Jeffrey Pagliuca
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Client |
16
Very Strong
|
34 | |
|
person
GHISLAINE MAXWELL
|
Professional |
10
Very Strong
|
14 | |
|
person
GHISLAINE MAXWELL
|
Legal representative |
10
Very Strong
|
6 | |
|
person
Nicole Simmons
|
Business associate |
6
|
6 | |
|
person
Bobbi C. Sternheim
|
Professional |
5
|
1 | |
|
organization
Haddon, Morgan and Foreman, P.C.
|
Professional |
5
|
1 | |
|
person
Ms. Sternheim
|
Professional |
5
|
1 | |
|
person
defendant
|
Client |
5
|
1 | |
|
person
Laura A. Menninger
|
Business associate |
5
|
1 | |
|
person
Juror 50
|
Lack of relationship |
5
|
1 | |
|
person
Ms. Sternheim
|
Business associate |
5
|
1 | |
|
person
Juror 50
|
None |
5
|
1 | |
|
person
Nicole Simmons
|
Professional |
2
|
2 | |
|
person
ALISON J. NATHAN
|
Correspondent |
1
|
1 | |
|
person
Ms. Maxwell
|
Legal representative |
1
|
1 | |
|
person
Nicole Simmons
|
Legal representative |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | Pretrial conference | A final pretrial conference was held to discuss outstanding issues and the plan for jury selection. | Courtroom | View |
| N/A | Legal stipulation | The prosecution and defense formally agreed that Government Exhibits 52A, 52D, 52E, 52F, 52G, and... | UNITED STATES DISTRICT COUR... | View |
| N/A | Pretrial conference | A pretrial conference was held where counsel for the government and defendant made their appearan... | Courtroom | View |
| 2022-08-10 | Legal proceeding | An opening statement was made by Ms. Sternheim on behalf of her client, Ghislaine Maxwell, in cas... | Courtroom (implied) | View |
| 2022-08-10 | Court proceeding | The defense, led by Ms. Sternheim, delivers its opening statement in the criminal trial of Ghisla... | Southern District Court (im... | View |
| 2022-03-11 | Court filing | Ghislaine Maxwell filed a MOTION for New Trial. | N/A | View |
| 2022-03-11 | N/A | Filing of Motion for New Trial by Ghislaine Maxwell | Court Docket | View |
| 2022-03-11 | Court filing | Ghislaine Maxwell filed a REPLY TO RESPONSE to the motion for a new trial. | N/A | View |
| 2021-12-22 | N/A | Jury Trial proceedings in USA v. Ghislaine Maxwell | New York, N.Y. | View |
| 2021-12-17 | Legal stipulation | The prosecution and defense agreed that Government Exhibit 1010 may be received in evidence at tr... | New York, New York | View |
| 2021-12-17 | Legal agreement | A stipulation was agreed upon by the defense and prosecution to allow Defense Exhibit A1 to be re... | New York, New York | View |
| 2021-12-10 | Legal agreement | A stipulation was signed agreeing that Government Exhibit 1009 may be received in evidence at trial. | New York, New York | View |
| 2021-11-28 | N/A | Stipulation agreed upon regarding the admission of Government Exhibits 1004 and 11-16. | New York, New York | View |
| 2021-11-13 | N/A | Filing of Defense Response to Motion In Limine | NYSD Court (via email) | View |
| 2021-11-12 | N/A | Filing of multiple Motions in Limine by Defense and Opposition Memoranda by Government | SDNY Court | View |
| 2021-11-12 | Court filing | Multiple motions in limine, a response, a reply memorandum, and memo endorsements were filed and ... | N/A | View |
| 2021-11-12 | Court filing | Multiple motions in limine, a response to a motion, and a reply memorandum were filed and entered... | N/A | View |
| 2021-11-12 | N/A | Submission of Maxwell's Response to Government's Motion In Limine to Preclude Expert Testimony of... | NYSD (New York Southern Dis... | View |
| 2021-11-12 | N/A | Multiple motions in limine and responses entered into the docket. | SDNY | View |
| 2021-11-01 | N/A | Submission of Rule 16(b)(1)(C) Disclosures for U.S. v. Maxwell | Email correspondence | View |
| 2021-10-29 | Court filing | MOTION in Limine to Preclude Reference to the Accusers as "Victims" or "Minor Victims" (Doc 395) ... | SDNY | View |
| 2021-10-29 | Court filing | MOTION in Limine to Preclude Testimony About Any Alleged "Rape" by Jeffrey Epstein (Doc 394) file... | SDNY | View |
| 2021-10-29 | Court filing | MOTION in Limine to Exclude Items Purportedly Seized During Search of 358 El Brillo Way on Octobe... | 358 El Brillo Way | View |
| 2021-10-29 | Court filing | REPLY TO RESPONSE to Motion filed by Ghislaine Maxwell. | N/A | View |
| 2021-10-29 | Court filing | MOTION in Limine to Suppress Identification (Doc 392) filed by Ghislaine Maxwell. | SDNY | View |
EFTA00023360.pdf
This document is a letter dated November 20, 2021, from the U.S. Department of Justice to Ghislaine Maxwell's defense team regarding the production of discovery materials. The government provided Jencks Act and Giglio materials for potential trial witnesses, as well as witness statements for individuals they did not currently intend to call to testify. The letter also clarifies confidentiality designations under a Protective Order.
