The document is a court filing in the case of 'United States v. Ghislaine Maxwell', where the Government is the prosecuting party and Maxwell is the defendant.
The document lists a series of legal filings where 'The Government' and 'Ghislaine Maxwell' are opposing parties in motions related to her detention and bail.
The document outlines the legal case 'United States v. Ghislaine Maxwell', where the Government is the prosecution and Ghislaine Maxwell is the defendant.
The document is a filing in the criminal case 'United States v. Ghislaine Maxwell', where the Government is the prosecution and Maxwell is the defendant.
The document is a court filing in the case of 'United States v. Ghislaine Maxwell', where the Government is the prosecutor and Maxwell is the defendant.
The document is part of the court case 'United States v. Ghislaine Maxwell'.
This document is a filing by the Government arguing against the claims and complaints made by the defendant, Ghislaine Maxwell, portraying her as dishonest.
The document is a memorandum filed by Ghislaine Maxwell's legal team 'In Opposition to the Government's Motion for Detention'.
The case is titled 'United States v. Ghislaine Maxwell', indicating the government is prosecuting Maxwell.
The document is a filing in the criminal case 'United States v. Ghislaine Maxwell', where the Government is the prosecutor and Maxwell is the defendant.
The government is prosecuting Maxwell, who is filing a motion to suppress evidence obtained by the government.
The document lists a series of legal filings where 'The Government' opposes motions filed by 'Ghislaine Maxwell' regarding her detention and bail.
The document details the government's efforts to deny bail to Ghislaine Maxwell, who is the defendant in the case.
The document describes a legal conflict where Ms. Maxwell is the Appellant challenging the conditions of her confinement imposed and justified by the government.
The document describes a legal conflict where Ms. Maxwell is the Appellant challenging the conditions of her confinement imposed and justified by the government.
The document describes the Government's strategy to argue Maxwell is a 'liar in general' to secure a conviction.
The Government moves this Court to dismiss the appeal... and opposes Maxwell’s motion.
The document describes the Government's strategy to argue Maxwell is a 'liar in general' to secure a conviction.
Maxwell opposes the government's motion in ongoing litigation.
Document argues against the government's request for detention.
Defense motion arguing against the government's timeline for disclosing evidence.
Maxwell argues government delay prejudiced her defense; Court rules in favor of Government.
The document contrasts arguments from the 'Defendant' (Maxwell) and 'The Government'.
Court document discussing Government's indictment of Defendant.
Defense counsel arguing against Government's discovery practices.
Maxwell is moving to exclude evidence offered by the Government.
Document discusses government's trial estimates and indictments against Maxwell.
Case title: United States v. Ghislaine Maxwell
Document discusses arguments between Maxwell's defense and the Government regarding a new trial motion.
Government must prove elements against the defendant.
The government seeks to increase sentencing; the defense argues against the government's application of adjustments.
The government objected to Ms. Maxwell’s proposed questions.
Government issuing subpoenas against Maxwell; pursuing a case.
reference to 'the government’s criminal allegations against Ms. Maxwell'
Arguments regarding the government's stance on Maxwell's ability to modify protective orders.
Government opposes Maxwell's motions; Maxwell challenges Government's conduct.
Mention of criminal indictment alleging perjury
Text states the Government must prove offenses charged against Ms. Maxwell.
Maxwell hiding whereabouts from government; facing serious charges.
Defense filing motion against government procedures in criminal case.
The document argues against the government's position on bond.
Defendant filing motion to exclude Government evidence.
Maxwell arguing for suppression of evidence based on Government misconduct.
The document is a legal argument by the Government opposing Maxwell's claims regarding her Fifth Amendment rights.
Discussion of Government opposing motions and criminal trial proceedings.
Context of criminal case filing and discussion of subpoenas.
Letter discusses government's accusations against Maxwell and legal disputes over subpoenas.
Brief argues against the Government's motion to unseal Maxwell grand jury materials.
Case caption: United States v. Ghislaine Maxwell
Case 1:20-cr-00330-PAE (Maxwell criminal case)
Defending against government detention; 'The Government Has Not Carried Its Burden'.
