GOVERNMENT
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Minor Victims
|
Protective |
7
|
2 | |
|
person
crime victim
|
Legal representative |
6
|
1 | |
|
person
MR. ROHRBACH
|
Representation |
6
|
2 | |
|
person
Epstein
|
Prosecution defendant |
6
|
1 | |
|
organization
district court
|
Legal representative |
6
|
2 | |
|
person
Susan Brune
|
Legal representative |
6
|
1 | |
|
person
MDC legal counsel
|
Professional |
6
|
1 | |
|
organization
BOP
|
Institutional |
6
|
2 | |
|
person
defendant
|
Adversarial professional |
6
|
1 | |
|
person
Ms. Sternheim
|
Professional |
6
|
2 | |
|
person
Catherine Conrad
|
Legal representative |
6
|
1 | |
|
organization
BSF
|
Professional |
6
|
1 | |
|
person
Mr. Everdell
|
Professional |
6
|
1 | |
|
person
Ms. Maxwell’s Counsel
|
Professional adversarial |
6
|
2 | |
|
person
Meder
|
Professional |
6
|
2 | |
|
person
MAXWELL
|
Adversarial investigative |
6
|
1 | |
|
person
Kimberly Meder
|
Witness |
6
|
1 | |
|
person
Kate
|
Legal representative |
6
|
2 | |
|
person
MS. POMERANTZ
|
Professional |
6
|
2 | |
|
person
Ms. Maxwell
|
Adversarial prosecutor defendant |
6
|
2 | |
|
person
Minor Victim-4
|
Legal representative |
6
|
1 | |
|
person
Epstein's Victims
|
Professional |
6
|
1 | |
|
person
Defendant (Maxwell)
|
Adversarial |
6
|
2 | |
|
person
Mr. Kelso
|
Professional potential rebuttal witness |
6
|
1 | |
|
person
Mr. Flatley
|
Professional witness |
6
|
1 |
| 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-00001785.jpg
This document, a court filing from October 6, 2020, outlines charges against Maxwell, including enticing and transporting minors for illegal sex acts, and perjury, with conduct dating between 1994 and 1997. It details the Government's handling of 'Materials' (documents and photographs) related to a broader investigation into Epstein's sexual abuse of minors, explaining that while these materials post-date the indictment's period and won't be used as direct trial evidence, they will be produced to the defense under a protective order due to victim identification concerns and ongoing investigation risks.
DOJ-OGR-00001768.jpg
This legal document is a letter dated August 24, 2020, from Jeffrey S. Pagliuca to Judge Alison J. Nathan. Pagliuca argues on behalf of his client, Ms. Maxwell, for a limited request to present sealed materials to other judicial officers, asserting that the materials are judicial documents and that disclosure would not compromise grand jury secrecy. The letter contends that the government has failed to provide a sufficient reason to prevent this limited disclosure.
DOJ-OGR-00001757.jpg
This is page 6 of a legal document dated August 17, 2020, filed in a case before Judge Alison J. Nathan. The filing argues on behalf of Ms. Maxwell for the modification of a Protective Order, claiming that secrecy surrounding a government investigation and grand jury subpoena has undermined the fairness of the adversarial process and unfairly disadvantaged her.
DOJ-OGR-00001756.jpg
This legal document is page 5 of a filing on behalf of Ms. Maxwell to Judge Alison J. Nathan, dated August 17, 2020. The filing argues that the government has violated the spirit of a Protective Order by its handling of discovery materials, particularly in relation to their potential use in civil litigation and a grand jury investigation. The defense cites previous assurances from the government and a letter from Alex Rossmiller, which the Court relied upon, to argue that a new request should be granted by the Court.
DOJ-OGR-00001753.jpg
This is page 2 of a legal filing from August 17, 2020, in case 1:20-cr-00330-AJN, addressed to Judge Alison J. Nathan. The document concerns a dispute over materials designated as 'Confidential' by the government, arguing that under Second Circuit precedent, they are 'judicial documents' with a right to public access. It states that Ms. Maxwell has objected to the designation and seeks to provide the materials under seal to judicial officers to resolve pending issues.