EFTA00023217.pdf
This document is a letter from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell, dated October 25, 2021. It details the production of discovery materials, including Jencks Act and Giglio materials, for potential trial witnesses and others the government does not currently intend to call. The letter also clarifies a labeling change for confidential documents to avoid confusion with classified materials, replacing 'confidential' stamps with references to the Protective Order.
EFTA00023045.pdf
A discovery cover letter dated July 21, 2021, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter accompanies the production of 'FedEx Records' (Bates range SDNY_GM_02753552 to SDNY_GM_02759392) which are designated as confidential under a protective order. The document outlines the ongoing discovery obligations of the government.
EFTA00022511.pdf
A discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated May 3, 2021. The letter confirms the production of confidential photographs (Bates range SDNY_GM_02753399 to SDNY_GM_02753431) under a Protective Order.
EFTA00022052.pdf
A discovery production letter dated October 19, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter outlines a production of evidence including FBI Florida and NY documents, Palm Beach Police Department (PBPD) materials, aerial video, and 3-D blueprints, spanning Bates numbers SDNY_GM_00328070 through SDNY_GM_00356148. The letter designates specific items as 'Confidential' or 'Highly Confidential' under a Protective Order.
EFTA00021941.pdf
This document is a formal letter from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team, dated October 11, 2021. It serves to notify the defense that the Government intends to refer to Jeffrey Epstein and other redacted individuals as co-conspirators during the trial, pursuant to a court order. The letter is marked as Exhibit 1 and designated as confidential under a protective order.
EFTA00021685.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 12, 2021. It serves as notice that the Government intends to introduce evidence showing Maxwell provided other men with access to women, in addition to her conduct with Epstein. The letter also discloses a redacted witness who worked for Epstein in 2005-2006 and will testify about scheduling sexualized massages with underage girls.
EFTA00021036.pdf
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 23, 2021. The letter details the production of Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials regarding individuals the government does not currently plan to call. It also clarifies confidentiality designations under a Protective Order.
EFTA00021034.pdf
A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 23, 2021, accompanying a discovery production. The production includes JPMC records, phone records, and other documents designated as confidential under a protective order. The letter clarifies labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00020815.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated October 13, 2021. It accompanies the production of spreadsheets previously reviewed by the defense at an FBI office in Denver. The letter notes that the original spreadsheets contained embedded hyperlinks to images of 'child exploitation materials,' necessitating the creation of a sanitized version for production.
EFTA00020105.pdf
A formal letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated October 11, 2021. The letter discloses that the Government intends to refer to Jeffrey Epstein and two other redacted individuals (one with a former alias) as 'co-conspirators' during the upcoming trial. The document is marked confidential under a protective order.
EFTA00019599.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team responding to a discovery request. The Government declines to produce broad FOIA-related documents citing lack of legal basis under Rule 16, but provides specific materials related to Radar Online and FBI-NY's involvement in the SDFL investigation as a courtesy. The letter also corrects a defense assertion regarding the FBI Florida office's role in the prosecution team.
EFTA00019422.pdf
A discovery letter dated December 16, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter accompanies the production of materials stamped SDNY_GM_00274187 through SDNY_GM_0274302, which are identified in the index as a 'UBS Subpoena Return' dated 12-15-2020. The document notes that the letter and materials are subject to a protective order.
EFTA00019420.pdf
A discovery letter dated December 16, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter documents the production of materials designated as confidential, specifically referencing a 'UBS Subpoena Return' dated December 15, 2020. The document indicates ongoing discovery obligations and mentions that physical items are in FBI custody.
EFTA00018883.pdf
This document is a formal notice from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team, dated April 23, 2021. The Government notifies the defense of its intent to call Dr. Lisa Rocchio as an expert witness to testify on trauma psychology, the dynamics of sexual abuse, grooming, and delayed disclosure, though she has not evaluated specific victims in this case. The letter also reiterates requests for reciprocal discovery and disclosure of defense expert witnesses.
EFTA00016949.pdf
This document is a legal letter dated April 23, 2021, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. It serves as a formal notice pursuant to Rule 16(a)(1)(G) that the Government intends to call a clinical expert witness (name redacted) to testify about the psychology of sexual abuse, grooming, delayed disclosure, and the impact of trauma on minors. The letter outlines the scope of the expert's anticipated testimony and requests reciprocal discovery regarding any experts the defense intends to call.
EFTA00016944.pdf
This document is an email chain from October 18-19, 2021, regarding the filing of Motions in Limine in the case U.S. v. Maxwell (Case No. 20 Cr. 330). Defense attorney Nicole Simmons submits the motions to Judge Nathan's chambers on behalf of Jeffrey Pagliuca. Subsequent internal emails among USANYS staff discuss accessing the files, revealing an internal DOJ file path labeled 'USvEpstein-2018R01618'.