The document argues against the government's position regarding a new trial.
Reference to 'two grand juries that indicted Ghislaine Maxwell' and the Government's motion regarding those proceedings.
Maxwell filing motions against Government charges.
Defense motion arguing against government's concerns of jury confusion and prejudice.
Maxwell argues against the Government's application of the statute of limitations.
Government disputes Maxwell's claim by citing a video.
Defense filing arguing against Government's delay in providing evidence notice.
The text defines the burden of proof resting on the Government to prove Ms. Maxwell's guilt.
Maxwell filing motions to compel against the Government.
Legal arguments presented against the government's claims regarding Maxwell's explanations.
Maxwell is challenging the strength of the government's case and seeking bail against their detention.
The Government argues against Maxwell's motion to suppress evidence in a criminal trial.
Case name 'US v. Maxwell'
Arguments presented in court filing regarding jurisdiction and subpoenas.
Document discusses the government's motion to exclude evidence favorable to Maxwell.
Government subsequently charged perjury counts.
The government objected to Ms. Maxwell’s proposed questions.
Defense arguing against government suggestions regarding protective orders.
Maxwell moves to compel the Government to produce certain documents she believes it has in its possession and has failed to produce.
Criminal case involving charges against Ghislaine Maxwell; Government has burden of proof.
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This is page 7 of a legal filing by the Law Offices of Bobbi C. Sternheim dated April 15, 2021, in the case against Ghislaine Maxwell. The defense argues for a continuance (delay) of the trial due to a second superseding indictment which doubles Maxwell's sentencing exposure, while noting that continued detention prejudices the defendant. It also mentions an upcoming bail appeal hearing at the Second Circuit scheduled for April 26th.
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This is a letter from Ghislaine Maxwell's attorney, Bobbi C. Sternheim, to Judge Alison J. Nathan, dated October 15, 2021. Sternheim complains that the government's explanation for the severely delayed delivery of Maxwell's legal mail at the Metropolitan Detention Center (MDC) is inadequate and hinders Maxwell's ability to prepare for trial. The letter argues that the MDC is capable of timely delivery, citing the extensive resources used to monitor Maxwell, and criticizes the government's refusal to facilitate special delivery for evidence.
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This document is page 16 of a legal filing (Document 148) in the case United States v. Ghislaine Maxwell, filed on February 4, 2021. It contains legal arguments by the defense requesting the immediate disclosure of 'Brady' and 'Giglio' material (exculpatory and impeachment evidence) from the government. The defense argues that Ms. Maxwell needs this information early to prepare an effective defense, citing various legal precedents (United States v. Rodriguez, Bagley, etc.) to support the claim that impeachment evidence falls under the Brady rule.
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Page 2 of a legal letter addressed to Judge Alison J. Nathan dated August 24, 2020. The document argues against the government's characterization of Ms. Maxwell's defense strategy and disputes the government's claim that their issuance of subpoenas was 'standard practice,' citing case law (Martindell) to argue that the procedure used was improper. The document contains significant redactions.
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This document is page 28 of a court order filed on April 16, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The court denies Maxwell's motion to dismiss multiplicitous counts without prejudice and addresses discovery disputes, specifically accepting the Government's representation that it has already disclosed all required Brady and Giglio material. The court orders the parties to negotiate a schedule for any remaining pretrial disclosures.
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An email dated November 19, 2021, from an Assistant United States Attorney in the Southern District of New York regarding the case 'US v. Maxwell'. The email conveys a letter motion submitted by the Government temporarily under seal. Key participant names and contact details are redacted.
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This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) addressed to Judge Alison J. Nathan on August 24, 2020. The text argues that Protective Orders may be modified as circumstances change and refutes the Government's suggestion that Ms. Maxwell waived her right to seek modification. It cites various legal precedents (Smith Kline Beecham Corp., United States v. Gurney, etc.) to support the court's power to modify orders and unseal records.
