Court Filing - Reply Memorandum: 223
Summary
Ghislaine Maxwell's reply memorandum argues that the Non-Prosecution Agreement (NPA) with Jeffrey Epstein applies to her as a co-conspirator and that the government's interpretation of the agreement is incorrect. The memorandum contends that the plain language of the NPA provides immunity to co-conspirators, including Maxwell, and that the government's attempt to add limitations not present in the text is unfounded.
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Court Filing - Reply Memorandum: 103
This reply memorandum supports Ghislaine Maxwell's renewed motion for bail, arguing that the government's case relies heavily on the testimony of three witnesses without significant contemporaneous documentary evidence. Maxwell's defense presents a substantial bail package, including a bond secured by her and her spouse's assets and additional sureties, arguing that these conditions reasonably assure her appearance in court.
Court Filing - Memorandum in Support of Motion to Dismiss: 126
The memorandum argues that the government's use of a White Plains Division grand jury to indict Ghislaine Maxwell was unconstitutional because it did not represent a fair cross-section of the community where the alleged crimes took place. The document highlights that the Manhattan Division grand jury was available but not used, and that the White Plains Division jury pool underrepresented Black and Hispanic residents.
Memorandum of Law in Support of Motion to Dismiss: 138
The memorandum of law argues that the pre-indictment delay has prejudiced Ghislaine Maxwell's ability to defend herself, citing lost witnesses, corrupted memories, and tactical delay by the government. The document presents a detailed analysis of the applicable law and the specific circumstances of the case. It contends that the government's delay was reckless and in bad faith, further supporting Maxwell's motion to dismiss the indictment.
Court Filing - Memorandum in Support of Motion to Strike Surplusage: 146
Ghislaine Maxwell's defense team files a motion to strike surplusage from the superseding indictment, arguing that allegations regarding Accuser-3 are irrelevant, prejudicial, and should be stricken or subject to the admissibility requirements of Fed. R. Evid. 404(b). The memorandum contests the government's inclusion of Accuser-3's allegations, claiming they do not support the charges against Maxwell.
Court Filing - Letter to Judge: 192
The letter, written by defense attorney Bobbi C. Sternheim, objects to the government's filing of a second superseding indictment in the case against Ghislaine Maxwell, arguing it is an example of 'tactical gamesmanship' that complicates the case and prejudices Maxwell's rights. The defense requests a new briefing schedule and considers seeking a continuance, citing concerns about Maxwell's detention and right to a fair trial.
Court Filing - Memorandum in Opposition to Government's Memorandum in Support of Detention: 21-770
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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