Relationship Details

A page from a legal filing (Case 20-3061) dated September 24, 2020. The text argues that the government failed to follow proper procedures to access court-protected documents from a civil case. It highlights Ms. Maxwell's unique position as the only individual involved in all six related judicial proceedings.

This legal document, filed on December 17, 2021, is a jury instruction (Instruction No. 11) from a criminal case. It directs the jury to consider each of the six counts against the defendant, Ms. Maxwell, separately and to only find her guilty if the Government has proven every element of a specific charge beyond a reasonable doubt.

This legal document, filed on December 19, 2021, contains jury instructions for a criminal trial involving Ms. Maxwell. Specifically, Instruction No. 11 directs the jury on how to handle the six-count indictment, mandating that they consider each count independently and return a separate verdict for each. It reinforces the legal standard that a guilty verdict can only be reached if the Government proves every element of a specific charge beyond a reasonable doubt.

This legal document argues for Ms. Maxwell to be released on restrictive bail. Her defense contends that the government's case lacks corroborating evidence, relies on old testimony, and that her oppressive confinement conditions at the MDC, including a COVID-19 outbreak, are unjust and impede her ability to prepare her defense. The filing also asserts she is not a flight risk, citing expert opinions on extradition from the UK and France.

This document is a page from the jury instructions (Instruction No. 40) for the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 19, 2021. It defines the legal concept of 'Venue' within the Southern District of New York and lists the specific counties included in that jurisdiction. The instruction clarifies that the Government must prove venue by a 'preponderance of the evidence' rather than 'beyond a reasonable doubt,' stating that Maxwell must be acquitted of any specific offense if venue is not established for it.

This legal document, filed on December 19, 2021, contains jury instructions for a criminal case against Ms. Maxwell. Specifically, it is Instruction No. 29, which defines the fourth element of Count Six, "Sex Trafficking of an Individual Under the Age of 18." The instruction explains the legal definition of "interstate commerce" and clarifies that the Government must prove Ms. Maxwell's conduct affected it, even minimally, but does not need to prove she intended to do so or that actual travel occurred.

This legal document from December 10, 2020, details a court's analysis of arguments from Ms. Maxwell's defense. The court dismisses the defense's claim that Maxwell is not a flight risk, finding her pre-indictment contact with the government insignificant and distinguishing her case from the legal precedent of U.S. v. Friedman. The court also suggests that Ms. Maxwell may not have fully grasped the severity of the charges against her until after she was formally indicted.

This document is a page from a legal motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell. The defense argues that the Superseding Indictment is vague, failing to identify specific accusers or dates beyond the range of 1994-1997. The filing requests that the Court dismiss Counts One through Four or force the Government to provide a Bill of Particulars, citing Federal Rule of Criminal Procedure 7(c)(1) and Constitutional precedents regarding due process.

This legal document, dated April 1, 2021, is a court's ruling regarding the defendant, Ms. Maxwell. The court concludes that Ms. Maxwell is a substantial flight risk and that the government has met its burden to show that no conditions of release would be sufficient. The court also finds her proposed bail package, secured by a foreign property worth several million dollars, to be insufficient, citing her failure to provide a full accounting of her financial situation.

This legal document, filed on February 11, 2022, discusses the background facts regarding jury instructions for Mann Act counts in a criminal case against Ms. Maxwell. It establishes that a conviction required proving an intent to violate a specific New York law (Penal Law § 130.55) and includes a court transcript clarifying this point, particularly in relation to the testimony of a witness named Kate.

This is page 6 of a legal brief filed on April 19, 2021, in Case 21-770 (United States v. Maxwell). The text argues that the lower court failed to ensure the reliability of the government's evidence during bail hearings, citing legal precedents *LaFontaine* and *Martir*. The defense contends that unlike the *Martir* case, Ms. Maxwell actively challenged the government's 'flimsy proffer' through multiple hearings, but the court accepted the government's claims 'blindly' and 'uncritically.'

This legal document is the second page of a letter dated January 8, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell requests a 30-day extension for his client, Ms. Maxwell, to file a notice of appeal against the court's December 28, 2020 order denying her bail. The letter argues the extension would promote judicial efficiency and notes that the government objects to the request.

