E.D.N.Y.
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This document is a page from a legal filing in which the prosecution (Government) argues against a motion by the defendant, Maxwell, to dismiss her indictment due to pre-indictment delay. The Government cites several legal precedents (Pierre-Louis, Burke, Carbonaro) to argue that the defendant has failed to show the delay was improper or for a tactical advantage. The document also addresses Maxwell's specific claim that the Government delayed the indictment to benefit from a separate civil litigation involving Giuffre, a claim the Government refutes.
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This legal document, filed on April 16, 2021, argues that a Non-Prosecution Agreement (NPA) signed by the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) is only binding within that specific district. The document refutes the defendant's claim that the use of terms like "United States" implies the agreement binds the entire U.S. Government, citing several legal precedents, including cases from the Second Circuit, to support the position that such agreements are geographically limited unless explicitly stated otherwise.
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This legal document, part of a court filing, argues that a Non-Prosecution Agreement (NPA) is not enforceable in the Southern District of New York. It cites numerous legal precedents from the Second Circuit to support the position that plea agreements are binding only in the district where they are made, unless explicitly stated otherwise. The document concludes that the defendant has failed to provide evidence that the USAO-SDFL's NPA with Epstein was intended to bind other districts.
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This document is page xxiv of a legal filing from Case 1:20-cr-00330-PAE, filed on April 16, 2021. It is a table of authorities, listing numerous legal case citations with corresponding page numbers where they are referenced within the larger document. The majority of the cases listed involve the United States as a party against various individuals and one corporation.
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This document is page 21 of a Table of Authorities from a legal filing (Document 204) in Case 1:20-cr-00330-PAE, which corresponds to the trial of United States v. Ghislaine Maxwell. The page lists various legal precedents (case law citations) ranging from 'United States v. Rahimi' to 'United States v. Rosa' used to support legal arguments in the main brief. The document bears the Bates stamp DOJ-OGR-00002955.
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This document is a 'Table of Authorities' from a legal filing (Case 1:20-cr-00330-PAE, Document 295), filed on May 25, 2021. It lists numerous legal cases, primarily involving the United States as a party, which are cited as legal precedent within the main document. The table provides the case names, citations, and the page numbers where they are referenced in the brief.
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This legal document argues that the photo identification of a defendant by 'Minor Victim-4' was valid and not suggestive. It establishes that the victim had prior personal knowledge of the defendant from interactions between 2001 and 2004, and that the photo identification procedure was conducted cautiously. The document refutes the defense's claim that the defendant's photo was unduly suggestive because it looked like a 'mug shot' or was different from the others.
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This legal document, filed on October 29, 2021, is a motion arguing for the admissibility of expert testimony from a Dr. Rocchio. The document refutes the defendant's claim that Dr. Rocchio's opinions are unreliable, asserting that the testimony on coercion, attachment, and grooming in abuser-victim relationships is well-supported and will help the jury understand the evidence at trial.
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This legal filing (Document 397 in Case 1:20-cr-00330-PAE) argues for the admissibility of expert testimony regarding sex trafficking, coercive control, and the psychological relationship between pimps and victims. It cites several precedents (Kelly, Torres, Randall, Dupigny) where such testimony was permitted. Specifically, it defends the qualifications of Dr. Rocchio, a Brown University professor with 25 years of clinical experience, noting that the defendant does not contest her expertise.
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This legal document is a court order signed by United States District Judge Alison J. Nathan on December 28, 2020. The order explicitly denies Defendant Ghislaine Maxwell's renewed motion for release on bail. The decision references a precedent from the 2018 case of United States v. Raniere.
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This legal document, filed on February 18, 2020, argues for the continued detention of a female defendant, asserting she is a significant flight risk due to her financial means, foreign ties, and skill at hiding. The filing dismisses proposed bail conditions, such as private security guards and GPS monitoring, as insufficient to ensure her appearance in court. To support its position, the document cites several past federal cases (Banki, Zarger, Benatar) where courts denied bail under similar circumstances, deeming electronic monitoring and home confinement inadequate for high-risk defendants.
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This legal document is a page from a government motion arguing against publicizing the full names of four minor victims in an upcoming criminal trial. The government contends that the defense has not shown a specific need for this disclosure, and that the court should prioritize the victims' privacy and dignity. The motion cites several legal precedents that support protecting witnesses' identities, especially when safety and privacy are concerns.
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This document is a page from a legal filing dated October 29, 2021, which argues for victim protections during testimony. It cites two judicial precedents: one from Judge Garaufis, who distinguished between a victim's choice to speak publicly and court testimony, and another from Judge Donnelly in the case of *United States v. Robert Kelly*, where the court allowed victims to use pseudonyms due to the sensitive nature of their testimony about sexual abuse.
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This legal document is a portion of a motion arguing to exclude evidence of an alleged rape committed by Mr. Epstein from the trial of Ms. Maxwell. The argument posits that such evidence is not part of the charged conspiracy (which is limited to securing "sexualized massages"), is highly inflammatory and unduly prejudicial, and would confuse the jury, leading to a conviction on an improper emotional basis. The document cites several legal precedents to support the exclusion of this evidence under Rule 403.