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This document is the conclusion page of a legal motion filed on January 25, 2021, in the case against Ghislaine Maxwell. The defense argues that the Court should sever the Perjury Counts (Counts 5-6) from the Mann Act Counts (Counts 1-4) pursuant to Federal Rules of Criminal Procedure 8(a) and 14. The defense contends that a joint trial would unfairly prejudice the jury against Maxwell by attacking her credibility regarding 'salacious topics,' potentially causing a conviction on the sex trafficking charges based on character attacks rather than evidence.
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This document is an introduction to a legal filing (Document 367-1) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated October 22, 2021. It outlines a request by the parties for the Court to include specific questions during the examination of prospective jurors (voir dire). The text emphasizes standard legal principles, specifically the presumption of innocence for Ms. Maxwell and the government's burden of proof beyond a reasonable doubt.
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This document is page 8 of a legal filing (Document 307) from the criminal case against Ghislaine Maxwell, filed on June 25, 2021. The text argues against Maxwell's attempt to suppress deposition transcripts from a civil case, citing legal precedents (Oshatz, Wong, Knox) to establish that even if a protective order was modified, the testimony can be used, particularly in a perjury trial where the statements themselves are the crime. The government asserts that civil deposition testimony does not violate rights against self-incrimination in this context.
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This document is an appendix from a legal filing in Case 21-770, dated April 1, 2021. It serves as a table of contents for various court documents related to Ghislaine Maxwell's case, including numerous motions and responses concerning her detention and requests for bail, filed by both her legal team and the Government. The list also references a transcript from a bail hearing and a letter from Maxwell about her conditions of confinement at the MDC.
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This document is page 9 (filed as page 14 of 23) of a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It discusses David Boies' frustration that the government initially failed to pursue perjury charges against Maxwell despite his belief they had her 'dead to rights.' The filing argues that a redacted individual (likely a judge, referred to as 'she') modified a protective order based on misrepresentations made by an Assistant U.S. Attorney. A large portion of the page is redacted.
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This document is page 11 of a court filing (Document 613) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 24, 2022. It details the legal arguments regarding the 'voir dire' process, specifically how the defense (Maxwell) and prosecution (Government) debated the wording of questions aimed at identifying potential jurors with a history of sexual assault or abuse. The text notes that the Court eventually settled on 'Question 48' to address this issue.
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This document is page 2 of a court order filed on November 9, 2020, dismissing Ghislaine Maxwell's appeal for lack of jurisdiction. Maxwell sought to appeal a lower court's denial of her request to modify a protective order and attempted to consolidate this with the 'Giuffre v. Maxwell' civil case. The court outlines legal precedents regarding the 'final judgment rule' and 'collateral order exception' to justify the dismissal.
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This page from a legal filing (Case 20-3061) argues that an order denying Ghislaine Maxwell's motion to amend a Protective Order is not subject to interlocutory appeal. The text cites various legal precedents (Nelson, Midland Asphalt, Punn) to support the argument that her rights to a fair trial can be vindicated after a final judgment or during the criminal trial itself. It addresses Maxwell's concern that unsealing documents in civil cases might prejudice her criminal trial, asserting she can raise those issues in the criminal case if they arise.
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This document is page 59 of a court filing (Document 382) in the case against Ghislaine Maxwell, filed on October 29, 2021. The defense argues against the government's motion to exclude evidence, asserting that they have the right to reference evidence in opening statements if they have a good-faith belief it is admissible. Specifically, the defense intends to introduce evidence showing that Jeffrey Epstein abused many victims without Maxwell's knowledge or participation, arguing this is relevant to refuting the conspiracy charge, while the government attempts to characterize this as inadmissible 'good acts' or 'propensity' evidence.
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This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) dated August 24, 2020, addressed to Judge Alison J. Nathan. It argues that Protective Orders can be modified as circumstances change and asserts that Ms. Maxwell did not waive her right to seek modification. The text claims the government circumvented Second Circuit processes regarding civil materials for grand jury use and cites various case laws supporting the court's power to modify protective orders.
