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This legal document, part of a court filing, analyzes a question posed by a jury during a trial. The core issue is whether sexual activity involving the defendant and a minor named Jane in New Mexico could be considered as evidence for a conviction on a charge related to transporting Jane to New York. The text argues that the jury's question is legally valid and references a prior statement by the Court from the trial transcript to support the relevance of the New Mexico events to the defendant's intent.
This legal document, part of a court filing, argues that a jury note submitted during Ms. Maxwell's trial was ambiguous. The defense claimed the note referred to a specific 1997 flight to New Mexico, but this document contends the jury could have been referencing other flights or asking a different question entirely. The document concludes that the defendant's interpretation is 'mere conjecture' and supports the court's decision to reject the defense's arguments on this point.
This legal document details a court's rejection of the defense's proposed jury instructions in a criminal case. The core dispute revolves around whether sexual activity with a minor named Jane in New Mexico is relevant to proving intent for a charge under New York law. The Court dismisses the defense's arguments as legally incorrect and refuses to alter its instructions to the jury based on the defense's interpretation of a jury note.
This document is page 14 of a court filing (Document 621) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It discusses a specific jury note sent during deliberations regarding 'Count Four' and whether aiding in the return flight of a victim named 'Jane' (but not the flight to New Mexico) constituted guilt if the intent was sexual activity. The text details the defense's attempt to add jury instructions to limit the scope of intent to New York, which the Court rejected.
This legal document, part of a court filing, refutes the defendant's argument that a constructive amendment occurred during trial. The prosecution argues that Jane's testimony about events in New Mexico was permissibly used to prove the defendant's intent for abuse to occur in New York. The document asserts that the jury was not erroneously convicted on a theory of guilt for crimes in New Mexico, as this was not pursued by the Government or allowed by jury instructions.
This page is from a Government legal filing (Document 621, Case 1:20-cr-00330-PAE) arguing against a post-trial motion by the defendant (Ghislaine Maxwell). The Government asserts that the jury did not improperly convict the defendant based solely on sexual abuse of a victim named 'Jane' in New Mexico, but rather followed instructions regarding violations of New York law. The text discusses jury instructions, the lack of New Mexico specific legal charges presented to the jury, and refutes the defense's claim of a constructive amendment or variance.
This document is page 10 of a legal filing (Document 621) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It discusses the Court's jury instructions regarding the Mann Act, specifically focusing on whether the defendant intended for victims (referred to as 'Jane,' 'Kate,' and 'Annie') to engage in sexual activity in New York in violation of New York Penal Law Section 130.55. The text argues that the Court properly defined the scope of the alleged crimes and limited the jury's consideration to specific state offenses.
This document is an excerpt from a legal filing, dated February 25, 2022, detailing the Government's arguments in a criminal case. It focuses on the alleged enticement and transportation of individuals, specifically 'Jane,' by Maxwell, Epstein, and the defendant across state lines to New York for abuse, emphasizing the intent behind these actions as sufficient for a Mann Act violation. The document also mentions the alleged grooming of 'Annie' by the defendant after she had visited Epstein in New York, and the intent of the defendant and Epstein to abuse 'Carolyn' and 'Annie'.
This document is page 8 of a court filing (Document 621) from February 25, 2022, related to the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE). It outlines the Government's argument regarding Mann Act convictions, detailing how the defendant aided and abetted Epstein in transporting minors (specifically 'Jane' and Virginia Roberts) to New York for illegal sexual activity. The text specifically cites a 2001 flight from Maine to Teterboro involving Epstein, the defendant, and Virginia Roberts.
This legal document is a portion of a court filing, specifically page 7 of Document 621 in case 1:20-cr-00330-PAE, filed on February 25, 2022. The prosecution argues that there was no improper variance between the S2 Indictment and the evidence presented at trial, asserting that the proof of a scheme with Epstein to transport minors to New York for criminal sexual activity directly matched the charges. The document cites legal precedents to support the argument that the defendant was not prejudiced.
Page 5 of 51 from a court filing (Document 621) in the case of United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on Feb 25, 2022. The text argues that no 'constructive amendment' of the indictment occurred regarding the charges of enticing and transporting victim 'Jane' and other minor victims to New York. The remainder of the page outlines applicable law regarding the Fifth Amendment's Grand Jury Clause, citing precedents like U.S. v. Khalupsky and U.S. v. Dove to define the legal standard for constructive amendments.
This document appears to be a page from a Curriculum Vitae or bibliography for legal scholar Stephen Gillers, filed as an exhibit in a legal case (Case 1:20-cr-00330, likely US v. Maxwell). It lists publications authored by Gillers between 1999 and 2000 in various legal and news outlets such as The New York Times and The American Lawyer, covering topics like legal ethics, impeachment, and professional responsibility. The page contains a DOJ Bates stamp at the bottom.
This document is a page from a bibliography or Curriculum Vitae for Stephen Gillers, filed as Exhibit A-5865 in the Ghislaine Maxwell case (1:20-cr-00330) on Feb 24, 2021. It lists 19 publications authored by Gillers between 1988 and 1993 in various legal journals and newspapers, covering topics such as legal ethics, prosecutorial conduct, and constitutional rights. The document appears to be part of expert witness credentials submitted to the court.
