D. Conn.

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District of Connecticut (D. Conn.)

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DOJ-OGR-00001748.jpg

This document is page 2 of a court order filed on September 2, 2020, in case 1:20-cr-00330-AJN. The court denies the defendant's request to modify a protective order that was previously entered on July 30, 2020. The court's decision is based on the original agreement between the parties, which stipulated that discovery materials provided by the government would be used solely for the defense of the current criminal case and not for any civil proceedings.

Legal document
2025-11-20

DOJ-OGR-00001687.jpg

This legal document, page 3 of a filing to Judge Alison J. Nathan dated July 29, 2020, presents the defense's argument against a government-proposed protective order in the case against Ms. Maxwell. The defense contends the order would impede their ability to investigate alleged victims and witnesses, citing legal precedents where individuals waived their privacy rights by making information public. The document asserts the need for a full investigation to challenge the credibility of accusers and mount an effective defense for their client, who is presumed innocent.

Legal document
2025-11-20

DOJ-OGR-00001665.jpg

This legal document, filed on July 28, 2020, is the government's argument against a defendant's request to publicly name victims of herself or Epstein. The government contends that such disclosure is inappropriate and violates victims' rights to privacy and safety, citing the Crime Victims' Rights Act and several legal precedents. The filing supports a proposed protective order that would prevent public identification of victims while still allowing the defense to prepare for trial.

Legal document
2025-11-20

DOJ-OGR-00001221.jpg

This legal document is a page from a court filing that discusses the enforceability of an anticipatory waiver of extradition, likely in the context of Ghislaine Maxwell's case. The author argues that the defendant has not provided cases where such waivers are enforceable and cites several past court decisions (e.g., Epstein, Morrison, Stroh) where courts have deemed such waivers unenforceable, invalid until a formal request is made, or an 'empty gesture'. The document contrasts these with cases cited by the defense (e.g., Cirillo, Salvagno) where waivers were considered but were not the central factor in the court's reasoning.

Legal document
2025-11-20

DOJ-OGR-00001145.jpg

This document is a 'Table of Authorities' from a legal filing dated June 25, 2018, associated with case number 201cr7-00330-AJN. It lists numerous U.S. federal court cases cited as legal precedent, with decisions spanning from 1985 to 2019. The vast majority of the cases listed are criminal proceedings with the United States as the plaintiff against various individual defendants.

Legal document
2025-11-20

DOJ-OGR-00021091.jpg

This page from a legal filing (dated Feb 28, 2023) argues against allowing the Government to bypass the terms of a Non-Prosecution Agreement (NPA) by moving jurisdictions ('parachuting into a new circuit'). It cites various legal precedents to argue that the court should apply the law of the circuit where the violation or agreement occurred (referencing the 11th Circuit) to protect the defendant's Fifth Amendment rights in the plea-bargaining process.

Legal filing / court brief (page 44 of 113)
2025-11-20

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This legal document, part of Case 22-1426, discusses the court's reasoning for why the sex trafficking charges against Maxwell are not time-barred. The court argues that U.S. Code ยง 3299 applies retroactively to offenses where the statute of limitations had not yet expired, citing several other district court decisions. The document also addresses Maxwell's motion to dismiss certain counts as multiplicitous, concluding that such a motion is premature at the pretrial stage.

Legal document
2025-11-20

DOJ-OGR-00002327.jpg

This legal document is an argument on behalf of defendant Ms. Maxwell, challenging the composition of the grand jury that indicted her. It cites an analysis by jury expert Jeffrey Martin from a similar case, United States v. Balde, which found significant underrepresentation of Black and Hispanic persons in the White Plains jury wheel. The argument posits that since Ms. Maxwell's grand jury was drawn from the same system, her Sixth Amendment right to a grand jury selected from a fair cross-section of the community was violated.

Legal document
2025-11-20

DOJ-OGR-00002327(1).jpg

This legal document argues that the defendant, Ms. Maxwell, was denied her Sixth Amendment right to a grand jury selected from a fair cross-section of the community. It cites a parallel case, U.S. v. Balde, and an expert analysis by Jeffrey Martin, which found significant underrepresentation of Black and Hispanic individuals in the White Plains jury wheel. Because Ms. Maxwell's grand jury was drawn from the same pool, the document contends this analysis applies to her case as well.

Legal document
2025-11-20

DOJ-OGR-00002323(1).jpg

This document is page 'ii' (labeled Page 3 of 13 in the PDF) of a legal filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It is a 'Table of Authorities' listing various legal precedents (Cases) and Statutes cited elsewhere in the filing. The citations heavily reference cases involving jury selection and fair representation (e.g., Duren v. Missouri, Taylor v. Louisiana), suggesting the main document likely involves a motion regarding jury composition or selection.