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This document is page 11 of a legal filing (Document 616) from Case 1:20-cr-00330-PAE, filed on February 24, 2022. It is a defense argument stating that Ghislaine Maxwell is entitled to a new trial because a juror failed to disclose childhood sexual abuse during voir dire, which would have been grounds for dismissal for cause. The text refutes the government's arguments regarding 'finality' and cites case law (Parker, Martinez-Salazar, Nelson) to argue that the presence of a biased juror constitutes a structural error requiring reversal.
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This document is page 100 of a court filing (Document 563) dated December 18, 2021, containing Jury Instruction No. 11 for the trial of Ghislaine Maxwell. The instruction advises the jury that the indictment contains six separate counts which must be considered independently of one another. It further reiterates the burden of proof, stating the Government must prove each element beyond a reasonable doubt to secure a guilty verdict.
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Page 10 of a legal filing (Document 69) dated September 28, 2020, in Case 20-3061. The text argues for the validity of an interlocutory appeal under collateral order jurisdiction, countering the government's claim that issues have not been finally resolved. It discusses the government's use of subpoenas to obtain evidence for a criminal case and Maxwell's challenge to the legitimacy of those methods within the context of a civil appeal.
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This is a page from a legal filing (likely a renewed bail application) for Ghislaine Maxwell, dated February 23, 2021. The defense argues that new bond conditions secure her assets to prevent flight, cites twelve pretrial motions filed by January 25 that challenge the government's case, and claims she has been unfairly demonized by the media as a 'substitute replacement' for Jeffrey Epstein. The document asserts Maxwell's determination to face her accusers at trial.
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This is a legal filing (Page 2 of 4) dated August 4, 2025, submitted by the Government to Judges Berman and Engelmayer regarding the unsealing of documents in the Epstein and Maxwell cases. The Government addresses Court orders requiring them to identify specific grand jury exhibits and transcripts for public release, noting that trial exhibits are presumptively public. The Government requests an extension until August 8, 2025, to advise the Court on its position regarding the unsealing of grand jury exhibits.
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This document is page 14 of a court filing (Document 809) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It discusses the legal standards for unsealing grand jury materials, citing Rule 6(e) and case law emphasizing that disclosure requires 'exceptional circumstances.' The text argues that the Government's proposal to disclose testimony and exhibits from the grand juries that indicted Maxwell does not meet the required exceptions for law enforcement or national security.
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This page is from a court order (Case 1:20-cr-00330-AJN) dated April 16, 2021, addressing Ghislaine Maxwell's motion to dismiss perjury charges. The Court denied the motion, stating that the charges are legally tenable and that arguments regarding the ambiguity of questions asked during her civil deposition are matters for a jury to decide. The document cites several legal precedents (Lighte, Wolfson) regarding perjury and 'knowing falsity'.
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This document is page 20 of a legal filing (Doc 809) in the case USA v. Ghislaine Maxwell. The defense argues against unsealing grand jury materials, claiming the Government has not met the 'special circumstances' burden. The text extensively cites the precedent 'In re Biaggi,' arguing that unsealing is only justified to correct misleading public characterizations, and suggests the Government's current motion is a 'diversion' rather than true transparency.
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A letter dated October 11, 2021, from the US Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter submits a joint proposed juror questionnaire and voir dire, noting specific disagreements marked in green and purple bubbles within the enclosed documents. The letter also conveys the defense's request to file these documents under seal to avoid media coverage that could prejudice jury selection, a request to which the Government consents.
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This legal document is a letter dated June 7, 2021, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter provides an update on the confinement conditions for defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC), stating that she receives more time and resources for discovery review than any other inmate. Specifically, it details her 13-hour daily access to computers, her ability to communicate with attorneys, and her extended time outside her cell.
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This document is page 13 of a legal filing (Case 20-3061) dated October 8, 2020, concerning Ghislaine Maxwell. It argues that releasing deposition material prematurely would compromise her ability to make a 'Martindell argument' and discusses her intent to move Judge Preska to stay unsealing pending her criminal case. The text highlights a conflict where Maxwell claims she cannot fairly argue her case because Judge Preska and the appellate panel are unaware of redacted facts regarding government proceedings and subpoenas.
