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 |
EFTA00019577.pdf
This document is an email chain from March and April 2019 involving an Assistant U.S. Attorney for the Southern District of New York and the chambers of Judge Sarah Netburn regarding the case 'Jane Doe 43 v. Epstein, et al.' The correspondence discusses the submission of a letter providing additional authority for a government application and a request from the Judge's chambers for a Word version of a Sealed Order.
EFTA00019402.pdf
This document is an email thread from August 15, 2019, circulating a Fox News article about the accidental release of serial bank robber Michael Matthews from the Metropolitan Correctional Center (MCC) just days before Jeffrey Epstein's death. The article highlights serious security failures and irregularities at the MCC, including quotes from Attorney General William Barr expressing anger at the facility's failures. It also includes comments from the lawyer of Epstein's former cellmate, Nicholas Tartaglione, describing conditions at MCC as inhumane and worse than Rikers Island.
EFTA00019029.pdf
This document contains an email thread from March 22, 2021, between Christian Everdell of Cohen & Gresser LLP and likely government prosecutors regarding the Ghislaine Maxwell case. The correspondence discusses a 'meet and confer' requirement ordered by Judge Nathan concerning redactions to 'Exhibit 11' and references a sealed document ('Exhibit H') from a civil docket before Judge Preska. The government (implied sender of the top email) asks Everdell if they wish to keep certain quotations redacted given they are sealed in the civil case.
EFTA00018992.pdf
This document is an email thread from attorney Bobbi C. Sternheim dated March 16, 2021. It serves as a transmittal for an unredacted Reply Memorandum in support of Ghislaine Maxwell's pending bail application, submitted to the Court and government pursuant to legal rules. The email includes Sternheim's contact information and standard confidentiality disclaimers.
EFTA00018263.pdf
This document is an internal email dated October 29, 2020, likely between prosecutors or government officials regarding the Ghislaine Maxwell case. The sender attaches a draft reply to a letter from Maxwell's defense team concerning discovery files from other agencies, along with copies of previous correspondence from October 7th and October 23rd.
EFTA00018167.pdf
An email chain from July 9, 2019, initiated by reporter Jeff Ostrowski of The Palm Beach Post. Ostrowski is inquiring with government officials (names redacted) about the indictment of Jeffrey Epstein, specifically asking if the government plans to pursue the forfeiture of the El Brillo Way property in Palm Beach, noting it was not specifically listed by address in the forfeiture clause. The email was forwarded internally among officials.
EFTA00018028.pdf
A court order from Judge Alison J. Nathan in the case of USA v. Ghislaine Maxwell, dated July 30, 2021. The order grants the Government's motion to require defense lawyer David Markus to comply with Local Criminal Rule 23.1 regarding extrajudicial statements, following an op-ed he published about the case. The judge ruled that although Markus had not formally appeared in the specific trial proceedings, his role as appellate counsel and public association with the defense made him subject to the rule.
EFTA00017864.pdf
This document is an email chain from August and September 2021 coordinating travel for a fact witness involved in the Ghislaine Maxwell trial. The emails discuss logistical requests for the witness to travel to the Southern District of New York (SDNY) for trial preparation meetings, specifically mentioning a meeting on August 20th, 2021. The names of the senders, recipients, and the witness are redacted.
EFTA00016461.pdf
This document is an email dated December 4, 2020, from an Assistant United States Attorney in the Southern District of New York to Judge Nathan's chambers. The email submits a letter from the Metropolitan Detention Center (MDC) legal counsel regarding the case US v. Maxwell (Ghislaine Maxwell) and notes that the government has no objection to the letter being publicly docketed despite not being filed on ECF by the MDC.
EFTA00016218.pdf
This document is an email from an Assistant United States Attorney in the Southern District of New York regarding the case US v. Maxwell. Dated March 23, 2021, it serves as a transmittal for attachments containing the Government's opposition to defense motions and proposed redactions for legal filings and exhibits.
EFTA00016206.pdf
This document is a motion in limine filed by Ghislaine Maxwell's defense team on October 18, 2021, seeking to exclude evidence offered by the government under Rule 404(b) due to lack of proper notice. The defense argues the government failed to identify specific evidence or articulate a non-propensity purpose for its admission. The motion references disputed evidence including emails between Maxwell and 'influential men' regarding dates, testimony from a former Epstein employee (2005-06) regarding 'sexualized massages,' and various exhibits including flight logs (GX-661 & 662) and financial statements.
EFTA00014876.pdf
An email dated November 23, 2021, discussing a draft letter regarding the witness order for the Ghislaine Maxwell trial (referred to as GM in the attachment). The sender explains their strategy for the witness list order, prioritizing the 'most likely' order over the 'order of proof' to reflect a realistic trial timeline. The document includes a Bates stamp EFTA00014876.
EFTA00014109.pdf
This document is an email chain from June 24-25, 2008, involving Assistant U.S. Attorneys and defense lawyers Roy Black and Jack Goldberger. The correspondence confirms the Government's stance that a binding plea agreement with Jeffrey Epstein is signed and requires no modification, while internal emails discuss a '2255 issue' and the upcoming Change of Plea (COP).
