3d Cir.
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This document is a page from a legal filing that discusses the legal precedent set in the Annabi case concerning the scope of plea agreements. It explains the "Annabi rule," which holds that a plea agreement only binds the U.S. Attorney's office in the district where it was made, unless explicitly stated otherwise. The document also highlights that this rule has been sharply criticized by other courts, such as in U.S. v. Gebbie, for lacking a sound analytical basis.
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This document is page 11 of a legal filing from Case 22-1426, dated February 28, 2023. It is a table of authorities listing numerous U.S. court cases, dating from 1926 to 2022, which are cited within the main document. Each citation includes the case name, legal reporter information, and the page numbers where the case is referenced.
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This document is page 4 of a court filing (Document 97) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-AJN), filed on December 14, 2020. It is a 'Table of Authorities' listing various legal precedents (United States v. Boustani, Bradshaw, Chen, etc.) cited elsewhere in the filing. The page is numbered 'iii' and bears the Bates stamp DOJ-OGR-00001976.
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This legal document analyzes court precedent regarding whether a plea agreement in one federal district binds prosecutors in another. It argues that the 'Annabi rule' has been sharply criticized and was based on a misreading of prior cases from the Second Circuit, specifically Abbamonte, Alessi, and Papa. The document suggests that the precedent set by these earlier cases does not support the broad interpretation applied in Annabi.
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This document is page 4 (labeled 'iii') of a Table of Authorities from a legal brief filed on November 1, 2024, in Case 22-1426 (likely the Ghislaine Maxwell appeal). It lists various legal precedents cited in the brief, including a 2024 Second Circuit decision in *U.S. v. Maxwell*, along with citations to other federal cases such as *U.S. v. Papa* and *U.S. v. Persico*. The document bears a Department of Justice Bates stamp.
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This document is a page from a legal brief (likely by the Government) appearing in the appellate case of United States v. Maxwell (Case 22-1426). It argues that the statute of limitations for the charges against Maxwell had not expired due to the 2003 amendment to Section 3283. The text supports Judge Nathan's lower court ruling that applying this amendment was not an impermissible retroactive effect, distinguishing Maxwell's situation from the precedent set in United States v. Richardson.
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This document is page 11 of 93 from a legal filing (Case 22-1426), dated June 29, 2023. It is a 'Table of Authorities' listing various legal precedents (case law) cited in the main brief, including 'United States v. Salameh', 'United States v. Teman', and 'United States v. Vickers'. The footer indicates it is a Department of Justice document (DOJ-OGR-00021658).
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This document is page 13 of a legal brief filed on October 2, 2020, in case 20-3061 (Maxwell appeal). The text argues that Maxwell's appeal regarding pretrial discovery materials does not meet the strict requirements of the collateral order doctrine established by the Supreme Court. The Government distinguishes Maxwell's situation from cases she cited (Pichler v. UNITE, Minpeco S.A. v. Conticommodity Servs.), noting those involved intervenors in civil cases rather than parties in criminal cases.
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This document is page 3 of a legal brief (Case 20-3061) filed on September 28, 2020, arguing that the appellate court has jurisdiction to review a district court's decision regarding a protective order in the Ghislaine Maxwell case. The text focuses on the 'collateral order doctrine' and cites legal precedents to support the claim that the unsealing order can be appealed immediately without waiting for the criminal trial to conclude. It mentions Ms. Maxwell's intention to stay the unsealing process.
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This document is a page from a legal filing (Document 613) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 24, 2022. The text argues against 'Juror No. 50's' request to intervene and obtain discovery, citing that the juror has no legal standing and is currently under criminal investigation. The prosecution argues that releasing information would allow the juror to tailor their testimony and prejudice the ongoing investigation into their conduct.
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This document is page 17 of a defense sentencing memorandum filed on June 15, 2022, in the case against Ghislaine Maxwell. The defense argues against the application of sentencing guideline § 4B1.5 ('Repeat and Dangerous' sex offenders), asserting that Maxwell has not committed crimes in nearly 20 years, is not attracted to minors, and acted only as a facilitator for Epstein's impulses rather than having them herself. The text contrasts her behavior with case law examples of violent repeat offenders and highlights her subsequent crime-free life involved with partners who had children.
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This legal document, part of a court filing, argues that Ms. Maxwell must be sentenced under the 2003 Guidelines rather than the harsher 2004 Guidelines. It asserts that applying the 2004 Guidelines would violate the Ex Post Facto Clause unless a jury, not the judge, found that her criminal conduct continued past November 1, 2004. Since the jury made no such finding, the court is bound to use the earlier guidelines.
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This legal document, a page from a court filing, analyzes the definition of "sexual abuse" under federal law, specifically 18 U.S.C. § 3509(a). It argues for a broad interpretation by citing several court cases, including decisions from the Supreme Court and various Circuit Courts. The document emphasizes that the definition is not limited to physical sexual contact but also includes actions like persuasion and inducement, and that the statutory examples are illustrative rather than exhaustive.
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This document is page 26 of 239 from a legal filing (Document 204) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It is a 'Table of Authorities' listing legal precedents (case law starting with W and Z) and a comprehensive list of Federal Statutes (18 U.S.C. and 28 U.S.C.) referenced in the filing. The statutes cited include laws regarding sex trafficking (§ 1591), coercion/enticement (§ 2422), transportation of minors (§ 2423), and child victims' rights (§ 3509), which are central charges in the Maxwell/Epstein proceedings.
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This document is page 58 of 80 from a legal filing (likely a brief or opinion) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on July 2, 2021. The text analyzes legal precedents, specifically *Government of Virgin Islands v. Scotland*, to argue that prosecutors must be held to their promises and assurances to defendants, particularly when a defendant relies on those promises to their detriment. The page discusses the concepts of specific performance, due process, and plea agreements.
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This legal document argues that Ms. Maxwell is not a flight risk and should be granted bail. The argument centers on her high public profile, which would make fleeing difficult, and her willingness to sign irrevocable waivers of extradition for both the United Kingdom and France. The document cites the case of United States v. Cirillo as a precedent for using such waivers as a condition for release.
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