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This document is page 221 of a court transcript filed on August 10, 2022, from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains jury instructions (Charge) specifically explaining the legal definition of conspiracy, withdrawal from a conspiracy, and 'Instruction No. 36' regarding the 'Third Element' of Conspiracy to Violate Federal Law (Counts One, Three, and Five). The text defines the requirement of an 'overt act' beyond mere agreement.
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This legal document is a motion filed on February 4, 2021, on behalf of Ghislaine Maxwell to suppress evidence and dismiss two perjury counts. The motion argues that the government unlawfully obtained evidence from Maxwell's civil depositions in a separate defamation case (Giuffre v. Maxwell) via a grand jury subpoena, thereby violating a Protective Order that prohibited sharing that material with law enforcement.
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This document is page 2 (labeled Page 5 of 23 in header) of a legal brief filed on October 8, 2020, in Case 20-3061 involving Ghislaine Maxwell. The text argues against the government's stance on Maxwell's Fifth Amendment rights and civil protective order, specifically criticizing the government for claiming Maxwell failed to articulate why Judge Preska needs certain information (which is redacted). The document also begins a section on 'Jurisdiction,' outlining the three conditions for interlocutory review under the collateral order doctrine, citing 'Will v. Hallock'.
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This is page 65 of 69 from a court filing (Document 382) in the case of USA v. Ghislaine Maxwell, filed on October 29, 2021. The defense argues that the burden of proof lies solely with the government and criticizes the prosecution's concerns about jury confusion. Specifically, under Section XI, the defense asserts that Maxwell was the 'prevailing party' in a previous civil litigation based on the same facts, a point the government seemingly disputes.
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This is a page from a legal brief filed on September 28, 2020, in the Second Circuit Court of Appeals (Case 20-3061). The text argues that a district court's refusal to modify a protective order is immediately appealable under the 'collateral order doctrine.' The filing contends that the appeal is necessary to share 'critical new information' with Judge Preska before deposition materials in the civil case *Giuffre v. Maxwell* are unsealed, arguing that post-judgment review would be moot.
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This page from a court filing (Case 1:20-cr-00330-PAE) details the jury selection process, specifically the debate over the juror questionnaire. Ghislaine Maxwell's defense team proposed detailed questions regarding potential jurors' history with sexual abuse and assault. The government objected to these specific questions, and the Court partially sided with the prosecution, resulting in the consolidated 'Question 48' which asked broadly about personal or family history with sexual harassment, abuse, or assault.
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This legal document argues that the trial court improperly denied bail to Ghislaine Maxwell by relying on the government's proffer, which was based on an indictment. The author contends that an indictment is merely an accusation and not evidence, citing legal precedent and pattern jury instructions from the Third Circuit to support this claim. The document asserts that the court should order Maxwell's release.
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This document is a page from a legal filing dated September 24, 2020, arguing procedural impropriety regarding how the government obtained Ghislaine Maxwell's confidential civil deposition transcripts. It details that a protective order in 'Giuffre v. Maxwell' specifically excluded language allowing sharing information with law enforcement, yet the government somehow obtained these sealed transcripts to indict Maxwell for perjury. The text questions the legality of the government's acquisition of these documents.
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This letter, dated November 23, 2020, is from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. It provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC). The letter details that Maxwell was placed in quarantine after a potential COVID-19 exposure from a staff member, outlines the quarantine protocols, and confirms that she has been provided with a laptop to review discovery materials and can still make private legal calls.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated June 26, 2022, regarding the case of Ghislaine Maxwell. The prosecution states that, in response to a court order, they have confirmed with the Metropolitan Detention Center's Warden and Chief Psychologist that the defendant has full access to her legal documents and counsel. Consequently, the government argues there is no reason to postpone her sentencing.