EFTA00016726.pdf
This document is an email chain from October 2021 regarding the 'US v. Maxwell' case (20cr330). Defense attorney Bobbi Sternheim provides a list of attendees, including legal counsel and Maxwell's family members (Ian, Kevin, Pandora, Philip, Isabel, Christine), for an October 21 teleconference and a November 1 in-person pretrial conference. The email responds to a request from Judge Alison J. Nathan's chambers regarding logistics, COVID-19 protocols, and speaking rules for the upcoming hearings.
EFTA00016267.pdf
This document is an email thread from November 2021 regarding 'U.S. v. Maxwell'. Nicole Simmons of Haddon, Morgan and Foreman, P.C. sent 'Ms. Maxwell's Rule 16(b)(1)(C) Disclosures' to USANYS counsel at the request of Jeffrey Pagliuca. The email was subsequently forwarded internally within the US Attorney's Office.
EFTA00015823.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 16 evidence discs labeled as 'Epstein Encase Files.' The government identified these discs as containing a forensic image of a computer seized from Epstein's Palm Beach residence in 2005. However, the government concluded that the original warrant authorized seizure but not the search of the computer's contents, and thus they lack the lawful authority to review the files or allow the defense to access them.
EFTA00014984.pdf
This document is an email chain from November 2021 regarding the case U.S. v. Maxwell. Nicole Simmons of the defense firm Haddon, Morgan and Foreman sent Rule 16 disclosures to the US Attorney's Office (USANYS) at the request of Jeff Pagliuca. The email was subsequently forwarded internally within the USANYS office with a note regarding a brief due on November 15th assigned to Ryan Hall.
EFTA00014671.pdf
This document is a letter from Ghislaine Maxwell's defense counsel to Judge Alison Nathan, dated May 12, 2021, arguing for the enforcement of a subpoena for evidence controlled by the law firm Boies, Schiller, and Flexner (BSF). The defense seeks the full production of a journal kept by 'Accuser-2' in 1996, arguing that the government is relying on selective excerpts to support its case while ignoring potentially exculpatory context in the rest of the journal. The letter also addresses disputes over the production of a pair of boots and original photographs, accusing the government of interfering with the defense's investigation and practicing 'selective ignorance.'
EFTA00014650.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 20, 2021, accompanying a production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as statements from individuals the government does not currently plan to call. The letter also clarifies labeling protocols for confidential documents under the Protective Order to avoid confusion with classified material.
EFTA00011133.pdf
This document is a letter dated October 13, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. The Government asserts that Maxwell has waived her right to use an insanity or mental condition defense (Rule 12.2) because she failed to provide notice by the pretrial motion deadlines in early 2021. The letter demands that if the defense intends to use such evidence despite the waiver, they must provide notice by October 20, 2021.
EFTA00010445.pdf
This document contains excerpts from depositions of Ghislaine Maxwell taken on April 22, 2016, and July 22, 2016. Maxwell denies knowingly inviting underage girls (other than friends' children) to Epstein's homes, denies knowledge of sex toys at Epstein's properties, and denies recruiting girls for sexual massages. She specifically denies giving a massage to a redacted individual (likely Virginia Giuffre) and claims her sexual involvement with Epstein was limited to him and two other specific women.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Notification regarding the filing of a motion under Federal Rule of Evidence 412 under seal and plans to notify alleged victims' counsel.
Response to Government Letters dated May 4, and May 6, 20...
Defense response arguing for the production of a journal, boots, and photographs, and criticizing the government's handling of evidence controlled by BSF.
Response to the Government’s October 7, 2020 letter, Unit...
Complaint regarding the Government's failure to meet discovery deadlines and promises regarding files from the Southern District of Florida.
Reply in Support of Request to Modify Protective Order (U...
Legal argument regarding the disclosure of information to a 'Civil Litigation' party about materials handed over to the U.S. Attorney's Office.
Request to Modify Protective Order (UNDER SEAL) - United ...
Request for an Order allowing Maxwell to refer to and file under seal certain discovery materials in redacted 'Other Matters'.
Modification of Protective Order
Motion seeking modification of protective order and to file under seal.
Request to Modify Protective Order
Requesting permission to disclose certain discovery materials under seal to Judge Preska in civil case.
Local Criminal Rule 23.1
Requesting order prohibiting Government/agents from making extrajudicial statements.
United States v. Ghislaine Maxwell, Case No. 20 Cr. 330 (...
A letter from Ghislaine Maxwell's counsel to the presiding judge requesting an order to prohibit the Government, its agents, and witnesses' counsel from making extrajudicial statements that could be prejudicial to Ms. Maxwell's right to a fair trial.
United States v. Ghislaine Maxwell, Case No. 20 Cr. 330 (...
A request to the Court to issue an order prohibiting the Government, its agents, and counsel for witnesses from making extrajudicial statements about the case to protect Ghislaine Maxwell's right to a fair trial.
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