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 |
|---|---|---|---|---|
| 2021-02-04 | N/A | Filing of Motion to Suppress Evidence obtained from Government Subpoena. | Court | View |
| 2021-02-04 | N/A | Filing of Motion to Dismiss Counts Five and Six. | Court | View |
| 2021-02-04 | N/A | Filing of Motion to Suppress Evidence under 4th/5th Amendments | Court | View |
| 2021-02-04 | N/A | Filing of multiple motions by the defense and an Order by the Judge. | Court Docket | View |
| 2021-02-04 | N/A | Filing of Motion to Dismiss Counts Five and Six (Alleged Misstatements). | Court | View |
| 2021-02-04 | N/A | Filing of multiple motions by Ghislaine Maxwell | Court Docket | View |
| 2021-01-25 | N/A | Motion filed for Separate Trial on Counts | Court | View |
| 2021-01-25 | N/A | Motion filed to Dismiss Counts as Multiplicitous | Court | View |
| 2021-01-25 | N/A | Motion filed to Dismiss Counts for Lack of Specificity | Court | View |
| 2021-01-25 | N/A | Multiple motions filed by defense (Separate Trial, Dismiss various counts). | Court | View |
| 2021-01-25 | Court filing | Multiple motions and supporting memorandums were filed by Ghislaine Maxwell's legal team, includi... | U.S. Court | View |
| 2021-01-25 | N/A | Filing of Motion for Separate Trial on Counts 5s-6s, 5-6. | Court | View |
| 2021-01-25 | N/A | Filing of Motion to Dismiss Counts One through Four for Lack of Specificity. | Court | View |
| 2021-01-25 | N/A | Ghislaine Maxwell filed multiple motions to dismiss the superseding indictment. | SDNY | View |
| 2021-01-25 | N/A | Filing of multiple motions by defense (Separate Trial, Dismiss Counts as Multiplicitous, Dismiss ... | Court Docket | View |
| 2021-01-25 | N/A | Motion filed for Separate Trial on Counts 5s-6s, 5-6. | Court | View |
| 2021-01-25 | N/A | Motion filed to Dismiss Either Count One Or Count Three as Multiplicitous. | Court | View |
| 2021-01-25 | N/A | Motion filed to Dismiss Counts One through Four for Lack of Specificity. | Court | View |
| 2020-08-24 | N/A | Filing of Reply in Support of Request to Modify Protective Order. | New York, NY (SDNY) | View |
| 2020-08-17 | Legal filing | Date the letter motion was written. | Denver, Colorado | View |
| 2020-07-21 | Legal filing | Attorneys for Ghislaine Maxwell filed a letter with the court requesting an order to prevent prej... | United States District Cour... | View |
| 2020-07-21 | Legal filing | Filing of a letter requesting an order to prohibit extrajudicial statements. | United States District Cour... | View |
| 2020-07-13 | Court order | Judge Alison J. Nathan signed an order granting the motion for Jeffrey Pagliuca to Appear Pro Hac... | N/A | View |
| 2020-07-13 | N/A | Order granting Jeffrey Pagliuca permission to appear Pro Hac Vice. | Court | View |
| 2020-07-13 | N/A | Order granting Motion for Jeffrey Pagliuca to Appear Pro Hac Vice. | Court Docket | View |
EFTA00032796.pdf
This document is an email dated October 19, 2021, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers in the NYSD. The email serves to submit 'Ms. Maxwell's Motions in Limine' and supporting documents for the case U.S. v. Maxwell (Case No. 20 Cr. 330), done at the request of attorney Jeffrey Pagliuca. The document contains redactions of contact information.
EFTA00032021.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated September 15, 2021. It serves as notice that the government intends to call FBI Computer Forensic Examiner Stephen [Redacted] as an expert witness to testify regarding the extraction of data from seized electronic devices. The letter also reiterates previous government requests from 2020 and early 2021 for reciprocal discovery and expert witness notices from the defense.
EFTA00031440.pdf
This document is a discovery production letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell's defense team, dated April 14, 2021. It details the production of a single photograph (Bates number SDNY_GM_02753398) designated as 'Confidential' under a Protective Order. The letter is signed by U.S. Attorney Audrey Strauss, with the specific Assistant U.S. Attorneys' signatures redacted.
EFTA00031437.pdf
A discovery letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team dated April 14, 2021. The letter documents the production of a single item, a photograph (Bates SDNY_GM_02753398), which is designated as confidential under a July 2020 Protective Order. The specific names of the Assistant U.S. Attorneys signing the document are redacted.
EFTA00031113.pdf
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 24, 2021, detailing the production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials for individuals the government does not currently intend to call. The letter also clarifies protective order designations for the enclosed documents.
EFTA00031016.pdf
This document is a discovery letter dated May 3, 2021, from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team. It accompanies the production of photographs (Bates range SDNY_GM_02753399 to SDNY_GM_02753431) designated as confidential under a Protective Order.
EFTA00030992.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 21, 2020. It outlines the production of various evidentiary materials, including Boies Schiller documents, emails, search warrant photos, Jeffrey Epstein's deposition recordings (2010), travel records, and SORNA records. The letter explicitly notes that 'highly confidential' materials containing sexualized images are being provided only to counsel, not the defendant, and refuses to produce a separate FBI obstruction file regarding a redacted former employee of Epstein deemed irrelevant to the case.
EFTA00030569.pdf
This document is a formal response from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 22 specific discovery requests made on October 13, 2020. The government addresses requests for Epstein's diary, the 'Billionaires Playboy Club' manuscript, flight logs (implied in broader requests but not itemized), and the identities of minor victims, often denying immediate production based on Rule 16 restrictions or asserting that materials have already been produced. The letter also discusses the handling of potential 'Brady' and 'Giglio' materials, stating that impeachment evidence will be produced closer to trial.
