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Case 1:20-cr-00330-PAE Document 701 Filed 07/12/22 Page5of10
him to handle the ‘sheer amount of data that was produced.’” Jd. at 84. He then conducted a
“comparative analysis,” and “concluded that de
Case 1:20-cr-00330-PAE Document 699 Filed 07/12/22 Page2of3
The Hon. Alison J. Nathan
March 9, 2021
Page 2
for a criminal prosecution against them.
In circumstances such as these, “it is most impor
Case 1:20-cr-00330-PAE Document 696 Filed 06/29/22 Page7of8
AO 245B (Rev. 09/19) Judgment in a Criminal Case
Sheet 5 — Criminal Monetary Penalties
EEE Judgment Page 7 oof
DEFENDANT: GHISLAINE MAXWELL
Case 1:20-cr-00330-PAE Document 696 Filed 06/29/22 Page1of8
AO 245B (Rev. 09/19) | Judgment in a Criminal Case (form modified within District on Sept. 30, 2019)
Sheet 1
UNITED STATES DISTRICT COURT
Case 1:20-cr-00330-PAE Document690 Filed 11/19/21 Page /7 of 23
jurisdiction, e.g. New Mexico] at the relevant time period, the sexual conduct she says
occurred with Mr. Epstein was not “illegal sexu
Case 1:20-cr-00330-PAE Document690 _ Filed 11/19/21 Page 2 of 23
massages progressed to involve sexual activity, and Ms. Maxwell’s role in facilitating those
massages. Based on all of the information
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 334 of 353
Juror ID: ran
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 305 of 353
/
Juror ID: [19
21a. If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial ju
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 276 of 353
Juror ID: v
21a. If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 247 of 353
Juror ID: 40
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in t
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 218 of 353
Juror ID: §0
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in t
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 189 of 353
Juror ID: 14
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in t
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 160 of 353
Juror ID: : %
rience that would prevent you from acting as
If yes, is there anything about that expe
a fair and impartial juror i
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 131 of 353
Juror ID: = ~]
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in
Case 1:20-cr-00330-PAE Document688 _ Filed 06/29/22 Page 102 of 353
Juror ID: a q
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in
Case 1:20-cr-00330-PAE Document688 Filed 06/29/22 Page 73 of 353
Juror ID: Z 6
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this
Case 1:20-cr-00330-PAE Document688 Filed 06/29/22 Page 44 of 353
Juror ID: |
If yes, is there anything about that experience that would prevent you from acting as
o Yes o No
Have you, or has any r
Case 1:20-cr-00330-PAE Document 688 _ Filed 06/29/22 Page 15 of 353
Juror ID: Q
21a. If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror i
Case 1:20-cr-00330-PAE Document 682 Filed 06/24/22 Page2of4
The Defendant contests whether the remaining four individuals—Maria Farmer, Sarah
Ransome, Teresa Helm, and Juliette Bryant—are “crime vict
Case 1:20-cr-00330-PAE Document 681-1 Filed 06/26/22 Page4of7
Under the CVRA’s plain language, “a party may qualify as a victim, even though [she] may
not have been the target of the crime, as long a
Case 1:20-cr-00330-PAE Document 681-1 Filed 06/26/22 Page1of7
UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Plaintiff
Vv. Case No. 1:20-cr-330
GHISLAI
Case 1:20-cr-00330-PAE Document 675-1 Filed 06/25/22 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
—v— Case No. 20—CR-330 (AJN)
GHISLAINE MAXWELL,
Case 1:20-cr-00330-PAE Document675 _ Filed 06/25/22 Page5of21
a deferred prosecution agreement)) “Congress crafted the CVRA to recognize the harm and
anguish suffered by victims of crime. This is why
Case 1:20-cr-00330-PAE Document675 Filed 06/25/22 Page4of21
CVRA, Congress used “an intentionally broad definition because all victims of crime deserve to have
their rights protected.” 150 Cong. Rec.
