GOVERNMENT
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
MAXWELL
|
Legal representative |
15
Very Strong
|
29 | |
|
organization
Defense
|
Legal representative |
13
Very Strong
|
21 | |
|
person
defendant
|
Legal representative |
13
Very Strong
|
62 | |
|
person
Defense counsel
|
Legal representative |
12
Very Strong
|
14 | |
|
person
GHISLAINE MAXWELL
|
Legal representative |
12
Very Strong
|
14 | |
|
person
Ms. Maxwell
|
Legal representative |
11
Very Strong
|
55 | |
|
person
Recipient
|
Legal representative |
11
Very Strong
|
5 | |
|
organization
Defense
|
Adversarial |
11
Very Strong
|
10 | |
|
person
MAXWELL
|
Adversarial |
10
Very Strong
|
14 | |
|
person
the defendant
|
Legal representative |
10
Very Strong
|
6 | |
|
person
THOMAS
|
Legal representative |
10
Very Strong
|
9 | |
|
person
Defense counsel
|
Professional |
10
Very Strong
|
6 | |
|
person
Ms. Maxwell
|
Adversarial |
10
Very Strong
|
21 | |
|
person
the defendant
|
Adversarial |
10
Very Strong
|
7 | |
|
person
defendant
|
Adversarial |
10
Very Strong
|
24 | |
|
location
court
|
Legal representative |
10
Very Strong
|
5 | |
|
person
Ms. Comey
|
Professional |
9
Strong
|
4 | |
|
person
MR. ROHRBACH
|
Professional |
8
Strong
|
4 | |
|
organization
Defense
|
Professional |
8
Strong
|
3 | |
|
person
MR. EPSTEIN
|
Legal representative |
7
|
2 | |
|
person
Thomas
|
Legal representative |
7
|
3 | |
|
person
Dr. Rocchio
|
Professional |
7
|
2 | |
|
person
Minor Victims
|
Protective |
7
|
2 | |
|
person
Epstein's counsel
|
Professional |
7
|
2 | |
|
person
Ms. Moe
|
Professional |
7
|
3 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Maxwell's motion to compel discovery from the Government, including Jencks Act, Brady, Giglio mat... | Court proceedings | View |
| N/A | N/A | Court's ruling on Maxwell's discovery requests, concluding she is not entitled to expedited disco... | Court proceedings | View |
| N/A | N/A | Court accepts Government's representations that it has disclosed all Brady and Giglio Material. | Court proceedings | View |
| N/A | N/A | Accusation by the government that Epstein paid Maxwell millions for recruiting young, underage wo... | N/A | View |
| N/A | N/A | Government's intention to produce 'Materials' to the defendant (Maxwell) under a protective order... | N/A | View |
| N/A | N/A | Argument that defendants should be able to rely on government promises in written agreements and ... | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss Mann Act counts for lack of specificity or to compel Government to s... | N/A | View |
| N/A | N/A | Broader investigation into Epstein's sexual abuse of minors, covering periods beyond the Indictment. | N/A | View |
| N/A | N/A | Government's review of 'Materials' (documents and photographs) related to Epstein's sexual abuse ... | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss indictment due to alleged actual prejudice from Government's delay i... | N/A | View |
| N/A | N/A | Ex parte proceeding where government allegedly misled Chief Judge McMahon to obtain a subpoena. | Court | View |
| N/A | N/A | Client's arrest and detention despite voluntary surrender. | N/A | View |
| N/A | N/A | Discussion of discovery timeline, with the government requesting until November. | Court | View |
| N/A | N/A | Government initiated a massive OPR investigation into the execution of the NPA. | N/A | View |
| N/A | N/A | Court agrees that some of Maxwell's concerns are overstated but acknowledges defamation action re... | N/A | View |
| N/A | N/A | NPA (Non-Prosecution Agreement) not disclosed to victims | N/A | View |
| N/A | N/A | Search warrants executed at properties of Jeffrey Epstein. | New York and Virgin Islands | View |
| N/A | N/A | Lefkowitz argued that the government was not required to notify victims under the § 2255 provisio... | N/A | View |
| N/A | N/A | Depositions taken as a result of government-supported civil suits against the speaker. | N/A | View |
| N/A | N/A | Indictment of Thomas | S.D.N.Y. | View |
| N/A | N/A | Opening of Grand Jury Investigation | Unknown | View |
| N/A | N/A | Sentencing hearing regarding fines, restitution, and guideline calculations. | Courtroom | View |
| N/A | N/A | Planned resolution of pending redaction issues | N/A | View |
| N/A | N/A | Victims' lawsuit against the government | Court | View |
| N/A | N/A | Ex parte modification of the protective order by Judge McMahon. | Court | View |
DOJ-OGR-00008247.jpg
This document, a court transcript filed on December 8, 2021, details a discussion about jury selection in Case 1:20-cr-00330-PAE. The speaker, a court official, outlines the process of reviewing prospective juror lists, noting the government's and defense's differing views on excusing jurors. The document also mentions a communication from the defense requesting to modify its previous juror strikes.