This document appears to be a page from the curriculum vitae or bibliography of Stephen Gillers, filed as an exhibit in court cases (including Case 1:20-cr-00330). It lists numbered publications (items 15 through 34) written by Gillers between January 1986 and June 1988, published in various legal and news outlets such as the New York Law Journal and The New York Times. The articles cover topics regarding legal ethics, lawyer discipline, and specific public figures like Bernhardt Goetz and Roy Cohn.
This document is a page from the Curriculum Vitae of legal scholar Stephen Gillers, filed as Exhibit A-5863 in court case 1:20-cr-00330 (United States v. Ghislaine Maxwell). It details his legal education at NYU Law School and undergraduate degree from CUNY, his date of birth (Nov 3, 1943), and provides a selected bibliography of 14 articles he authored between 1978 and 1985 for publications such as The Nation, The New York Times, and the New York Law Journal. The document bears a DOJ Bates stamp indicating it was part of a production by the Department of Justice.
This document is a page from a legal filing, specifically a curriculum vitae or list of professional activities for Stephen Gillers. It details his public service roles and activities on various legal committees, commissions, and bar associations from the late 1970s through the early 1990s. The document also lists his state and federal bar memberships, including admission to the New York bar in 1968 and the United States Supreme Court bar in 1972.
This document is a page from a professional resume or curriculum vitae for Stephen Gillers, detailing his public lectures and service activities. It lists his participation in PBS series, numerous lectures on legal ethics, and significant roles within the American Bar Association and as a consultant for the New Jersey Supreme Court. The activities span from 1989 to at least 2009, highlighting a long career in legal ethics and public service.
This document is a page from the Curriculum Vitae or publication list of Stephen Gillers, filed as Exhibit A-5856 in the Ghislaine Maxwell case (1:20-cr-00330). It lists academic legal articles authored by Gillers between 1987 and 1999, focusing on legal ethics, professionalism, and judicial independence. The text includes citations for publications in journals such as the Georgetown Journal of Legal Ethics, Yale Law Journal, and Fordham Urban Law Journal.
This legal document analyzes statements made by defense lawyers in a memorandum regarding their investigation of a juror named Conrad. The author, likely a judge, concludes that while the lawyers' phrasing could have been clearer and may have led to unintended inferences, their statements were not knowingly false or a violation of ethical rules. The analysis specifically addresses a July 15 telephone conference where a lawyer, Trzaskoma, denied prior awareness of certain facts, a statement the author finds consistent with the lawyers' overall position.
This legal filing (Case 1:09-cr-00581-WHP) defends the conduct of attorneys from Brune & Richard regarding a potential conflict with 'Juror Conrad.' The text details events in March and May 2011 where the legal team investigated whether the juror was actually a suspended Bronx lawyer of the same name. The attorneys concluded the two were different people based on discrepancies in addresses, education, and age, and therefore determined they had no ethical duty to disclose their suspicion to the court.
This document appears to be a page from a legal memorandum or expert report (filed as part of court proceedings in 2012 and re-filed in 2022) analyzing the ethical obligations of defense lawyers. It cites case law regarding the 'adversary system' and specifically questions whether lawyers from the firm Brune & Richard LLP violated ethical duties by failing to disclose information prior to a letter sent to the Court on July 21, 2011. The text discusses the balance between client confidentiality and the duty of candor to the tribunal.
This document is a page from a legal filing (originally 2012, refiled 2022) discussing attorney ethics regarding the reporting of perjury (fraud on the tribunal). It cites a precedent case involving 'Doe,' arguing that an attorney must have actual knowledge, not just strong suspicion, of perjury before a duty to disclose arises. The author of this text notes in a footnote that they served as the expert witness for 'Doe' in a Connecticut disciplinary hearing.
This legal document, page 3 of 29 from a court filing, discusses a lawyer's ethical obligations under various New York Rules of Professional Conduct. It emphasizes that a lawyer's duty to take remedial action, such as disclosing fraudulent conduct to a court, is triggered only by "actual knowledge," a subjective standard. The document cites the 1988 Second Circuit case 'Doe v. Federal Grievance Committee' to support the argument that a mere belief of wrongdoing is insufficient to compel disclosure.
This document is page 2 of a legal opinion or declaration filed in April 2012 (and re-filed in 2022) regarding the ethical conduct of lawyers from the firm Brune & Richard. The text argues that the lawyers had no obligation to disclose certain research regarding juror Catherine Conrad at specific times. It lists various documents reviewed, including briefs, letters, and hearing transcripts from 2011 and 2012, and cites New York Rules of Professional Conduct.
This legal document is a court order from the First Judicial Department regarding attorney Catherine M. Conrad. The court grants the Departmental Disciplinary Committee's motion to suspend Conrad indefinitely due to a medical disability related to her admitted alcohol dependency. The court denies Conrad's cross-motion for immediate reinstatement, stating she has not yet met the burden of proving her fitness to resume the practice of law.
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