9th Cir.
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This legal document, part of case 1:20-cr-00330, argues against the unsealing of materials related to the convicted individual, Maxwell. It outlines the victims' concerns, citing Maxwell's recent transfer to a lower-security prison, her access to a public platform through individuals like Deputy Attorney General Todd Blanche, the government's failure to consult victims, and a growing fear of clemency. The filing asserts that these developments are causing re-traumatization for the survivors and disregard their rights under the Crime Victims' Rights Act (CVRA).
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This is page 2 of a legal filing (Document 550) from United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 17, 2021. The Government argues regarding the admissibility of extrinsic evidence for impeaching a witness, specifically noting that the prior inconsistent statements come from FBI 302 reports written by agents, not the witness herself. The document cites various legal precedents to argue that if a witness admits to an inconsistency found in '3500 material' (Jencks Act material), no further extrinsic evidence is needed.
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This legal document, part of a court filing, argues for the detention of a defendant by highlighting her characteristics as a significant flight risk. The prosecution points to the defendant's extensive international ties, including being born in France, raised in the United Kingdom, and holding citizenship and passports for the US, UK, and France. Her frequent international travel, including at least fifteen flights in the last three years, and her financial means are presented as evidence supporting the argument that she could easily flee and live abroad.
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This document is page 6 of a court filing (Case 1:20-cr-00330-AJN) arguing for the detention of a female defendant (identified by context as Ghislaine Maxwell). The prosecution argues she is a significant flight risk due to her wealth, multiple citizenships (US, UK, France), and possession of three passports. It notes she has taken at least 15 international flights in the last three years to locations including the UK, Japan, and Qatar.
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This legal document argues for the continued pretrial detention (remand) of Mr. Epstein. It cites legal precedents establishing a strong presumption of detention for defendants charged with certain serious offenses, arguing this presumption is not easily overcome. The document concludes by highlighting that the U.S. Pretrial Services Department, after interviewing Mr. Epstein, issued a report on July 8, 2019, recommending to the court that he remain in custody.
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This document is page 6 of a legal filing (Case 9:08-cv-80736-KAM) entered on July 9, 2019. The government argues that the Petitioners (victims) lack standing to void Epstein's Non-Prosecution Agreement (NPA) because the government is contractually bound to it, and a favorable ruling would not redress their injury. However, the document notably admits that a federal investigation and potential prosecution of Epstein remains a 'legally viable possibility' regardless of the NPA's status.
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This document is a page from a legal filing (Document 657 in Case 1:20-cr-00330-AJN) addressing the Defendant's (Ghislaine Maxwell) claim that delay in prosecution caused prejudice to her defense. The text argues the defendant failed to prove substantial prejudice but outlines her specific claims regarding lost evidence, including flight records, financial documents, phone records, and property records. It specifically names deceased witnesses the defense claims were unavailable: architects Albert Pinto and Roger Salhi, and property manager Sally Markham.
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This document is page 39 of a court order filed on April 1, 2022, in the case United States v. Ghislaine Maxwell. The Court rejects the Defendant's motion for a new trial based on Juror 50's conduct, concluding that Juror 50 did not commit perjury, was not biased, and testified credibly at a post-trial hearing regarding his failure to disclose prior sexual abuse during the questionnaire phase. The judge rules that the 'McDonough inquiry' standard for a new trial was not met.
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This document is page 'iii' of a Table of Authorities from a legal filing dated April 24, 2020, in Case 1:19-cr-00830-AT (which corresponds to USA v. Parnas et al., though released in a DOJ OGR batch). It lists numerous legal precedents (case law citations) primarily from the Second Circuit and Southern District of New York, referencing cases such as U.S. v. Coppa, U.S. v. Ghailani, and others used to support legal arguments in the main brief.
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This document, a page from a legal filing dated June 29, 2023, outlines the statutory definitions of "sexually explicit conduct" and "sexual contact" under 18 U.S.C. § 3509. It cites the 2012 Ninth Circuit case, United States v. Carpenter, to establish that the legal definition of "sexual abuse" is broad, encompassing not only physical contact but also acts of persuasion, inducement, or coercion.
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This legal document argues that the legislative history of a statute of limitations for child sex abuse offenses demonstrates Congress's clear intent for a 2003 amendment to apply retroactively to pre-enactment conduct. It cites a conference report and the 9th Circuit case United States v. Sure Chief to support its position. The document also refutes an argument by Maxwell that the statute's language is only "forward-looking," using a hypothetical offense from the year 2000 to illustrate the amendment's intended effect.
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This document is page 11 of 93 from a legal filing (Case 22-1426), dated June 29, 2023. It is a 'Table of Authorities' listing various legal precedents (case law) cited in the main brief, including 'United States v. Salameh', 'United States v. Teman', and 'United States v. Vickers'. The footer indicates it is a Department of Justice document (DOJ-OGR-00021658).