DOJ-OGR-00008241.jpg
This page from a court filing (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) argues that attorney-client privilege protects communications between a witness named 'Jane' and her attorney 'Glassman.' It asserts that Glassman could not waive this privilege as it belongs to Jane, and distinguishes the situation from the 'Bergonzi' case precedent regarding documents prepared for the Government.
DOJ-OGR-00008236.jpg
This is a court order issued by Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell on December 5, 2021. The order addresses a motion from the Government concerning the testimony of 'Witness-3' and compels both the Government and the Defense to submit letters to the court on the same day with specific deadlines. The order also reminds the parties to be mindful of sealing requirements under Rule 412.
DOJ-OGR-00008230.jpg
This legal document, part of a letter to Judge Alison J. Nathan dated December 5, 2021, presents an argument criticizing the government's handling of photographic evidence. The author contends that the government failed to properly authenticate 2019 photos as representative of a scene from 1994-1996 by not showing them to a witness named Jane during her testimony. The document dismisses the government's rationale that doing so would have diminished the photos' value as independent corroboration, suggesting the real reason was a fear that Jane's response would not support their case.
DOJ-OGR-00008226.jpg
This legal document, dated December 5, 2021, is a filing to Judge Alison J. Nathan arguing against the admissibility of interior photographs of Mr. Epstein's apartment. The author contends the photos, taken in 2019, cannot be proven to accurately represent the apartment's state during the charged conspiracy, which ended in 2004. The document highlights that the government's case for the photos' relevance relies solely on the testimony of a witness, "Jane," who described the apartment's interior based on her memory from an alleged visit in the mid-1990s.
DOJ-OGR-00008224.jpg
This legal document, filed on December 5, 2021, is a request from the U.S. Government to the Court in case 1:20-cr-00330-PAE. The Government proposes a specific limiting instruction for the jury to be read before a witness, identified as "Witness-3," testifies. The instruction aims to prevent prejudice by clarifying that any testimony about sexual conduct between Witness-3 and Mr. Epstein is not part of the charged crimes and cannot be used to judge the character or propensity of either Mr. Epstein or Ms. Maxwell.
DOJ-OGR-00008217.jpg
This legal document, part of Case 1:20-cr-00330-PAE, discusses the testimony of a witness named Jane regarding a massage room where she was allegedly sexually abused. The Government argues that photographs presented as exhibits corroborate Jane's detailed descriptions of the room's size, features, and the house's artwork, thereby establishing their relevance to the case. The document acknowledges the Court's concern about the lack of testimony directly comparing the photos to the room's state during the conspiracy but asserts that most of Jane's testimony concerns non-movable features.