EFTA00013552.pdf
A 2008 email from a federal prosecutor arguing against delaying the Epstein case. The author cites expiring statutes of limitations for 5 of 16 indicted victims, the risk of losing the ability to prosecute for 'additional girls,' and the fact that the Grand Jury is ready to indict. The email reveals there are over 20 known child victims and mentions a 'state resolution' deal Epstein signed months prior.
EFTA00013220.pdf
This document is an email chain from October 2020 regarding legal proceedings involving Ghislaine Maxwell. A sender (redacted) forwards a communication from the law firm Cohen & Gresser LLP to another party (redacted), discussing letters received from 'Maxwell's counsel' concerning discovery and prison conditions. The sender proposes a meeting to discuss a draft response expected to be ready by the following Monday.
EFTA00013196.pdf
An email thread from October 25, 2020, between officials at the US Attorney's Office for the Southern District of New York (USANYS). The prosecutors are coordinating a schedule for a call the following day with Ghislaine Maxwell's defense team ('Maxwell team') to discuss discovery updates and a 'defense response' letter regarding other agency files. The final email confirms a 2:00 PM meeting time and circulates the PDF attachment of the defense's letter.
EFTA00011417.pdf
This document is an email chain from October 2020 involving the legal defense team of Ghislaine Maxwell (Christian Everdell, Mark Cohen, Laura Menninger, etc.). The email circulates a PDF attachment titled 'Letter to Government re Rule 16 and Brady Requests,' indicating legal maneuvering regarding evidence disclosure and discovery requests in a federal case.
EFTA00011162.pdf
This document is an email dated October 18, 2021, sent to a recipient at the US Attorney's Office for the Southern District of New York (USANYS). The email concerns 'Revised MILs' (Motions in Limine), attaching version 7 of the Government's MIL document and a redline comparison. The sender notes that the 'paras' (paralegals) are unavailable to assist with citechecking.
EFTA00002171.pdf
This document is a photograph of several identification papers belonging to Phillip Anthony Baker (New Zealand) and Janice Indino Salazar (Philippines). The collection includes passports, a New Zealand driver's license, a BDO debit card, a US Social Security card, and Philippine civil registry documents (birth and marriage certificates). The marriage certificate confirms a spousal relationship between Baker and Salazar.
DOJ-OGR-00000253.tif
This document discusses legal arguments related to a Non-Prosecution Agreement (NPA) concerning Epstein, highlighting the government's perceived misinterpretation of the agreement and the findings of an OPR investigation into its execution. It asserts that Maxwell has standing to enforce the NPA as a third-party beneficiary because she falls within the class of 'any potential co-conspirators of Epstein' that the agreement was designed to protect.
DOJ-OGR-00000151.tif
This document excerpt discusses discovery procedures in a criminal case involving Maxwell, noting the complexity due to decades-old allegations and multiple locations. It highlights the Government's proposed disclosure schedule, providing Maxwell six weeks to review witness statements and mentioning a production of over 20,000 pages of materials on April 13, 2021. The document also addresses Maxwell's request for early disclosure of Rule 404(b) evidence, outlining the prosecutor's obligation to provide notice of intent to use such evidence at least 45 days in advance of trial.
DOJ-OGR-00000147.tif
This legal document addresses discovery disputes in a case involving 'Maxwell.' It details Maxwell's motion to compel the Government to produce various types of evidence, including Jencks Act, Brady, and Giglio material. The Court rules that while Maxwell is not entitled to expedited discovery, the parties must confer on a pretrial disclosure schedule, and the Court accepts the Government's assertion that it has already disclosed all required Brady and Giglio material, citing relevant Supreme Court precedents.
DOJ-OGR-00000144.tif
This document discusses a court's decision regarding severance of charges and a motion to strike surplusage in a case involving 'Maxwell'. The court favors severing perjury counts from other charges, including Mann Act counts, to ensure a fair and expeditious trial, and declines Maxwell's motion to strike certain allegations from the superseding indictment as premature. The document references several legal precedents including States v. Cunningham, Kross, Gaudin, and United States v. Casamento.
DOJ-OGR-00000141.tif
This legal document discusses perjury charges against Maxwell, concluding that they are legally tenable but should be severed and tried separately from Mann Act counts to avoid undue prejudice. It references legal precedents and argues that Maxwell's statements in a civil case about sex trafficking and sexual abuse allegations could have led to the discovery of other evidence or influenced the factfinder, thus supporting the perjury charges.
DOJ-OGR-00000140.tif
This document is a legal excerpt, likely from a court order or memorandum, discussing motions filed by 'Maxwell.' The Court addresses Maxwell's arguments for dismissing charges, stating her motion is premature and that determining truth, falsity, and materiality of statements are typically jury functions. The document cites several legal precedents to support the Court's position that Maxwell's statements could be considered material and that her arguments for dismissal are not sufficient at this stage.
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