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This document is page 14 of a legal ruling filed on December 2, 2024 (Case 22-1426), likely from the Second Circuit Court of Appeals. The court affirms the District Court's decision to deny Ghislaine Maxwell's motion to dismiss Counts Three and Four of her indictment. The court rules that the offenses involving sexual abuse of minors fall within the extended statute of limitations provided by 18 U.S.C. § 3283 and that the 2003 amendment to this statute was correctly applied retroactively.
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This document is a page from a court transcript (dated April 1, 2021) in the case against Ghislaine Maxwell. The court is addressing a defense argument for release, distinguishing Maxwell's case from 'United States v. Friedman.' The judge notes that while Maxwell stayed in contact with the government, she did not provide her whereabouts and the circumstances of her arrest suggest she may have been hiding, driven by a realization of the severity of the charges and potential sentence.
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This document is page 39 of a defense filing (Document 97) dated December 14, 2020, in the case United States v. Ghislaine Maxwell. The defense argues that the government only pursued Maxwell as an 'afterthought' following Jeffrey Epstein's death in custody, noting that subpoenas for her financial records were not issued until August 16, 2019 (six days after his death). The text contends there is a lack of documentary corroboration for the charges, characterizing the case as relying on 25-year-old witness testimony, and urges the court to grant bail.
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This document is page 3 of a legal filing by attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell at the MDC. The letter alleges HIPAA violations regarding the release of Maxwell's medical data and details an incident of physical abuse where a guard shoved Maxwell into an isolation cell. The defense requests the Court order the MDC to stop releasing health info and demands video evidence of the abuse incident, which the government disputes.
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This is page 9 of a legal filing (Document 18) dated July 10, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues that Maxwell should be released on bail because the government failed to prove she is a flight risk and because the COVID-19 pandemic poses a significant health risk to her in detention, citing the precedent of United States v. Stephens. The document also highlights that detention would hinder her ability to prepare a defense due to restrictions on attorney access.
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This document is page 4 of a legal filing (Motion in Limine) in the case of United States v. Ghislaine Maxwell, filed on October 29, 2021. The defense argues that the Government should be precluded from introducing certain evidence under Federal Rule of Evidence 404(b) because the prosecution failed to provide particularized notice and reasoning as required by the December 2020 amendments to the rule. The text outlines the specific requirements of the amended rule regarding notice in criminal cases.
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This document is page 13 of a court order filed on April 1, 2022, in the case against Ghislaine Maxwell. The text analyzes a motion regarding juror misconduct, specifically discussing the 'McDonough' test. The Court concludes that the juror's false answers during voir dire were not deliberate and that the second prong of the legal test was not satisfied. It also defines legal standards for actual, implied, and inferable bias.
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This document is page 19 of a legal filing (Document 148) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on February 4, 2021. It details the defense's motion requesting the Court to order the government to disclose Jencks Act material (witness statements, notes, emails, texts) by March 12, 2021, citing the complexity of the case and the global pandemic. The page also begins a section (VI) requesting a list of government witnesses intended for trial.
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This document is a page from a sentencing memorandum filed on June 15, 2022, in the case of Ghislaine Maxwell. The defense argues that the Court should not apply a five-point sentencing adjustment for 'Repeat and Dangerous Sex Offender Against Minors' (USSG § 4B1.5), stating that Maxwell poses no continuing danger to the public and that the relevant conduct ended nearly 20 years prior. The text also references Judge Posner regarding the standard of proof required for sentencing factors.
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This document is the conclusion page of a legal motion filed on January 25, 2021, in the case against Ghislaine Maxwell. The defense argues that the Court should sever the Perjury Counts (Counts 5-6) from the Mann Act Counts (Counts 1-4) pursuant to Federal Rules of Criminal Procedure 8(a) and 14. The defense contends that a joint trial would unfairly prejudice the jury against Maxwell by attacking her credibility regarding 'salacious topics,' potentially causing a conviction on the sex trafficking charges based on character attacks rather than evidence.
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This is a letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan dated December 9, 2021, regarding the case United States v. Ghislaine Maxwell. The Government is requesting permission to redact a letter motion concerning the admission of Government Exhibit 52 and to seal or redact Exhibits A and B to protect the privacy of minor victims, witnesses, and third parties.
