The government
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Legal representative |
24
Very Strong
|
70 | |
|
person
Ms. Moe
|
Representative |
17
Very Strong
|
21 | |
|
person
Ms. Maxwell
|
Legal representative |
15
Very Strong
|
68 | |
|
person
the defendant
|
Legal representative |
15
Very Strong
|
65 | |
|
person
the defendant
|
Adversarial |
13
Very Strong
|
21 | |
|
person
Ms. Moe
|
Legal representative |
12
Very Strong
|
8 | |
|
person
Ms. Comey
|
Representative |
12
Very Strong
|
10 | |
|
person
Ms. Maxwell
|
Adversarial |
12
Very Strong
|
16 | |
|
organization
the defense
|
Legal representative |
11
Very Strong
|
20 | |
|
person
MR. ROHRBACH
|
Representative |
11
Very Strong
|
11 | |
|
person
MAXWELL
|
Legal representative |
11
Very Strong
|
15 | |
|
person
GHISLAINE MAXWELL
|
Adversarial |
11
Very Strong
|
21 | |
|
person
Defense counsel
|
Legal representative |
11
Very Strong
|
7 | |
|
person
MS. POMERANTZ
|
Representative |
10
Very Strong
|
6 | |
|
person
Jeffrey Epstein
|
Legal representative |
10
Very Strong
|
6 | |
|
person
defendant
|
Legal representative |
10
Very Strong
|
18 | |
|
organization
The Court
|
Legal representative |
10
Very Strong
|
7 | |
|
person
victims
|
Legal representative |
10
Very Strong
|
8 | |
|
person
Jane
|
Legal representative |
10
Very Strong
|
3 | |
|
person
ALISON J. NATHAN
|
Professional |
10
Very Strong
|
6 | |
|
person
MS. MENNINGER
|
Opposing counsel |
9
Strong
|
5 | |
|
person
MAXWELL
|
Adversarial |
9
Strong
|
5 | |
|
person
JANE
|
Witness prosecution |
9
Strong
|
5 | |
|
person
Juror 50
|
Legal representative |
9
Strong
|
5 | |
|
person
A. Farmer
|
Witness prosecution |
8
Strong
|
4 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Court proceedings/Trial discussions | Courtroom (referenced by Tr... | View |
| N/A | N/A | Modification of a Protective Order | Court | View |
| N/A | N/A | Legal Argument regarding NPA applicability | Court | View |
| N/A | N/A | Limited Hearing | Court | View |
| N/A | N/A | Closing Arguments and Jury Charge | Courtroom | View |
| N/A | N/A | Modification of Protective Order | Court | View |
| N/A | N/A | Boies Schiller began producing materials not covered by protective orders in response to subpoenas. | N/A | View |
| N/A | N/A | Trial Testimony (Trial Tr. at 2518–22) | Court | View |
| N/A | N/A | Submission of evidence (Journal) | Unknown | View |
| N/A | N/A | Anticipated trial where evidence regarding victims and terms like 'rape' will be used. | Court | View |
| N/A | N/A | Review of Motion to Unseal Grand Jury Materials | Court (Southern District of... | View |
| N/A | N/A | Government's motion to unseal testimony and exhibits | Court | View |
| N/A | N/A | Entry of Non-Prosecution Agreement | Unknown | View |
| N/A | N/A | Previous hearing where government touted documentary evidence. | Court | View |
| N/A | N/A | Three bail renewal hearings | Court | View |
| N/A | N/A | Proffer session | Unknown | View |
| N/A | N/A | Hearing regarding requested discovery | Court | View |
| N/A | N/A | Transfer of legal materials | Court / MDC | View |
| N/A | N/A | The government served a redacted party with a subpoena to produce [redacted items]. | Unknown | View |
| N/A | N/A | Legal defense against charges | United States | View |
| N/A | N/A | Criminal indictment alleging Ms. Maxwell committed perjury. | Unknown | View |
| N/A | N/A | Witness preparation for trial where the government asked McHugh to review exhibits. | Unknown | View |
| N/A | N/A | Government charged Jeffrey Epstein with conduct falling within the NPA time scope. | Court | View |
| N/A | N/A | Bail hearing argument. | Court | View |
| N/A | N/A | Government secret deal (Non-Prosecution Agreement) | Florida (implied context of... | View |
DOJ-OGR-00005405.jpg
This legal document, filed on October 29, 2021, is a motion from the Government requesting protective measures for witnesses and minor victims in a criminal case. The Government asks the Court to allow several witnesses to testify using pseudonyms or first names only to protect the identities of the minor victims they are testifying about. The motion also requests that a non-testifying minor victim be referred to by her first name only in open court.
DOJ-OGR-00005403.jpg
This document is a page from a legal filing dated October 29, 2021, which argues for victim protections during testimony. It cites two judicial precedents: one from Judge Garaufis, who distinguished between a victim's choice to speak publicly and court testimony, and another from Judge Donnelly in the case of *United States v. Robert Kelly*, where the court allowed victims to use pseudonyms due to the sensitive nature of their testimony about sexual abuse.