Page 3 of a legal letter addressed to Judge Alison J. Nathan dated August 17, 2020, filed in Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell). The majority of the page is heavily redacted. The visible text under the heading 'The Material' discusses the government contacting an unnamed party prior to February 2019 and serving a subpoena to produce materials, noting that Ms. Maxwell was not served with something specific.

This document is the table of contents for a legal filing (Document 18 in Case 1:20-cr-00330-AJN), filed on July 10, 2020. The filing argues for the release of Ms. Maxwell, citing the COVID-19 pandemic and challenging the government's assertion that she is a flight risk.

This is the conclusion page of a legal filing (Case 20-3061) dated October 8, 2020, arguing on behalf of Ghislaine Maxwell. The text requests that the appellate court reverse a district court order denying Maxwell's motion to modify a protective order. It references the 'Martindell' legal standard and accuses the government of trying to shield itself from a forthcoming motion before Judge Nathan.

This document is page 6 of a legal filing (Case 1:20-cr-00330-AJN) dated February 4, 2021, filed by Ghislaine Maxwell's defense. The defense argues that despite receiving millions of pages of discovery in November 2020, there is almost no information regarding the specific allegations from the 1994-1997 indictment period. Consequently, the defense requests a 'bill of particulars,' early access to the government's witness list (Jencks Act material), and 404(b) evidence to adequately prepare for trial given the 25-year age of the case and COVID-19 delays.

This document is a court transcript of a judge's instructions to a jury in the criminal case against Ms. Maxwell. The judge outlines the procedures for deliberation, including the election of a foreperson, the method for communicating with the court via written notes, and the process for requesting testimony. Crucially, the judge explicitly instructs the jury not to consider punishment in their deliberations, focusing solely on the evidence to determine guilt beyond a reasonable doubt.

This page from a legal brief (Case 20-3061) dated October 8, 2020, argues that the appellate court has jurisdiction to review Judge Preska's decision because Judge Nathan's order is unreviewable post-judgment. The text counters the Government's arguments regarding the unsealing of confidential criminal discovery materials and references a previous motion to consolidate cases. Significant portions of the text are redacted.

This document appears to be page 10 of a legal brief filed on April 1, 2021, arguing that Ghislaine Maxwell should be granted bail. The text criticizes the District Court for relying on the Government's 'conclusory allegations' regarding the strength of the case to justify detention. The defense argues the case is old, based on anonymous hearsay that has not been confronted, and that prosecutors have refused to disclose the accusers' names or specific allegations.

This document is page 198 of a court transcript (Document 767, filed Aug 10, 2022) from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains the judge's instructions (Charge) to the jury regarding legal definitions of 'knowingly' and 'intentionally,' as well as specific instructions (No. 16 and 17) regarding Count Two: Enticement to engage in illegal sexual activity. The text defines interstate commerce and outlines the government's burden of proof regarding Maxwell's intent to cause an individual to engage in criminal sexual activity under New York law.

This document is a limiting instruction (Instruction No. 48) issued to the jury in the criminal trial of Ms. Maxwell on December 19, 2021. The instruction clarifies that evidence of 'similar acts' introduced by the Government cannot be used as direct proof of the charged crimes or as evidence of bad character or a propensity to commit crimes. The jury is only permitted to consider this evidence for the limited purpose of determining if Ms. Maxwell acted knowingly and intentionally or utilized a common scheme or plan.

Page 2 of a legal filing addressed to Judge Alison J. Nathan, dated August 17, 2020. The document discusses the handling of materials marked 'Confidential' by the government, with the defense (Maxwell) arguing that these are 'judicial documents' with a presumptive right of public access, citing Brown v. Maxwell. Large portions of the factual history and footnotes are redacted.

This legal document, part of Case 20-3061 dated September 24, 2020, presents an argument on behalf of Ms. Maxwell, countering the government's position. The author argues that the government misinterprets and improperly relies on two precedent cases, United States v. Caparros (1986) and United States v. Pappas (1996), regarding the appealability of protective orders. The document specifically analyzes the Caparros case to demonstrate why it is distinguishable from Ms. Maxwell's current situation.