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This page is from a legal filing (Document 644) dated March 11, 2022, in the case of Ghislaine Maxwell. The text argues that Maxwell does not need to prove prejudice or that an innocent person was convicted to warrant a new trial. It counters government arguments that discourage inquiries into juror misconduct, citing case law (Tanner v. United States, United States v. Ianniello) regarding the sanctity of jury deliberations and the right to an impartial jury.
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This page is part of a legal opinion (page 10 of the specific order, page 201 of the appellate appendix) regarding Ghislaine Maxwell. The Court denies Maxwell's motion to dismiss count five of the S2 indictment (sex trafficking conspiracy) and rejects her argument that the Government's delay in bringing charges violated due process. The Court rules that Maxwell failed to show actual prejudice resulting from the delay.
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This document is page 24 of a court filing (likely an order or opinion) in the case United States v. Maxwell (Case 1:20-cr-00330-PAE). The text discusses a legal analysis regarding the unsealing of grand jury materials, weighing the defendant's (Maxwell) opposition against the public interest. The Court concludes that the specific factor of 'public interest' weighs decisively against unsealing because the materials consist of summary testimony by law enforcement that is already public record due to the trial, and lacks the historical significance found in cases like the Rosenbergs or Alger Hiss.
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This page from a legal filing (dated April 1, 2021) argues for Ghislaine Maxwell's release on bond. The defense asserts she is not a flight risk because she voluntarily stayed in the U.S. to fight 'bogus charges.' To alleviate concerns about her wealth and foreign ties, the filing states she has agreed to renounce her British and French citizenships and place all her and her spouse's assets into an account monitored by a retired federal judge.
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This document is a page from a court order in the case of United States v. Ghislaine Maxwell (part of appeal record Case 22-1426). The Judge denies Maxwell's motion to compel the immediate disclosure of prior statements by 'Minor Victim-4' in which the victim allegedly did not mention Maxwell. The Court rules that the Government's deadline of October 11, 2021, for Jencks Act and Giglio material is sufficient and that the Government understands its Brady obligations regarding exculpatory evidence.
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This legal document is a letter dated November 23, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC), specifically that she was placed in quarantine after a staff member tested positive for COVID-19. The letter details that Maxwell tested negative, outlines the protocols for her quarantine including access to legal calls and discovery materials, and confirms she is being monitored by medical staff.
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This document is the introduction to a Motion in Limine filed by Ghislaine Maxwell on October 29, 2021, seeking to exclude 'Government Exhibit 52.' The defense argues the exhibit is an unauthenticated, altered compilation of hearsay with no identified author or custodian, originating from lawyers representing Epstein accusers in the 'Giuffre v. Maxwell' civil case. The text details physical irregularities in the exhibit, such as inconsistent staple marks and tab shadows, suggesting tampering or cut-and-paste compilation.
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This is page 13 of a court filing (Doc 307) from the Ghislaine Maxwell criminal trial (Case 1:20-cr-00330-PAE), filed on June 25, 2021. The text denies Maxwell's request to suppress evidence, stating she failed to prove a due process violation or justify the use of the Court's supervisory authority. The Court argues that the Government's omission of information regarding past communications with BSF (Boies Schiller Flexner) does not constitute the 'extreme misconduct' or 'willful disobedience of law' required for suppression.
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This page is from a legal filing (likely a memorandum in support of bail) arguing for the release of Ghislaine Maxwell. It asserts that the government has failed to prove she is a flight risk or that no conditions can assure her appearance, citing the Bail Reform Act and Supreme Court precedent favoring liberty. It also references the COVID-19 crisis and a footnote cites a letter regarding poor prison conditions hindering legal defense preparation.
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This document is page 6 of a legal filing (Document 307) by the Government in the criminal case against Ghislaine Maxwell, filed on June 25, 2021. The text argues that the Government did not violate Maxwell's Fifth Amendment rights by obtaining and using her deposition transcripts from a previous civil case. It cites Second Circuit precedent to establish that civil protective orders do not guarantee protection against the use of testimony in subsequent criminal prosecutions.