DOJ-OGR-00008207.jpg
This legal document is page 2 of a filing to Judge Alison J. Nathan, dated December 3, 2021. The author argues that the government cannot use attorney-client privilege to prevent Ms. Maxwell's team from cross-examining a witness named Jane about a statement her attorney, Mr. Glassman, made to her. The filing contends the privilege does not apply because the communication was not intended to be confidential and, in any case, was waived when it was relayed to the government.
DOJ-OGR-00001926.jpg
This legal document discusses cases involving Khashoggi, Bodmer, Hanson, and Sabhnani. It mentions a defendant who is a citizen of England and France and has three passports, and the document discusses the defendant's international travel and financial means.
DOJ-OGR-00001923.jpg
This document is a page from a court transcript dated December 10, 2020. An attorney argues during a bail hearing, dismissing the government's evidence concerning a threat from a 'Ms. Moe' as irrelevant 'spin' not connected to their client, 'Ms. Maxwell'. The attorney then pivots to the legal standard for pretrial release, quoting statute 3142 to argue for release under the least restrictive conditions.
DOJ-OGR-00001899.jpg
This document is a court transcript from a hearing on December 10, 2020, in case 1:20-cr-00330-AJN. The judge rules to set a firm trial date for July 12, 2021, justifying the delay as necessary for discovery and preparation, and finding it serves the ends of justice. The court then prepares to hear arguments regarding the government's motion for the defendant's detention.
DOJ-OGR-00001890.jpg
This document is a page from a court transcript dated December 10, 2020, from Case 1:20-cr-00330-AJN. A representative for the government informs the judge that they are prepared for discovery and have collaborated with defense counsel on a proposed schedule for the trial. The government representative emphasizes their commitment to a thorough review of materials, including an ongoing privilege review of electronic data, and mentions the bulk of materials will be produced by the end of summer. The judge then begins to question the representative about issues with complete disclosure seen in other cases.
DOJ-OGR-00001871.jpg
This legal document, a letter from the law office of Bobbi C. Sternheim, argues that their client, Ghislaine Maxwell, is being subjected to "draconian" and punitive pretrial detention conditions. The letter posits that these harsh measures are not related to Maxwell's own conduct but are a direct result of the government's attempt to repair its reputation following the suicide of Jeffrey Epstein in federal custody. The attorney details failed attempts to resolve these issues through internal prison channels and claims the conditions are impeding Maxwell's ability to prepare her legal defense.
DOJ-OGR-00001864.jpg
This legal document, dated November 25, 2020, is a letter to Judge Alison J. Nathan arguing for the sealing of information related to Ms. Maxwell's bail application. The author contends that the privacy of Ms. Maxwell's sureties (co-signers) and other third parties outweighs the public's right to access, citing fears of harassment and legal precedent from cases like U.S. v. Amodeo and U.S. v. Nejad. The filing requests an in-camera conference to discuss the redaction of the sureties' names and other confidential materials.
DOJ-OGR-00001856.jpg
This legal document is a letter to Judge Alison J. Nathan, dated November 30, 2020, arguing for the redaction of the identities of individuals supporting Ms. Maxwell's bail application. The letter contends that public disclosure would violate their privacy and expose them to significant personal and physical danger, citing stalking by the tabloid press, physical threats, and the intense public opprobrium surrounding the case. It references legal precedent from United States v. Amodeo to support the court's power to protect innocent third parties from public scandal.
DOJ-OGR-00001836.jpg
This document is the second page of a filing from the United States Attorney's Office regarding the conditions of confinement for a defendant (implied to be Ghislaine Maxwell based on the case number) at the MDC. It details the schedule for legal calls, discovery review, and isolation, asserting that the defendant has more access than other inmates and that the Government is actively communicating with defense counsel regarding any concerns.
DOJ-OGR-00001830.jpg
This document is page 3 of a court filing (Case 1:20-cr-00330-AJN) filed on November 6, 2020, likely in the prosecution of Ghislaine Maxwell. The Government argues regarding discovery deadlines, agreeing to a laptop for the defendant to review evidence at the MDC but refusing early disclosure of witness lists (Giglio/Jencks material) seven months before trial. The text details upcoming discovery productions, specifically mentioning thousands of images/videos from Epstein's electronic devices, portions of seized iPads and an iPhone, and documents from the FBI's Florida files.