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This document is page 2 of a legal filing (Document 362) from the United States v. Ghislaine Maxwell case (1:20-cr-00330), filed on October 20, 2021. The text argues for public access to the jury selection process (voir dire) and juror questionnaires, citing numerous legal precedents including United States v. Shkreli and Press-Enterprise Co. v. Superior Court. It asserts that First Amendment rights require these proceedings and documents to be presumptively open to the press and public.
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This document is a legal letter to Judge Alison J. Nathan arguing against a subpoena issued by the Defendant (Ghislaine Maxwell) to the law firm BSF. The author argues that requests for materials related to the Epstein Victim's Compensation Program (EVCP) and communications between BSF and the U.S. Attorney are irrelevant to the charges, protected by work-product privilege, and constitute a 'fishing expedition' intended to support a false narrative of collusion. The document specifically details Requests 1, 3-5, 8, and 12.
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This document is a page from a legal filing arguing against a defendant's subpoena requests, asserting they fail to meet the Nixon standard for admissibility and relevance. The text specifically challenges requests for materials from the Epstein Victim's Compensation Program and communications between the firm BSF and the U.S. Attorney, characterizing them as fishing expeditions or irrelevant work product.
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This document is page 52 of a 2005 Brigham Young University Law Review article discussing the implementation of the Crime Victims' Rights Act (CVRA). It emphasizes the necessity for the judiciary to comprehensively protect victims' rights in federal criminal cases to avoid further congressional intervention. The document bears the name of attorney David Schoen (Epstein's lawyer) and a House Oversight Committee Bates stamp, suggesting it was part of materials submitted during a congressional investigation, likely regarding the violation of victims' rights in the Epstein case.
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This document is an excerpt from a 2005 BYU Law Review article discussing the Crime Victims' Rights Act (CVRA), specifically regarding the government's obligation to notify victims of case events. It outlines specific rights such as notification of release, plea agreements, and sentencing, and includes a rationale section quoting Senator Feinstein. The document bears the name of attorney David Schoen and a House Oversight Bates stamp, suggesting it was part of a production related to the investigation into the handling of the Epstein case, particularly the failure to notify victims under the CVRA.
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This document is a page from a legal article (104 J. Crim. L. & Criminology) submitted to the House Oversight Committee, likely by attorney David Schoen. It presents a legal argument criticizing the Office of Legal Counsel's (OLC) memorandum for interpreting the Crime Victims' Rights Act (CVRA) too narrowly, specifically arguing that victim rights should extend to the pre-charging phase. The text cites various statutes (VRRA) and case law to support the claim that victims have rights to protection and conference with the government before formal charges are filed.
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This document is a page from a legal filing authored by David Schoen (likely representing victims in the Epstein case), produced to the House Oversight Committee. It presents a legal argument contrasting the Victims' Rights and Restitution Act (VRRA) with the Crime Victims' Rights Act (CVRA), arguing that the Justice Department is obligated to recognize and inform victims as soon as an investigation opens, not just after formal charges are filed. It criticizes a 2011 Office of Legal Counsel (OLC) memorandum that attempted to limit these protections for victims of uncharged conduct.
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This document appears to be page 9 of a legal brief or research document (indicated by the Westlaw footer and Bates stamp HOUSE_OVERSIGHT_023369) listing a Table of Authorities. It cites numerous legal cases primarily related to terrorism, banking liability, and civil procedure, including 'United States v. Bin Laden' and 'Weiss v. Nat'l Westminster Bank PLC'. While titled under 'In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001', the document originates from a House Oversight Committee production, likely related to investigations into financial institutions.
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This document is a 'Table of Authorities' page from a legal filing, marked with Bates stamp HOUSE_OVERSIGHT_023368. It lists various legal precedents and case citations, primarily focusing on litigation related to the September 11, 2001 terrorist attacks, sovereign immunity, and international liability (Alien Tort Statute). While the document is part of a collection likely reviewed by the House Oversight Committee (possibly related to an investigation involving Epstein or similar legal themes of jurisdiction/immunity), this specific page contains no direct mentions of Jeffrey Epstein, Ghislaine Maxwell, or their associates.
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This document is a page from a legal academic article (Vol. 104, likely by Paul Cassell) analyzing the Crime Victims' Rights Act (CVRA) in the context of the Jeffrey Epstein case. It details that the FBI found abuse allegations against Epstein credible and presented the case to the U.S. Attorney's Office in Florida, which then negotiated a non-prosecution agreement in 2007. The text argues that victims should have been notified and allowed to confer with prosecutors once substantial evidence was developed, rather than being excluded from the plea negotiation process.
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This document is page 80 of a legal analysis (likely by Paul Cassell) included in House Oversight materials (Bates HOUSE_OVERSIGHT_014059). It critiques an Office of Legal Counsel (OLC) memorandum regarding the Crime Victims' Rights Act (CVRA), specifically arguing against the OLC's position that victim rights only apply after formal charges are filed. The text outlines specific rights that logically apply pre-charging (protection, conferencing with government attorneys, and fairness/dignity) and cites case law (US v. Rubin) and legislative history to support a broader interpretation of the Act.
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