This document is a legal filing, specifically an appeal, related to Case 20-3061. The appellant, Ms. Maxwell, challenges a district court order by Judge Nathan that denied her request to share information with another judge. The filing argues that the appellate court has jurisdiction to review this order under the collateral order doctrine, countering the government's contention that the order is unreviewable.

This legal document, filed on March 11, 2022, is a page from a motion arguing for a new trial for Ms. Maxwell. The argument centers on the post-trial conduct of 'Juror No. 50,' who allegedly engaged in a paid publicity tour, gave interviews for a documentary, and communicated with journalist Annie Farmer, demonstrating bias. The document criticizes the government for publicly filing a letter (Docket No. 568) to stop the juror's tour, arguing this was an improper procedure that alerted the juror to scrutiny, whereas Ms. Maxwell's counsel would have objected and preferred the matter be handled under seal.

This is page 7 of a legal argument filed by the defense in the case of United States v. Ghislaine Maxwell on October 29, 2021. The defense argues that the Government failed to comply with Rule 404(b) notice requirements regarding the admission of certain evidence and testimony from a redacted female witness. The document contends that because the Government did not specify the reasoning or purpose for this evidence, it should be precluded from the trial.

This document is page 49 of a court filing (Document 563) dated December 18, 2021, containing Jury Instruction No. 35 for the trial of Ghislaine Maxwell. It outlines the legal standards for 'Membership in the Conspiracy' (Counts One, Three, and Five), defining the terms 'knowingly' and 'willfully' and establishing the Government's burden of proof regarding Maxwell's intent and participation.

This legal document is a page from an argument brief filed on behalf of Ms. Maxwell. It contends that the government improperly failed to notify her of subpoenas by not following the precedent set in the Martindell case. The brief refutes the government's justification, which relies on grand jury secrecy under Federal Rule of Criminal Procedure 6(e), arguing that the government's actions were not excused by the rule.

This page is from a legal filing (Case 1:20-cr-00330-PAE, involving Ghislaine Maxwell) filed on October 29, 2021. The defense argues that the government is evading a court order to identify specific co-conspirator statements by instead providing massive 'document dumps.' The text cites Federal Rules of Evidence and case law (Tracy, Daly, Tellier) regarding the admissibility of hearsay and the requirements for proving a conspiracy exists.

This legal document argues that there is a substantial likelihood that Ms. Maxwell was improperly convicted on Mann Act counts. The defense contends the conviction may have been based on testimony about conduct in New Mexico, which does not violate New York law, thereby constituting a 'constructive amendment' of the indictment that broadened the charges beyond what was originally presented by the government.

This legal document argues that the court should reconsider Ms. Maxwell's bail application based on new evidence. It cites legal precedents affirming the court's authority to reconsider such decisions and states that Ms. Maxwell has received over 2.7 million pages of discovery from the government since her initial hearing, which allegedly raises serious questions about the strength of the government's case.

This document is a page of concluding remarks from a judge to a jury in the criminal case against Ms. Maxwell, filed on December 18, 2021. The judge instructs the jurors on their duty to deliberate based solely on the evidence and the law, to disregard sympathy, and to engage in a fair and collaborative discussion to reach a verdict. The instructions emphasize that each juror's final vote must reflect their own conscientious belief.

This document is a legal instruction (Instruction No. 48) for a jury in the trial of Ms. Maxwell, filed on December 17, 2021. It provides guidance on how to handle 'Similar Act Evidence' introduced by the Government, which pertains to conduct not formally charged in the indictment. The instruction strictly limits the use of this evidence, forbidding the jury from using it to infer that Ms. Maxwell has a bad character or a propensity to commit crimes, but allowing its consideration for determining intent, knowledge, or a common scheme.

This document is page 19 of a legal filing (Case 20-3061) dated October 8, 2020, likely an appellate brief filed by Ms. Maxwell's defense. It argues that Judge Preska (civil case) is evaluating unsealing documents without knowing critical facts obscured by a criminal protective order overseen by Judge Nathan. The defense contends that unless the order is modified to allow sharing information under seal, Maxwell's right to a fair trial by an impartial jury will be prejudiced by the release of deposition materials.