DOJ-OGR-00005396.jpg
This legal document is a preliminary statement from the Government, filed on October 29, 2021, in case 1:20-cr-00330-PAE. The Government submits nine motions in limine to the Court, seeking to set the rules for an upcoming trial. The motions aim to protect victims' privacy, admit certain statements, and preclude the defense from introducing what the Government considers irrelevant, confusing, or improper evidence and arguments, such as questioning law enforcement decisions or attempting to garner sympathy for the defendant.
DOJ-OGR-00005395.jpg
This document is the table of contents for a legal motion filed on October 29, 2021, in case 1:20-cr-00330-PAE. The motion, presumably from the prosecution, outlines a series of requests to the court to limit the defense's ability to introduce certain evidence and arguments during the upcoming trial. Key issues addressed include protecting witness identities, the admissibility of minor victims' statements, precluding discussion of prior investigations, and preventing arguments related to jury nullification or the defendant's status in a past civil case.
DOJ-OGR-00005386.jpg
This is page 2 of a legal filing from the Law Offices of Bobbi C. Sternheim, dated October 27, 2021, related to Case 1:20-cr-00330-PAE (US v. Ghislaine Maxwell). The text argues that the government is prioritizing witness convenience over the prudence of seating a fair and impartial jury, characterizing the government's actions as seeking an 'undue and unreasonable advantage.'
DOJ-OGR-00005381.jpg
This legal document, filed on October 26, 2021, is a submission by the Government to the Court regarding jury selection procedures for an upcoming trial. The Government argues against providing juror identities to the parties weeks in advance, citing precedent that the purpose of voir dire is to identify disqualifications, not to enable deep background research. The Government requests that peremptory challenges be made at the conclusion of voir dire, not on the trial's start date of November 29, 2021, and asks the Court for clarification on the matter.
DOJ-OGR-00005379.jpg
This document is a letter motion filed by Christian Everdell, attorney for Ghislaine Maxwell, requesting a one-week extension (until November 3, 2021) to file the joint proposed jury charge and verdict sheet. The letter explains that the delay is needed due to other pressing deadlines and states that the government consents to the request. Judge Alison J. Nathan signed and ordered the approval of this request on October 26, 2021.
DOJ-OGR-00005377.jpg
This document is a letter motion filed on October 25, 2021, by defense attorney Christian R. Everdell to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The defense requests a one-week extension (to November 3, 2021) to file the joint proposed jury charge and verdict sheet, citing conflicting deadlines including Rule 412 briefing. The government has consented to this extension request.
DOJ-OGR-00005363.jpg
This document is page 6 of a court filing from the case against Ghislaine Maxwell, dated October 22, 2021. It appears to be a proposed jury questionnaire, outlining the charges in Counts Five and Six related to sex trafficking of minors with Jeffrey Epstein between 2001 and 2004. The document also includes questions for potential jurors regarding legal principles like the presumption of innocence and reasonable doubt, alongside objections from both the defense and the government concerning the wording and content of these sections.
DOJ-OGR-00005362.jpg
This document is page 5 of a court filing (Document 367-1) from the trial of Ghislaine Maxwell, filed on October 22, 2021. It appears to be a script for jury selection (voir dire), outlining the specific charges in the indictment against Maxwell, including conspiracy with Jeffrey Epstein to entice minors and sex trafficking between 1994 and 2004. The text details the first four counts of the indictment.
DOJ-OGR-00005359.jpg
This document is an introduction to a legal filing (Document 367-1) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated October 22, 2021. It outlines a request by the parties for the Court to include specific questions during the examination of prospective jurors (voir dire). The text emphasizes standard legal principles, specifically the presumption of innocence for Ms. Maxwell and the government's burden of proof beyond a reasonable doubt.
DOJ-OGR-00005346.jpg
This document is page 24 of a juror questionnaire for a federal criminal case (1:20-cr-00330-PAE), filed on October 22, 2021. It contains questions designed to screen potential jurors for biases or personal experiences related to sexual abuse, sex trafficking, and sex crimes involving minors. A comment on the document indicates that the U.S. Government proposed some of the specific wording used in the questions.
DOJ-OGR-00005342.jpg
This document is page 20 of a juror questionnaire for a legal case (Case 1:20-cr-00330-PAE), filed on October 22, 2021. It questions potential jurors on their ability to be impartial given Ghislaine Maxwell's association with Jeffrey Epstein, their capacity to avoid media coverage, and their feelings about the sexually explicit nature of the alleged crimes. A comment indicates that the government proposed some of the question's language.
DOJ-OGR-00005338.jpg
This document is page 16 of a juror questionnaire for the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on October 22, 2021. The questions are designed to screen potential jurors for pre-existing knowledge, biases, and opinions about Ghislaine Maxwell and her associate Jeffrey Epstein, based on media they may have consumed or discussions they may have had. The document also includes annotations indicating legal objections and proposed changes from both the defense and the government.