Court filing (table of authorities)
2025-11-20

DOJ-OGR-00002244.jpg

This legal document, part of a court filing, discusses the legal arguments concerning the enforceability of an anticipatory waiver of extradition in the case of Ghislaine Maxwell. The text cites various legal precedents, noting that while some defendants have offered such waivers, courts have often not ruled on their enforceability or have deemed them unenforceable, as in the Epstein case where it was called an "empty gesture." The document highlights the significant legal uncertainty surrounding whether a foreign country would enforce such a waiver, making it a contentious point in the defendant's case against extradition to the United States.

Legal document
2025-11-20

DOJ-OGR-00002244(1).jpg

This legal document, part of a court filing, discusses the enforceability of an anticipatory waiver of extradition in the case of Ghislaine Maxwell. It contrasts different legal precedents, citing cases where such waivers were considered unenforceable or an 'empty gesture' (e.g., United States v. Epstein) against others where they were conditions of release, though their enforceability was not explicitly determined. The document highlights the legal ambiguity surrounding whether a foreign country, like France, would honor such a waiver.

Legal document
2025-11-20

DOJ-OGR-00002179.jpg

This legal document argues that pre-release waivers of extradition are unenforceable and meaningless because any defendant who flees will inevitably contest the waiver's validity. The author cites numerous court cases, including United States v. Epstein, to support the claim that such waivers are merely an "empty gesture." The document also refutes the defense's counterarguments by distinguishing the specific factual circumstances of the cases they rely upon.

Legal document
2025-11-20

DOJ-OGR-00019559.jpg

This document is page 2 of a court order filed on August 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The court denies the Defendant's request to modify a protective order, reaffirming that discovery materials produced by the Government must be used solely for the defense of the criminal action and not for any civil proceedings. The text cites Federal Rule of Criminal Procedure 16(d)(1) and various legal precedents regarding 'good cause' for protective orders.

Court order / legal opinion
2025-11-20

DOJ-OGR-00019441.jpg

This legal document is a court order denying a defendant's request to modify a previously established protective order. The defendant sought permission to use discovery materials, provided by the Government for a criminal case, in a separate civil proceeding. The court references the original protective order from July 30, 2020, which both parties had agreed to and which explicitly forbade such use, and ultimately denies the defendant's request.

Legal document
2025-11-20

DOJ-OGR-00019337.jpg

This document, dated August 21, 2020, is a legal filing addressed to Honorable Alison J. Nathan, arguing against the defendant's attempts to use criminal discovery materials in civil cases. It references several legal precedents and asserts that the Government's methods of obtaining materials through grand jury subpoenas are standard practice, not nefarious, and that the materials at issue are properly sealed due to an ongoing grand jury investigation.

Legal document/court filing
2025-11-20

DOJ-OGR-00019329.jpg

This legal document is a court order denying a defendant's request to modify a protective order. The court notes that on July 30, 2020, it entered a protective order, which both the defendant and the government had agreed to, stipulating that discovery materials could only be used for the defense of the current criminal case. The defendant's subsequent request to use these materials for other purposes is denied, with the court referencing the prior agreement and legal standards.

Legal document
2025-11-20

DOJ-OGR-00019259.jpg

This document is a court order denying the Defendant's request to modify a protective order in a criminal case. The original order, entered on July 30, 2020, restricted the use of discovery materials provided by the Government solely for the defense of the current criminal action. The court's decision upholds this restriction, preventing the Defendant from using the documents for any other purpose.

Legal document
2025-11-20

DOJ-OGR-00010374.jpg

This legal document, page 8 of a filing in case 1:20-cr-00330-PAE dated April 29, 2022, analyzes the legal distinctions between two conspiracy charges, Count Three and Count Five. The author argues that despite being charged under the same statute, the counts are not multiplicitous because they have different statutory objectives, legal definitions (e.g., of a 'minor'), and required elements of intent, citing precedents like Macchia, Estrada, and Villa. The document refutes the Government's claim that a single distinguishing factor is dispositive in this analysis.

Legal document
2025-11-20

DOJ-OGR-00010269.jpg

This document is a Table of Authorities from a legal filing in case 1:20-cr-00330-PAE, filed on March 11, 2022. It lists various legal precedents (cases) and statutes that are cited in the main body of the legal document. The cited authorities primarily consist of federal cases, many from the Second Circuit Court of Appeals, and federal and New York state statutes.

Legal document
2025-11-20
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