This document is a page from a legal filing (Document 616) in the case of United States v. Ghislaine Maxwell, filed on February 24, 2022. It is a legal argument rebutting the government's opposition to a new trial, specifically addressing standards of juror misconduct, prejudice, and the right to an impartial jury. The text cites various legal precedents including Tanner v. United States and United States v. Ianniello to discuss the balance between investigating juror misconduct and maintaining verdict finality.

This document is page 68 of 82 from a court filing (Document 562) dated December 17, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It contains Jury Instruction No. 49, which explicitly instructs the jury that Ms. Maxwell exercised her Constitutional right not to testify, that the burden of proof rests solely with the Government, and that no adverse inference can be drawn against her for not taking the witness stand.

This legal document is a page from a filing arguing that the district court erred in denying bail to Ms. Maxwell. The author contends that the court improperly relied on the government's weak and unsubstantiated allegations, which are based on old, anonymous hearsay. The document concludes by asserting that Ms. Maxwell should be granted bail or the case should be remanded.

This document is page 64 of a legal filing (Document 382) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. The defense argues against government motions to exclude evidence regarding Maxwell's 'charitable works' and 'family history,' suggesting these may become relevant if the government opens those topics. Section X argues strongly against the government's request to preview the defense's evidence, using the metaphor of having 'hands tied behind their back and their mouths duct-taped,' while noting that accusers are testifying under anonymity.

Page 16 of a legal filing (Document 644) in the case against Ghislaine Maxwell, filed March 11, 2022. The defense argues that Ms. Maxwell is entitled to a new trial or hearing because Juror No. 50 failed to truthfully answer voir dire questions 25 and 48, preventing the defense from challenging the juror for cause. The text disputes the government's position on the burden of proof, citing precedents such as McDonough, Langford, and United States v. Stewart.

This legal filing argues that the District Court erred by failing to hold an evidentiary hearing on the scope of a Non-Prosecution Agreement (NPA) involving Ms. Maxwell. The author contends the court ignored key evidence from the OPR and improperly applied a rule of construction, ultimately failing to resolve ambiguities in the agreement in favor of Ms. Maxwell as required by law. The document cites precedent from the Second Circuit to support the necessity of such a hearing.

This document is page 80 of a court filing (Document 565) from Case 1:20-cr-00330-PAE, filed on December 19, 2021. It contains the concluding remarks and jury instructions for the trial of Ghislaine Maxwell, specifically instructing jurors on the standard of proof (reasonable doubt), the necessity of ignoring sympathy, and the conduct expected during deliberations. The text emphasizes that the burden of proof lies with the Government.

This document is page 79 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. It captures the conclusion of the defense counsel's argument requesting strict bail conditions rather than detention, followed immediately by the Judge beginning to deliver their ruling. The Judge outlines the legal standards for detention, emphasizing the presumption of innocence and stating that detention is based on risk of flight or danger to the community.

This document is page 29 of a legal filing (Case 1:20-cr-00330-PAE) filed on March 11, 2022, arguing for a new trial or evidentiary hearing based on juror misconduct. The defense argues that a second juror (besides Juror No. 50) failed to disclose being a victim of childhood sexual abuse during voir dire, citing a New York Times article and Juror No. 50's statements as evidence. The document also argues that Ms. Maxwell is entitled to discovery regarding communications outside of deliberations, specifically referencing social media material.

This document is page 208 of a court transcript (Document 767) filed on August 10, 2022, from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains jury instructions regarding the legal definition of 'interstate commerce' in the context of sex trafficking, clarifying that actual travel is not required if the acts were economic in nature. It also introduces Instruction No. 30 regarding 'Aiding and abetting' for Counts Two, Four, and Six.

This legal document, dated October 23, 2020, is a filing on behalf of Ms. Maxwell arguing that the U.S. Government is improperly withholding critical information. The defense claims the government has not provided details about Jeffrey Epstein's 2007 Non-Prosecution Agreement or meetings held in 2016 to investigate Maxwell. The filing accuses the government of contradicting its earlier court assurances by now disclaiming responsibility for investigative files from Florida that were transferred to the New York F.B.I. office.

This document is a court transcript from a bail hearing dated April 1, 2021, in case 21-770. It outlines the legal standards for detention, citing 18 U.S.C. 3142(g), and clarifies that the government's argument for detaining the defendant, Ms. Maxwell, is based solely on her being a flight risk, not a danger to the community.

