly in relation to the testimony of a witness named Kate.
This legal document is a motion filed on behalf of Ms. Maxwell to vacate her convictions and grant a new trial. The argument is that the jury improperly convicted her on charges based on testimony about events in New Mexico, which was outside the scope of the original indictment premised on violations of New York law. The filing contends this constituted a 'constructive amendment' of the indictment, making the conviction invalid.
This legal document is an Omnibus Memorandum filed on February 11, 2022, by Ghislaine Maxwell in support of her post-trial motions. The defense argues that her convictions on the Mann Act counts should be vacated due to a constructive amendment from the original indictment, asserting the government failed to properly prove a violation of New York law as required. The motion also seeks alternative relief, including a new trial, judgment on only one conspiracy count, or a complete dismissal of the indictment.
This document is the Table of Contents (page 'i') for a legal filing (Document 600) in the case against Ghislaine Maxwell, filed on February 11, 2022. The filing outlines arguments to vacate Maxwell's convictions on Mann Act counts due to variances from the indictment, consolidate conspiracy counts because they are multiplicitous, and dismiss the indictment due to pre-indictment delay. It references specific evidence types including flight records, passenger manifests, and financial documents.
This legal document, dated February 9, 2022, from Winston & Strawn LLP, describes the National Association of Criminal Defense Lawyers (NACDL) and its practice of filing amicus curiae briefs. It cites legal precedents for amicus participation and requests the Court's permission to file an amicus brief regarding a motion for a new trial based on juror misconduct. The document notes that Counsel for the Defendant has consented, while Counsel for the DOJ has not yet responded to inquiries.
This document is a printout of a webpage from New York Social Diary, dated April 20, 2004. It features photographs of various individuals at a social event, most notably showing known Jeffrey Epstein associates Nadia Marcinkova, Sarah Kellen, and Teela Davies posing together in one photograph. The document was processed as part of a DOJ Public Records Request.
This document is an entry from 'David Patrick Columbia's New York Social Diary' dated April 20, 2004. The author recounts a dinner at the New York restaurant Swifty's, noting the presence of Lee Radziwill, as well as Jim Kaufman dining with Laura Codman. The entry focuses on Laura Codman's lineage, as she is a descendant of the influential 20th-century interior designer Ogden Codman, and muses on his legacy and collaboration with Edith Wharton.
This document is a page from a legal filing (likely an indictment or information) dated via fax header April 4, 2006, and released via FOIA in 2017. It details a 'Scheme and Artifice to Defraud' involving a redacted defendant working as a mortgage broker at Mortgage Express in Palm Beach Gardens. The text outlines how the defendant allegedly submitted false information to obtain mortgage financing and commissions from various banks, including Bank of America, Republic Consumer Lending Group, and Ohio Savings Bank.
This document is a defense transcript from October 11, 2005, where a witness is being questioned by detectives. The witness discusses past unemployment, lying to a person named Will, spending all their money, and being in New York on New Year's on 'his dime', referring to an unnamed individual who owns an island in the Caribbean and uses a private plane.
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