DOJ-OGR-00001750.jpg
This page from a court document outlines the procedural history regarding the modification of civil protective orders to comply with criminal grand jury subpoenas. It details the Court's decision to permit the defendant to provide specific information under seal to other relevant courts (Court-1 and Court-2) to determine if materials should be unsealed.
DOJ-OGR-00001749.jpg
This document is page 3 of a court order filed on September 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Defendant's request to modify a protective order to disclose documents to judicial officers in other civil cases, citing a lack of good cause and noting that the relevant facts are already public. The text reveals that the Government previously issued grand jury subpoenas to an entity referred to as 'Recipient' regarding an investigation into Jeffrey Epstein and his co-conspirators.
DOJ-OGR-00001748.jpg
This document is page 2 of a court order filed on September 2, 2020, in case 1:20-cr-00330-AJN. The court denies the defendant's request to modify a protective order that was previously entered on July 30, 2020. The court's decision is based on the original agreement between the parties, which stipulated that discovery materials provided by the government would be used solely for the defense of the current criminal case and not for any civil proceedings.
DOJ-OGR-00001741.jpg
This document is a letter motion dated August 24, 2020, from attorney Laura A. Menninger to Judge Alison J. Nathan of the Southern District of New York. The attorney requests permission to file documents under seal on behalf of her client, Ghislaine Maxwell, in the case of United States v. Ghislaine Maxwell. The justification for the request is that the documents contain information designated as confidential by the Government under the terms of the existing Protective Order in the case.
DOJ-OGR-00001740.jpg
This document is the final page of a legal filing from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan, dated August 21, 2020. The Government respectfully requests that the Court schedule a date approximately 180 days in the future for them to provide an update on their position regarding the sealing of documents in case 1:20-cr-00330-AJN. The filing is submitted by Acting U.S. Attorney Audrey Strauss and her assistants Maurene Comey, Alison Moe, and Lara Pomerantz.
DOJ-OGR-00001739.jpg
This document is page 3 of a legal filing (Document 47 in Case 1:20-cr-00330-AJN) from the Government to Judge Alison J. Nathan, dated August 21, 2020. The Government argues for the redaction and sealing of a 'Defense Letter' and its exhibits, citing an active and ongoing grand jury investigation that resulted in new charges the previous month. The Government requests that both the unredacted Defense Letter and the instant letter be filed under seal to protect the integrity of the investigation.
DOJ-OGR-00001738.jpg
This document is page 2 of a legal filing dated August 21, 2020, addressed to the Honorable Alison J. Nathan. The author, presumably the Government, argues for keeping grand jury-related exhibits under seal by citing historical precedent for grand jury secrecy and analyzing the First Amendment's presumptive right of public access. The filing references multiple court cases to support the position that sealing is justified and necessary to protect higher values, even when a presumptive right of access applies.
DOJ-OGR-00001723.jpg
This legal document, filed on August 13, 2020, is a response from the U.S. Attorney's Office for the Southern District of New York to a defendant's requests regarding housing and access to discovery. The prosecution argues that the defendant's application is moot because the Bureau of Prisons (BOP) has already granted the defendant extensive daily access to discovery materials from 7:00 a.m. to 8:00 p.m. The document concludes by requesting that the defendant's application be denied.
DOJ-OGR-00001721.jpg
This legal document is a filing by the Government to Judge Alison J. Nathan in a criminal case, dated August 13, 2020. The Government argues that the defendant's request for more detailed charges is premature and should be handled through a formal motion for a bill of particulars after discovery is complete. The filing also expresses significant concern over the defense counsel's recent actions in a related civil case, suggesting they may have violated a protective order by publicly referencing sealed discovery materials.
DOJ-OGR-00001716.jpg
This document is a letter from Ghislaine Maxwell's defense counsel to Judge Alison J. Nathan dated August 10, 2020. The defense requests the disclosure of the identities of 'Victims 1-3' to prepare for trial and argues that Maxwell is being subjected to uniquely harsh confinement conditions at the MDC as a direct reaction to the BOP's failure to prevent Jeffrey Epstein's suicide in 2019. The letter details Epstein's timeline of detention and death to contextualize the extreme surveillance and isolation Maxwell is facing.