This legal document, page 8 of a filing in case 21-770, argues on behalf of defendant Ms. Maxwell. It claims that preparing for trial from custody is impossible due to pandemic restrictions and an overwhelming 2.7 million pages of discovery. The filing criticizes the Government's response and alleges that newly provided evidence is actually exculpatory Brady material that undermines the prosecution's case.

This legal document is a letter from defense counsel Jeffrey S. Pagliuca to Judge Alison J. Nathan, dated October 23, 2020, concerning Ghislaine Maxwell's case. The letter complains that the Bureau of Prisons (BOP) and the Metropolitan Detention Center (MDC) are severely hindering Ms. Maxwell's ability to prepare her defense by preventing counsel from reviewing documents with her effectively during legal visits. The defense requests the Court to order the BOP to allow them to pass legal papers to Ms. Maxwell for review and suggests a status conference to address these ongoing issues.

This legal document, filed on March 11, 2022, is part of a motion on behalf of Ms. Maxwell arguing for a new trial. The central claim is that she does not need to prove that Juror No. 50's false answers during jury selection were deliberately made. The document cites multiple legal precedents to support the argument that even an honest but mistaken answer from a juror can be grounds for a new trial, especially when it raises questions of juror bias.

This document is a page from a court transcript (filed August 10, 2022) containing jury instructions regarding the trial of Ms. Maxwell. The judge instructs the jury on how to interpret evidence of 'similar acts' introduced by the government, warning them not to use it as proof of bad character but potentially to determine intent, lack of mistake, or the existence of a common scheme or plan.

This document is page 29 of a defense filing (Document 616) in the case of United States v. Ghislaine Maxwell, filed on February 24, 2022. The text argues for a hearing and discovery regarding potential juror misconduct, specifically alleging that a second juror (in addition to Juror No. 50) failed to disclose a history of childhood sexual abuse during voir dire. The defense cites a New York Times article and statements by Juror No. 50 as evidence, while rebutting the government's objections to post-trial discovery.

This legal document is a filing by Ms. Maxwell's counsel arguing against the government's motion to limit the introduction of her statements at trial. The defense contends the motion is premature and improper because the government has not identified any specific hearsay statements it seeks to exclude. The filing asserts that the correct procedure is for the government to object to any potential hearsay testimony as it arises during the trial, allowing the Court to rule on admissibility in context.

This page is from a government legal filing (Case 1:20-cr-00330-PAE) opposing Ghislaine Maxwell's motion to dismiss. The Government argues that Maxwell's claims of prejudice due to pre-indictment delay and media publicity since 2011 are speculative and insufficient to warrant dismissal. A footnote details a discovery dispute where the defense is requesting names, birth dates of minor victims, and specific details of overt acts.

This document is a page from a court transcript filed on December 17, 2021, in the case against Ghislaine Maxwell. The discussion involves the admissibility of evidence regarding 'non-testifying alleged victims' and 'prior statements of Ms. Maxwell' (referred to as government 8). The government attorney, Ms. Moe, mentions producing a large volume of electronically-stored discovery to the defense.

This is page 4 of a legal filing from September 24, 2020, in Case 20-3061. Ms. Maxwell's legal counsel requests permission to file several documents under seal, including an unredacted opening brief, Appendix Volume 2 (which is entirely confidential), and a response to the government's opposition. The document notes that the government does not oppose this motion.

This legal filing argues that the government is mischaracterizing the record concerning Juror No. 50's responses during jury selection. The document contends that, unlike other jurors, Juror No. 50's specific claim of childhood sexual abuse was directly relevant to the case, and had he disclosed his belief that memory works 'like a video-tape' during the trial, the Court would have questioned his ability to fairly evaluate expert testimony on the topic.

This legal document is a filing on behalf of Ms. Maxwell, arguing for her innocence. It claims the government's evidence is weak and consists of old, untested hearsay, and that the prosecution is motivated by the 'Epstein Effect'—a need for a scapegoat following the public outrage over Jeffrey Epstein's death in custody. The filing asserts that this effect has biased prosecutors, the Bureau of Prisons, and the public against her.

