December 14, 2020
Document filed in court
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This document is page 17 of a defense sentencing memorandum filed on June 15, 2022, in the case against Ghislaine Maxwell. The defense argues against the application of sentencing guideline § 4B1.5 ('Repeat and Dangerous' sex offenders), asserting that Maxwell has not committed crimes in nearly 20 years, is not attracted to minors, and acted only as a facilitator for Epstein's impulses rather than having them herself. The text contrasts her behavior with case law examples of violent repeat offenders and highlights her subsequent crime-free life involved with partners who had children.
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This document is a financial schedule filed on December 14, 2020, in the case of US v. Ghislaine Maxwell (1:20-cr-00330-AJN). It details the net worth of the client (Maxwell) and spouse (Borgerson) from 2014 through October 2020, showing a net worth fluctuating between $20 million and $26.5 million. Notable entries include significant real estate holdings and a massive $7.67 million expenditure for 'Advance Legal Retainer Fees' in October 2020.
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This document is a legal memorandum written by French attorney William Julié on March 14, 2021, filed in the US v. Maxwell case. It argues against a French Ministry of Justice assertion, stating that France could legally extradite Ghislaine Maxwell if she renounces her French citizenship, which she stated she is prepared to do to secure bail. The memo aims to counter the argument that her French nationality creates an insurmountable flight risk due to non-extradition policies.
019-04.pdf
A Certificate of Good Standing issued by the Supreme Court of Virginia for attorney John Marcus McNichols. The document certifies his admission to the bar on June 7, 2004, and his current good standing as of June 29, 2023. This document was filed as an exhibit in federal case 1:23-cv-03903-JSR (Doe v. JPMorgan Chase Bank) on June 30, 2023.
001-01.pdf
This document is an Exhibit A filed on October 17, 2019, containing an Asset Summary for Jeffrey Epstein dated June 30, 2019. It details a total asset value of $559,120,954, broken down into cash, fixed income, equities, hedge funds, and specific real estate properties including residences in New York, New Mexico, Florida, Paris, and two islands in the USVI. Footnotes clarify valuation methods, noting discrepancies between assessed tax values and potential market values or cost basis, specifically highlighting a valuation dispute regarding the New York property.
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This document is a page from a court filing (Case 1:20-cr-00330-AJN, filed Feb 24, 2022) which contains a printout of a Daily Mail Online article dated Jan 26, 2022. The page features a photograph of a male juror from the Ghislaine Maxwell trial standing in a room holding a cat, with a headline stating the juror was convinced by the evidence that Maxwell was a predator. The document bears the Bates stamp DOJ-OGR-00009178.
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This document is page 40 of a court filing (Exhibit 397-1) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on October 29, 2021. The content is an excerpt from an academic paper (page 296, likely by S. Craven et al.) analyzing the psychology of sex offenders, focusing on how they manipulate children into feeling guilt, the role of empathy in the grooming process, and the concept of 'cognitive deconstruction' which allows offenders to justify their actions. The document bears a Department of Justice discovery stamp.
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This document appears to be a cover page or title slide for an exhibit titled 'Ghislaine Maxwell Media Analysis'. It was filed on December 14, 2020, as part of the legal proceedings in Case 1:20-cr-00330-AJN and bears a DOJ bates stamp.
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This document is a court exhibit (Page 11 of 12, Document 615-2) filed on February 24, 2022, in the case United States v. Ghislaine Maxwell. It consists of a screenshot of a Daily Mail article dated January 26, 2022, featuring a photograph of a male juror sitting on a couch with a cat. The URL and title indicate the article discusses the juror's statement that the evidence convinced the panel Maxwell was a 'predator'.
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This document is a legal memorandum authored by French attorney William Julié on March 14, 2021, filed in the US case against Ghislaine Maxwell. It provides a legal opinion countering the French Ministry of Justice's stance, arguing that if Maxwell were to renounce her French citizenship (which she stated she is prepared to do), the French government would be legally entitled to extradite her to the US. The memo specifically refutes a March 9, 2021 letter from Philippe Jaeglé of the French Ministry of Justice regarding the non-extradition of nationals.
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This document is an excerpt from the Journal of Interpersonal Violence, filed as an exhibit in the US v. Ghislaine Maxwell case (1:20-cr-00330). It contains a graph and text analyzing the historical usage and evolution of the term 'grooming' in professional literature regarding child sexual abuse. The text highlights how offenders groom not just victims, but also parents and communities to maintain a 'nice guy' persona, citing experts like Ken Lanning and Ann Burgess.
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This document is Page 6 of 43 from Exhibit 397-1, filed on October 29, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains a page from an academic text (page 961) titled 'Grooming in Child Sexual Abuse' which presents a table and analysis of various academic definitions and subtypes of 'grooming.' The text cites numerous researchers (Leberg, Craven, Salter, etc.) to discuss the psychological tactics involved in grooming, such as gaining trust and preventing disclosure, noting the difficulties in defining these terms for forensic use.
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This document is page 5 of 23 from a court filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on February 4, 2021. It serves as a Table of Exhibits listing items A through I. While Exhibits A, B, D, and E refer to protective orders (specifically mentioning Giuffre) and 2019 transcripts, Exhibits C, F, G, H, and I are heavily redacted.
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This document is a court filing (Exhibit 615-2) containing a screenshot of a Daily Mail article dated January 26, 2022. The article features an interview with a juror named David who explains his reasoning for convicting Ghislaine Maxwell, stating she was a 'predator' who facilitated Epstein's abuse. The text also notes legal concerns regarding David's potential failure to disclose past experiences during jury selection, which experts suggested could lead to a mistrial.
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This document is the final page (6 of 6) of a court exhibit filed on March 11, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains the conclusion of a news article, likely from 'The Independent,' which quotes an unidentified man asserting Maxwell's knowledge of illicit activities and notes that her sentencing schedule has not yet been determined. The page includes website navigation elements and a DOJ Bates stamp.
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This document is a screenshot of a UPS tracking page, filed as Exhibit 15-2 in Case 1:20-cv-03380-AJN on September 4, 2020. It displays the tracking interface for a 'UPS Next Day Air' shipment, though the specific status is collapsed. The URL at the bottom reveals the specific tracking number 1ZF4661F0194176904.
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This document is a court filing (Document 615 in Case 1:20-cr-00330-AJN) filed on February 24, 2022. It consists of a printout of a Reuters news article dated January 5, 2022, written by Luc Cohen, titled 'Some Ghislaine Maxwell jurors initially doubted accusers, juror says.' The page bears a Department of Justice Bates stamp (DOJ-OGR-00009187).
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