DOJ-OGR-00001699.jpg
This document is page 10 of a court order filed on July 30, 2020, in case 1:20-cr-00330-AJN. It details strict regulations for the handling of confidential discovery materials by the Defendant and their legal team, prohibiting dissemination, copying, and public filing unless authorized in writing by the Government or by a specific Order of the Court. The order also specifies that information identifying victims or witnesses is an exception and should not be disclosed.
DOJ-OGR-00001698.jpg
Page 9 of a court order (Protective Order) from case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The document defines 'Highly Confidential Information' as materials containing sexualized images of individuals and outlines the strict limitations on its use, specifically prohibiting use in civil proceedings. It also establishes the protocol for the Defense Counsel to challenge the Government's classification of such materials.
DOJ-OGR-00001697.jpg
Page 8 of a Protective Order filed on July 30, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The document outlines strict protocols for the Defendant's review of discovery materials, mandating supervision by Defense Counsel or BOP officials, and defines the handling of 'Highly Confidential Information,' prohibiting the dissemination of copies to potential witnesses.
DOJ-OGR-00001695.jpg
This is page 6 of a court filing (Document 36) from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 30, 2020. The document outlines protocols for handling 'Confidential Information' during discovery, specifically regarding the protection of PII for victims and witnesses, while noting that victims who have publicly identified themselves on the record are exempt from this confidentiality. It also establishes the procedure for Defense Counsel to challenge confidentiality designations made by the Government.
DOJ-OGR-00001688.jpg
This legal document is page 4 of a filing from Ms. Maxwell's defense team to Judge Alison J. Nathan, dated July 29, 2020. The defense argues that the government's proposed protective order would improperly restrict their ability to investigate and prepare for trial by limiting contact with witnesses, including accusers who have already publicly identified themselves. The defense also refutes the government's interpretation of their own proposed order, clarifying its intended scope and purpose.
DOJ-OGR-00001683.jpg
This document is an Affidavit of Certification filed on July 28, 2020, in the criminal case of U.S. v. Ghislaine Maxwell. Assistant U.S. Attorney Alex Rossmiller affirms that the prosecution and defense have conferred on a proposed protective order but have been unable to resolve two areas of dispute. The first point of contention involves the defense's objection to the government's proposal regarding the referencing of witness and victim identities.
DOJ-OGR-00001680.jpg
This document is a page from a court order filed on July 28, 2020, detailing the strict rules and procedures for the handling of confidential and highly confidential information by the defendant and their legal team. It prohibits the public filing of discovery materials unless explicitly authorized by the Government or by a court order, and specifies that materials must be reviewed under controlled conditions. The order aims to protect sensitive information, including victim and witness identities, during legal proceedings.
DOJ-OGR-00001679.jpg
This document is page 9 of a court filing (Document 33-1) from Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on July 28, 2020. It outlines the protocols for handling 'Highly Confidential Information,' specifically defining it as materials containing sexualized images of individuals. It establishes that such information is to be used solely for the criminal defense and not for any civil proceedings.
DOJ-OGR-00001670.jpg
This legal document, filed on July 28, 2020, is the U.S. Government's response to a defendant's motion in a criminal case. The Government argues against the defendant's attempt to restrict its use of gathered materials and to impose restrictions on third parties, calling the request unprecedented and without legal basis. The filing, submitted by Acting U.S. Attorney Audrey Strauss to Judge Alison J. Nathan, urges the court to deny the defendant's motion and implement the Government's own proposed protective order.
DOJ-OGR-00001667.jpg
This document is a page from a government filing addressed to Judge Alison J. Nathan in the case against Ghislaine Maxwell. The text argues against the defendant's broad proposal for a protective order, asserting that it would unfairly expose victims who made minor public statements years ago to intense public scrutiny without their consent. The government contends this is unnecessary for defense preparation and inconsistent with the Crime Victims' Rights Act.
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