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This document is page 9 of a legal filing (Doc 385) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on October 29, 2021. The text argues that the Government failed to provide timely notice of 'other act evidence' under Rule 404(b) and requests that the Court view any excuse for this delay with skepticism. The defense requests additional time to investigate newly disclosed materials which the Government claims are 'direct evidence' of conspiracy, though the specific details of these materials are redacted.
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This legal document is a renewed motion for bond on behalf of appellant Ghislaine Maxwell, dated May 17, 2021. The motion argues against the harsh conditions of her confinement, specifically citing sleep deprivation caused by flashlight checks every 15 minutes for over 318 days. The document refutes the government's justifications for these measures—such as suicide risk or the high-profile nature of the case—as nonsensical and abusive.
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This document is a page from a court order (Case 1:20-cr-00330-AJN) filed on April 29, 2022, denying Ghislaine Maxwell's renewed motion regarding pre-indictment delay. The Court ruled that the Defendant failed to prove the Government intentionally delayed the indictment to gain a tactical advantage or that the delay caused actual prejudice to her defense. The text notes that trial testimony provided legitimate explanations for the timing of the indictment.
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This document is page 13 of a court filing (Document 565) dated December 19, 2021, from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains 'Instruction No. 7,' which details the legal standards for the 'Presumption of Innocence and Burden of Proof,' explicitly stating that the burden lies solely with the Government to prove guilt beyond a reasonable doubt and that Ms. Maxwell is not required to prove her innocence.
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This document is a page from a legal filing (Appendix 106) addressed to Judge Alison J. Nathan, dated August 17, 2020. While largely redacted, the visible text discusses 'The Material' and notes that the government contacted an unknown party prior to February 2019 and served a subpoena, but explicitly states that Ms. Maxwell was not served with it.
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This document is the cover page for Exhibit B of a legal filing in Case 21-770, dated April 1, 2021. It is a memorandum submitted on behalf of Ghislaine Maxwell, arguing against the U.S. Government's motion to keep her in detention pending trial.
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This document is an appendix from a legal filing in Case 21-58, dated April 1, 2021. It serves as a table of contents for various court documents, including memoranda, motions, orders, and a hearing transcript related to the detention and multiple bail requests of the defendant, Ghislaine Maxwell. The list highlights the ongoing legal proceedings between Maxwell and The Government.
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This document is Page 5 of a legal filing addressed to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense argues that the Government is failing to meet discovery obligations, specifically regarding 28 boxes of material from Florida and files from Georgia, and that the proposed timeline impairs Maxwell's ability to prepare for the July 2021 trial. The text highlights concerns about witness statements, the age of the claims (26 years), and the difficulty of securing out-of-country testimony.
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This is a letter dated April 25, 2022, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case against Ghislaine Maxwell. The Government requests that the court order the Probation Office to complete its revised Presentence Investigation Report (PSR) earlier than the currently scheduled date of June 21, 2022. The letter argues that the current schedule, which has the revised PSR due on the same day as the defendant's sentencing submission, does not allow the parties sufficient time to incorporate the report's findings into their own submissions before the June 28 sentencing.
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The U.S. Attorney for the Southern District of New York submitted a letter motion to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The motion, dated May 11, 2022, requests the exclusion of time under the Speedy Trial Act for two counts until Maxwell's scheduled sentencing on June 28, 2022. The government intends to dismiss these counts but seeks the exclusion as a precaution, noting that the defense counsel consents to the request, which was granted by the judge.
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This legal document, filed by the Government on June 22, 2022, argues against the defendant's (Ghislaine Maxwell's) complaints regarding her confinement conditions at the MDC. The prosecution asserts that her claims of abuse are unfounded, as determined by a BOP investigation, and are part of a pattern of dishonesty aimed at garnering public sympathy, citing a November 2021 Daily Mail article as a previous example of this tactic.
Entities connected to both The government and GHISLAINE MAXWELL
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