DOJ-OGR-00005235.jpg
This document is Page 2 of a Government filing (Case 1:20-cr-00330-PAE, filed 10/15/21) addressing defense complaints regarding legal mail delays at the MDC. The Government argues that a request for 1-day mail turnaround is burdensome given the facility houses 1,700 inmates. It details the timeline of a specific hard drive delivery: sent Oct 11, received Oct 12, delayed Oct 13 due to an 'institutional emergency,' and personally delivered to the defendant by MDC legal counsel on Oct 14, 2021.
DOJ-OGR-00002884.jpg
A legal letter dated March 31, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense objects to a second superseding indictment filed by the government, characterizing it as 'tactical gamesmanship' that expands the conspiracy timeline (1994-2004) and adds charges based on old evidence against Jeffrey Epstein. Sternheim expresses concern over Maxwell's health and ability to stand trial, notes the government's refusal to provide accuser names, and requests a conference to discuss moving the July 12th trial date.
DOJ-OGR-00002877.jpg
This legal document is a letter from the law firm Boies Schiller Flexner LLP (BSF) to Judge Alison J. Nathan, dated March 22, 2021, regarding the case of United States v. Ghislaine Maxwell. BSF objects to a subpoena issued by Maxwell's defense, arguing it is overly broad and lacks clarity on which victims require notice, while clarifying that the firm represents victims Annie Farmer (Minor Victim-2) and Virginia Giuffre. The firm states its intention to notify all Epstein victims it represents about the subpoena out of an abundance of caution.
DOJ-OGR-00002685.jpg
This document is page 10 of a legal defense filing in the case United States v. Ghislaine Maxwell, filed on Feb 4, 2021. The text argues that the indictment fails to establish a conspiracy charge regarding 'Accuser-3' because there is no evidence of interstate or foreign travel (a requirement for federal jurisdiction), noting that the alleged incidents took place in England. Additionally, the defense argues that any charges related to Accuser-3 are time-barred by the statute of limitations.
DOJ-OGR-00002677.jpg
This document is the Table of Contents for a legal filing (Document 146) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on February 4, 2021. The filing outlines arguments to strike references to 'Accuser-3' from the indictment, claiming they are surplusage, irrelevant to the alleged conspiracies, and unduly prejudicial to Ms. Maxwell. Alternatively, it argues the Government should be required to demonstrate the admissibility of evidence regarding Accuser-3.
DOJ-OGR-00020383.jpg
This document is a court order from the U.S. Court of Appeals for the Second Circuit, dated June 2, 2021, in the case of United States of America v. Ghislaine Maxwell. The order, issued by Circuit Judges Leval, Lohier Jr., and Sullivan, denies the appellant Ghislaine Maxwell's renewed request for pretrial release. It also denies her alternative request for the court to remand the matter to a district court for a hearing on her confinement conditions.
DOJ-OGR-00020379.jpg
This document is a page from a government legal filing (Case 21-58) responding to Ghislaine Maxwell's complaints regarding her incarceration conditions at the MDC. The text refutes Maxwell's claims of sewage flooding by clarifying that the cited precedent (Tiffany Days) occurred at the MCC, not the MDC. Additionally, it counters her claim of 'solitary confinement' by detailing her 13-hour daily access to a day room equipped with computers, a phone, and a TV, while noting she requires protective custody for her safety.
DOJ-OGR-00020369.jpg
This document is page 11 of a court filing dated May 27, 2021, concerning Ghislaine Maxwell's confinement conditions at the Metropolitan Detention Center (MDC). It details the Government's response regarding Maxwell's request for an eye mask and a dispute over nighttime flashlight checks. Judge Nathan denied Maxwell's request to modify the monitoring schedule on May 14, 2021, noting that Maxwell's claims were unsupported by an affidavit and that flashlight checks are standard procedure for all inmates.
DOJ-OGR-00020361.jpg
This document is page 3 of a Government legal filing dated May 27, 2021, opposing Ghislaine Maxwell's renewed attempts for bail. It outlines the procedural history, noting that Judge Nathan previously denied bail twice and that the appellate court affirmed these denials on April 27, 2021. The document states that Maxwell's trial is scheduled to begin on November 29, 2021, and begins a Statement of Facts regarding her indictment.
DOJ-OGR-00020328.jpg
This document is page 4 of a legal filing (Case 21-58) dated May 17, 2021, arguing for Ghislaine Maxwell's release on bond due to 'horrific conditions' at the MDC. The text details specific grievances, including sleep deprivation by guards every 15 minutes, contaminated brown water, sewage smells in her unit, and the video/audio recording of privileged meetings with her attorneys. The filing asserts that these conditions make it impossible for her to prepare for trial and that she is not being treated like similarly situated pre-trial detainees.
DOJ-OGR-00020327.jpg
This legal document is a renewed motion for bond on behalf of appellant Ghislaine Maxwell, dated May 17, 2021. The motion argues against the harsh conditions of her confinement, specifically citing sleep deprivation caused by flashlight checks every 15 minutes for over 318 days. The document refutes the government's justifications for these measures—such as suicide risk or the high-profile nature of the case—as nonsensical and abusive.
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