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This legal document, part of a court filing, argues against an immediate appeal by a party named Maxwell regarding the use of criminal discovery materials. It contends that Maxwell has not met the legal standard for such a review, citing precedents like Flanagan, Martoma, and Guerrero. The document asserts that Maxwell's concerns about privacy and publicity can be adequately addressed during a standard appeal after a final judgment is rendered in her criminal case.
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This document appears to be page 5 (labeled Roman numeral iv) of a legal brief or filing related to Case 20-3061, filed on October 2, 2020. It is a Table of Authorities listing various legal precedents (case law) cited in the main document, including United States v. Caparros and United States v. Kerik. The footer indicates it is part of a Department of Justice (DOJ-OGR) release.
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Page 10 of a legal filing (Case 20-3061) dated September 16, 2020. The text contains legal arguments regarding the timing of appellate reviews, specifically citing precedents (Punn, Mohawk Indus., Hitchcock) to argue that immediate appeals are generally not granted if post-judgment relief (like a reversal after a trial) can adequately protect the defendant's rights. The document bears a DOJ Bates stamp.
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This document is a page from a legal filing, specifically Case 20-3061, dated September 16, 2020. It argues against the immediate appeal of a district court's pretrial decision, asserting that any potential harm to the defendant, Punn, can be adequately remedied through the standard appellate process after a final judgment. The text cites several legal precedents, including Mohawk Indus. and United States v. Hitchcock, to support the principle that post-conviction review is sufficient to protect a defendant's rights, even in cases involving purportedly ill-gotten evidence.
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This legal document discusses the government's arguments in a case, referencing previous cases like United States v. Torres and United States v. Daugerdas. It focuses on whether a new trial is warranted based on juror bias and concealed personal background information, arguing that the current case is stronger than in Torres.
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This legal document is a court filing arguing for the credibility of Juror 50 against a defendant's challenge. The filing contends that any inconsistencies in the juror's questionnaire answers should be assessed in a formal hearing, not based on public statements, and cites legal precedents suggesting jurors can make honest mistakes. It further argues that the juror's disclosure of having read about the defendant's connection to Epstein and the illogical nature of deliberately lying only to immediately risk exposure suggest the juror did not intentionally mislead the court.
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This legal document, page 38 of a court filing from February 24, 2022, argues that a specific juror, Juror No. 50, should be considered impliedly biased. The argument is supported by citing legal precedent from various cases (Eubanks, Daugerdas, Dyer, Sampson) which establish two main theories for implied bias: when a juror lies during the selection process (voir dire) and when a juror's personal life experiences are too similar to the issues being litigated in the case, potentially compromising their impartiality.
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Page 17 of a legal filing (Case 20-3061, dated Oct 2, 2020) produced by the DOJ. The text contains legal arguments citing various precedents (Punn, Mohawk Indus., Hitchcock) to argue that appellate review should generally wait until a final judgment is entered, rather than allowing immediate interlocutory appeals, particularly regarding pre-trial discovery or evidence rulings.
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This legal document, part of a court filing, argues that a defendant's actions satisfy the requirements for a 'covered sex crime' under the U.S. Sentencing Guidelines. The prosecution asserts that the defendant engaged in a pattern of prohibited sexual conduct, including transporting victims (Jane) and non-consensual touching (Jane and Carolyn), justifying a sentencing enhancement. The document refutes the defendant's claim that the guideline is inapplicable, citing case law and the original congressional intent to ensure lengthy incarceration for such offenders.
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This legal document is a court's conclusion regarding a defendant's motion to find a juror, Juror 50, biased. The defendant argued the juror's failure to disclose a personal history of sexual abuse during jury selection showed an inability to be impartial. The Court rejects this argument, finding that the juror's omission was due to inattention rather than a deliberate lie or perjury, and therefore denies the defendant's motion.
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This document is page 25 of a defense filing (Document 644) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated March 11, 2022. The text argues against a proposed hearing format regarding 'Juror No. 50's' alleged misconduct, citing legal precedent (*Dyer v. Calderon*) to claim that the Court cannot act as investigator, witness, and decision-maker simultaneously without violating due process. The defense questions how the Court intends to uncover Juror No. 50's motives and social media posts without independent investigation.
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This legal document argues against a defendant's claim that Juror 50 intentionally lied on a juror questionnaire about being a victim of sexual abuse in order to serve on the jury. The filing contends that Juror 50's other disclosures, such as his knowledge of the defendant's connection to Epstein, are inconsistent with an intent to deceive. It cites legal precedents to support the idea that juror questionnaires should be viewed in context and suggests the matter of credibility should be resolved in a formal court hearing.
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This legal document argues that a district court's supervisory authority to suppress evidence is limited and should only be used when there is a clear violation of constitutional, statutory, or procedural law. Citing multiple legal precedents, the author contends that this power must be 'sparingly exercised' and that the defendant in this case has not established such a violation, and is therefore not entitled to an evidentiary hearing to challenge the government's actions.
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