DOJ-OGR-00001823.jpg
This legal document, dated November 6, 2020, details a negotiation between defense counsel and the Government regarding an extension in case 1:20-cr-00330-AJN. The defense proposed four conditions for an extension, including extending motion deadlines and providing discovery materials and victim names. The Government agreed to only two of the conditions, resulting in an inability to reach an agreement on the requested two-week extension for production. The document is certified by Assistant United States Attorney Maurene Comey.
DOJ-OGR-00001822.jpg
This legal document is an affidavit filed on November 6, 2020, by Assistant U.S. Attorney Maurene Comey in the case of U.S. v. Ghislaine Maxwell. Comey certifies that the government attempted to negotiate in good faith with Maxwell's defense counsel for a two-week extension (from November 9 to November 23, 2020) for the production of documents seized from Jeffrey Epstein, but the parties were unable to reach an agreement. The extension was requested to allow an outside vendor to complete bates stamping and downloading of the electronic evidence.
DOJ-OGR-00001817.jpg
This is page 2 of a court order dated November 5, 2020, in case 1:20-cr-00330-AJN, signed by United States District Judge Alison J. Nathan. The order outlines the procedure for the Government to request modification of its disclosure obligations if there are concerns about witness safety, national security, or other interests. It also lists six potential sanctions the Court may impose if the Government fails to comply with the disclosure order, ranging from specifying production terms to dismissing charges.
DOJ-OGR-00001815.jpg
This document is the final page of a Government filing (dated Oct 30, 2020) regarding the detention conditions and discovery process for the defendant (Ghislaine Maxwell) at the Metropolitan Detention Center (MDC). The Government argues against the need for a court order regarding MDC issues, citing that protocols are already in place for passing papers, COVID-19 safety (Plexiglas barriers), and laptop viewing. The filing asserts that the defendant has access to discovery materials for approximately 13 hours a day—more than any other inmate—and details technical efforts to resolve file viewing issues mentioned in a footnote.
DOJ-OGR-00001810.jpg
This document is page 6 of a legal filing dated October 23, 2020, addressed to Judge Alison J. Nathan from Ghislaine Maxwell's defense team. The text details significant ongoing technical failures at the Metropolitan Detention Center (MDC) regarding Maxwell's ability to access discovery materials on provided hard drives. Despite multiple letters and conference calls between August and October 2020, the Government and MDC IT staff failed to provide a functional computer or readable files, severely impairing Maxwell's ability to prepare her defense.
DOJ-OGR-00001805.jpg
This document is a legal letter filed on October 23, 2020, by attorney Jeffrey Pagliuca on behalf of Ghislaine Maxwell, addressed to Judge Alison J. Nathan. The defense argues that the Government has failed to meet discovery deadlines promised during the July 14, 2020, initial conference, particularly regarding investigative files from the Southern District of Florida. The letter criticizes the Government's recent production as lacking substance, noting it consists largely of civil litigation documents and old records related to Jeffrey Epstein rather than the charged conspiracy.
DOJ-OGR-00001802.jpg
This page from a legal filing argues against the defense's position that a co-conspirator committing similar crimes without the defendant constitutes exculpatory evidence under Brady. The Government cites multiple Second Circuit precedents to establish that evidence of a defendant's non-participation in other criminal events or lawful conduct on other occasions is irrelevant to disproving specific charged crimes.
DOJ-OGR-00001799.jpg
This legal document is a letter dated October 14, 2020, from attorney Christian R. Everdell to Judge Alison J. Nathan. Everdell argues against the government's request to delay the disclosure of evidence to his client, Ms. Maxwell, in case 1:20-cr-00330-AJN. He asserts the government has not provided sufficient legal justification, such as risks to an ongoing investigation or witness safety, and asks the court to order the immediate production of the materials to the defense.
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