This document is a page from a court transcript (page 79 of the proceeding, page 142 of the filing) dated April 1, 2021, related to Case 21-770 involving Ghislaine Maxwell. The defense attorney concludes arguments for release on strict bail conditions, asserting the government failed to carry its burden. The Court then begins to deliver a ruling, outlining the legal standards for detention versus bail, emphasizing the presumption of innocence, and stating that high-profile status or wealth should not influence the application of the law.

This legal document is a jury instruction, specifically "Instruction No. 48," from the trial of Ms. Maxwell, filed on December 18, 2021. It directs the jury on the proper use of "similar act evidence" introduced by the Government, stating it cannot be used to prove bad character or a propensity to commit crimes. The instruction clarifies that this evidence may only be considered for the limited purpose of determining if Ms. Maxwell acted knowingly, intentionally, or as part of a common scheme or plan.

This legal document argues for the reconsideration of Ms. Maxwell's bail application. It cites several legal precedents that allow a court to reopen bail hearings based on new evidence or changed circumstances. The primary new evidence cited is the voluminous discovery (over 2.7 million pages) produced by the government after the initial hearing, which the defense claims raises serious questions about the strength of the government's case.

This document is page 20 of 167 from a court filing (Document 563) dated December 18, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains Jury Instruction No. 11 regarding 'Multiple Counts,' instructing the jury to consider each of the six counts separately. The text shows specific edits replacing the generic term 'Defendant' with 'Ms. Maxwell' and outlines the burden of proof required by the Government.

This legal document is a filing on behalf of the defendant, Ms. Maxwell, arguing that the Court should deny the government's motion to compel her to provide pre-trial notice of certain evidence. The defense asserts there is no legal authority for this demand and that the relevant rules, specifically Federal Rule of Evidence 404(b), place the burden of providing such notice on the prosecution, not the defendant. The document aims to prevent the defendant from having to disclose her evidence strategy concerning her alleged absence when Epstein committed abuse.

This document is a page from a court transcript dated April 1, 2021, regarding United States v. Ghislaine Maxwell. The court is addressing defense arguments for release, comparing her situation to United States v. Friedman, but distinguishing it because Maxwell allegedly did not provide her whereabouts to the government despite staying in contact. The judge argues that Maxwell may not have realized the severity of the charges or the likelihood of prosecution until her actual indictment.

This document is page 2 of a legal filing dated September 23, 2020, arguing that the criminal case against Ghislaine Maxwell is directly related to the civil case involving Virginia Giuffre, specifically citing perjury allegations. It contends that the government has a strategic interest in not intervening in the civil case regarding the unsealing of an April 2016 deposition to argue that a 'Martindell' violation was harmless. The page contains significant redactions in the center.

This legal document, dated December 8, 2021, is an argument addressed to Judge Alison J. Nathan on behalf of Ms. Maxwell. The argument contends that the government cannot admit a piece of evidence, referred to as Exhibit 52, because it cannot be properly authenticated as a business record under the Federal Rules of Evidence. The filing asserts that Ms. Maxwell disclaimed all knowledge of a related document (Exhibit 13) during a deposition, and therefore the government fails to meet the legal requirements for its admission.

This legal document, part of an appeal, argues against the government's position that Ms. Maxwell must wait until after her criminal trial to challenge certain judicial decisions. The filing asserts that the current appeal is the correct and only time to review Judge Preska's unsealing order from a related civil case, as a panel in the criminal case would lack jurisdiction. It also refutes the government's claim that a post-judgment appeal would be an effective remedy for premature unsealing of materials.

This legal document page (dated April 1, 2021) argues that the government lacks any contemporaneous documentary evidence (emails, texts, police reports) to corroborate allegations against Ghislaine Maxwell regarding conduct between 1994 and 1997. The defense asserts that Maxwell is being prosecuted as a 'substitute' for Jeffrey Epstein following his 'inexplicable death' at the MCC, noting that she was not named in Epstein's original indictment.

A page from a legal filing (Case 21-58) dated April 1, 2021, arguing against the Government's position that Ms. Maxwell is a flight risk solely based on statutory maximum penalties. The defense cites Second Circuit precedents (Friedman, Sabhnani) to establish that a potential long sentence is insufficient grounds for detention without further evidence of flight risk.