EFTA00030092.pdf
A cover letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated March 12, 2021. The letter accompanies a discovery production of photographs and documents received from victims not referenced in the indictment (S1 20 Cr. 330), designated as confidential under a protective order.
EFTA00029180.pdf
This document is an email chain from November 2021 regarding the legal case U.S. v. Maxwell. Attorney Nicole Simmons submits Ghislaine Maxwell's response to the government's motion to preclude the expert testimony of Dr. Park Dietz and Dr. Elizabeth Loftus to Judge Nathan's chambers. The documents were submitted under temporary seal to allow for government redaction proposals.
EFTA00028733.pdf
A discovery production letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated May 20, 2021. The production includes 'Interlochen records' and native 'carved' image files from various electronic devices (identified by codes such as NYC024321) that were previously produced in PDF format. The letter and materials are marked confidential under a Protective Order.
EFTA00028257.pdf
A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 9, 2021, regarding the production of discovery materials (Jencks Act and Giglio) for her trial. The letter explains that materials previously designated as 'confidential' are now marked with a specific reference to the Protective Order paragraphs to avoid confusion with classified document markings.
EFTA00028045.pdf
This document is a discovery production letter dated October 1, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. It details the transfer of financial records from Deutsche Bank, JPMorgan Chase, Citibank, UBS, and American Express, many of which are designated as confidential. The letter specifically links Ghislaine Maxwell to various entities including the Terramar Project, Max Foundation, and Angara Trust via UBS records, and notes shared American Express records between Maxwell and Jeffrey Epstein.
EFTA00027301.pdf
This document is a discovery production letter from the DOJ to Ghislaine Maxwell's defense team, dated August 5, 2021. It lists materials being turned over, including files recovered from discs seized at Jeffrey Epstein's New York residence, images from his electronic devices, Missouri records, a JPMorgan Chase return, and a 1995 Oxford letter. The letter also clarifies confidentiality designations under the Protective Order.
EFTA00027296.pdf
This document is a discovery production letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 4, 2021. It lists produced materials including FBI recovered metadata, Missouri records, a JPMorgan Chase return, and a letter from 1995 related to Oxford. The letter also clarifies new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00027072.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated October 20, 2020, serving as a cover letter for a discovery production. The production includes various materials such as FBI documents from Florida and NY, PBPD materials, and videos, listed with Bates numbers. The letter also addresses the status of data extracted from electronic devices seized from Jeffrey Epstein's properties, noting that privilege reviews are ongoing and that the Epstein Estate has not waived privilege.
EFTA00026819.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 8, 2020. The government asserts it has met its discovery obligations despite technical issues at the MDC, detailing efforts to reformat files and provide IT support. The letter also addresses Maxwell's conditions of confinement, confirming she must sleep in an isolation cell and undergo weekly body scans, while noting she has access to commissary food, mail, and 13 hours of discovery review time per day. It mentions the FBI possesses 43,500 images from Epstein's residences (3,500 containing nudity) which will be made available for review via a secure laptop brought to the MDC.
EFTA00026813.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 8, 2020, refuting claims that the government failed to meet discovery obligations. The letter details technical efforts to ensure Maxwell can review digital evidence at the MDC, including the provision of a secure laptop to review 43,500 images seized from Jeffrey Epstein's properties (3,500 of which contain nudity). It also addresses conditions of confinement, confirming Maxwell remains in an isolation cell for safety, undergoes weekly body scans, and has access to commissary food items.
EFTA00025147.pdf
This document is an email dated October 28, 2021, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers in the Southern District of New York. It serves as a transmittal for the filing of 'Ms. Maxwell's Reply In Support of Her Motions in Limine' in the case U.S. v. Maxwell (Case No. 20 Cr. 330). The email was sent at the request of attorney Jeffrey Pagliuca.
EFTA00025066.pdf
This document is a letter dated October 11, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. It formally notifies the defense that the government intends to refer to Jeffrey Epstein and other redacted individuals as co-conspirators during the trial, specifically for the purpose of admitting evidence under the co-conspirator hearsay exception. The letter is marked as Exhibit 1 and designated as confidential under a protective order.
EFTA00025035.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding the production of Jencks Act and Giglio materials for potential trial witnesses. The letter clarifies a stamping error in a previous production (October 11, 2021) involving records 3501.507-516 and explains new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00024987.pdf
This document is a discovery production letter dated November 24, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It details the production of confidential records related to JPMC (JPMorgan Chase) and Lockheed Martin, governed by a Protective Order. The letter explains the specific confidentiality markings applied to the produced materials.
EFTA00024868.pdf
A discovery cover letter dated May 3, 2021, from U.S. Attorney Audrey Strauss's office to Ghislaine Maxwell's defense team. The letter accompanies the production of photographs stamped SDNY_GM_02753399 through SDNY_GM_02753431, noting that the materials and the letter itself are designated as confidential under a Protective Order.
EFTA00024791.pdf
A discovery production letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated October 28, 2021. The letter lists produced materials including a scanned contact book page, records from the United Kingdom, and materials from the Estate of Jeffrey Epstein, noting confidentiality designations under a protective order.
EFTA00024232.pdf
This document is an email chain from October 2021 regarding the legal case U.S. v. Maxwell. The initial email is from defense attorney Nicole Simmons to Judge Nathan's chambers, submitting Ghislaine Maxwell's reply in support of motions in limine. This email was subsequently forwarded internally within the US Attorney's Office (USANYS) with a note attaching both the defense reply and the government's final brief.
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.
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.
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.
Local Criminal Rule 23.1
Requesting order prohibiting Government/agents from making extrajudicial statements.
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