Case 1:20-cr-00330-PAE Document675 Filed 06/25/22 Page1of21
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
vo ceeeenentenennnennnnennnnnnnnennnnnnnnennnentenennnnnnnnnnenennenne )
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UNIT
Case 1:20-cr-00330-PAE Document672 Filed 06/24/22 Page1of68
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fax b
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 24 of55
affirmative steps to withdraw.” Meneilly, 28 F. App’x at 32 (citations omitted). The defendant
has not claimed, as a legal matter, tha
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 23 of 55
employees was unnecessary. The book is authentic, and the defendant offers no basis for
concluding otherwise.”
The Court should reje
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 21 of55
to resolve, and not the jury. Fusco, 560 F. App’x at 45-46 (citing United States v. Norris, 281 F.3d
357, 369 (2d Cir. 2002)).
Lackin
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 20 of55
1. The Court, and not the Jury, Determines Which Manual to Apply
The defendant claims that a jury must determine which version of the
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page17 of 55
involvement in the offense is immense,” and that she was essential to “fostering a culture for the
abuse to continue.” (/d.). Moreover
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page19of55
current version of the Guidelines as representing the most recent views of the agency charged by
Congress with developing sentencing pol
Case 1:20-cr-00330-PAE Document 667 Filed 06/21/22 Page2of2
dies before the final judgment is issued, the Indictment must be dismissed under the rule of
abatement. See United States v. Wright 160 F.3
Case 1:20-cr-00330-PAE Document 666 Filed 06/21/22 Page1of2
MARSH
law firm pllc
31 Hudson Yards, Fl. 11
New York, New York 10001
620-290-9084 e robertlewis@marsh. law
June 14, 2022
Via email — nat
Case 1:20-cr-00330-PAE Document663_ Filed 06/15/22 Page 21 of 77
who have been found guilty of dissimilar conduct.”) (citing Gall v. United States, 552 U.S. 38, 55
(2007)).
In addition, a non-guidel
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page5of77
conspirators or accomplices of Epstein in connection with his controversial Florida plea deal, and
although three of those same women were
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page4of77
prosecution and to an investigation by the Justice Department's (“DOJ”) Office of Professional
Responsibility.
At the urging of civil att
Case 1:20-cr-00330-PAE Document 663 _ Filed 06/15/22 Page3of77
threats continue while she is incarcerated.' It would be a travesty of justice for her to face a
sentence that would have been appropria
Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 12 of 29
Furthermore, it would be improper for the Court to rely on Carolyn’s recollection and the
message slips to find that the offense condu
Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 8of29
In each of these cases, the ex post facto violation resulted from an increase in the
applicable statutory penalty, as opposed to the appl
Case 1:20-cr-00330-PAE Document657 _ Filed 04/29/22 Page 45 of 45
captured the core of criminality charged in the Indictment, and the Defendant was not prejudiced
by any alleged variance. Further, be
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 41of 45
not entitled to the inference that all absent evidence would have been both favorable and material
to her case. United States v. Berry,
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 42 of 45
defense witnesses died three years or more prior to indictment); United States v. King, 560 F.2d
122, 130 (2d Cir. 1977) (defense witn
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 37 of 45
request a continuance or object to Jane’s testimony until the charging conference suggests that
she was not unfairly surprised. See Ka
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 38 of 45
that the Government intentionally delayed bringing charges for an improper purpose and that the
delay seriously damaged [her] ability
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 34 of 45
ran the risk of moving the jury away from consideration of the core of criminality alleged in the
Indictment.®
The appropriate approa
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 33 of 45
convictions on Counts Two and Four, erroneously implying that such evidence was irrelevant.
Dkt. No. 566 at 7 (emphasis added). Thus,
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 28 of 45
part of the same “set of discrete facts consistent with the charge in the indictment,” not a
previously unidentified and independent t
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 24 of 45
justice so requires.” Fed. R. Civ. P. 33(a). Such a motion is granted “sparingly and in the most
extraordinary circumstances, and only
Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page 23 of 45
Banki, 685 F.3d 99, 118 (2d Cir. 2012) (quoting United States v. Rigas, 490 F.3d 208, 228 (2d
Cir. 2007)). Thus, the defendant must sh