Court Filing - Memorandum in Opposition to Government's Memorandum in Support of Detention: 21-770
Summary
Ghislaine Maxwell's legal team argues that she should be released on bail due to the risks posed by COVID-19 in detention and the government's failure to meet its burden of proving she is a flight risk. Maxwell denies the charges against her and has lived in the US since 1991, never leaving the country even after Epstein's arrest.
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Court Memorandum Opinion & Order: 37
The court adopts the Government's proposed protective order, restricting Ghislaine Maxwell's ability to publicly reference alleged victims and witnesses, while allowing her to reference individuals who have spoken on the record in this case. The court also denies Maxwell's request to restrict potential Government witnesses and their counsel from using discovery materials for purposes other than preparing for trial.
Court Filing - Letter to Judge: 490
The letter, filed by Ghislaine Maxwell's attorneys, argues that Government Exhibit 52, an address book allegedly belonging to Jeffrey Epstein, is not authentic and should not be admitted as evidence without proper authentication. The defense contends that the book was altered by Alfredo Rodriguez, a former Epstein employee, and that the government's witness cannot verify its authenticity.
Court Filing - Government's Sentencing Memorandum: 670
The government's sentencing memorandum details Ghislaine Maxwell's instrumental role in the sexual abuse of multiple young girls as part of her agreement with Jeffrey Epstein, and argues that a sentence within the guidelines range is warranted due to the seriousness of the offense and Maxwell's lack of remorse.
Government's Memorandum in Response to the Court's Orders: 796
The document is a government memorandum responding to court orders regarding the disclosure of grand jury transcripts in the cases of Jeffrey Epstein and Ghislaine Maxwell. It discusses the factors set forth in In re Craig for determining whether to disclose grand jury materials and addresses the government's position on the matter. The government is seeking to unseal certain grand jury transcripts while also requesting to file a supplemental submission to protect victims' interests.
Court Filing - Exhibit: 148-5
This document is an exhibit filed in the case against Ghislaine Maxwell, listing the defense's requests for documents related to the Non-Prosecution Agreement negotiations between the government and Jeffrey Epstein, as well as communications between government agencies and attorneys for accusing witnesses. The requests cover a range of topics, including meetings between SDNY prosecutors and attorneys for accusing witnesses in 2016 and 2018.
court filing: 20-60080-CR-MORENO
The document argues that the government's case against Ghislaine Maxwell is weakening as her detention period extends, and that the government's assessment of her flight risk has increased in tandem with the diminishing strength of their case. It highlights the defendant's challenges to the indictment, including the Non-Prosecution Agreement with Jeffrey Epstein and statute of limitations issues. The document also alleges that government prosecutors misled a federal judge to obtain evidence against Maxwell.
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