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-00003140.jpg
This legal document, page 206 of a court filing from April 16, 2021, is part of the government's argument against a defendant's motion. It contends that the indictment is sufficiently detailed, outlining the defendant's role in grooming three minor girls for sexual activity with Epstein in Florida, New Mexico, New York, and London between 1994 and 1997. The document also references the defendant's alleged perjury during a 2016 civil deposition and cites case law to support the legal sufficiency of the indictment.
DOJ-OGR-00003139.jpg
This legal document is a portion of a court filing by the prosecution (the "Government") arguing against the defendant's request for a "bill of particulars." The Government contends that the existing 18-page Indictment provides sufficient detail about the charges, which involve conspiracies with Jeffrey Epstein to traffic minors between 1994-1997 and a subsequent cover-up during a 2016 deposition. Citing legal precedents, the prosecution argues that providing more detail would unfairly restrict its case and could allow the defendant to tailor her testimony.
DOJ-OGR-00003138.jpg
This document is a page from a legal filing, dated April 16, 2021, arguing against the misuse of a 'bill of particulars'. It cites numerous court cases to establish the legal precedent that a bill of particulars is not a tool for the defense to compel the Government to disclose its evidence, witnesses, or trial strategy. The document asserts that such a bill is only warranted when an indictment is so vague that it prevents the defendant from preparing a defense.
DOJ-OGR-00003137.jpg
This document is page 203 of a legal filing (Document 204) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal arguments citing various precedents (Bortnovsky, Mandell, Levy, etc.) to support the Government's position that providing voluminous discovery negates the need for a 'bill of particulars,' arguing that the defense is not entitled to a preview of the Government's legal theories, only what is strictly necessary for defense preparation.
DOJ-OGR-00003135.jpg
This legal document is a filing by the prosecution (the Government) in the criminal case against the defendant, Maxwell. The Government argues that Maxwell's various motions for disclosure, including a request for a bill of particulars, should be denied as they are meritless or premature. The prosecution asserts that it has already provided sufficient information through the indictment and discovery, and that the defendant is not entitled to the requested details under established law.
DOJ-OGR-00003124.jpg
This document is page 190 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The Government argues against striking allegations related to 'Minor Victim-3,' asserting that her testimony regarding grooming and sex acts in London is probative of the defendant's intent and the conspiracy with Jeffrey Epstein, even if potential statute of limitations issues exist for specific charges. The document emphasizes that the evidence establishes the relationship between the defendant and Epstein.
DOJ-OGR-00003123.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, argues that the indictment against the defendant is valid. The prosecution asserts that the defendant's alleged actions of recruiting and grooming 'Minor Victim-3' for 'Epstein' constitute sufficient evidence of participation in a conspiracy, even if the substantive crime of transporting a minor was not completed. A footnote addresses a defense objection to the term 'abuse,' noting that while Minor Victim-3 may have been over the age of consent in the United Kingdom for some acts, she will testify to the traumatic nature of the experience.
DOJ-OGR-00003122.jpg
This document is a page from a legal filing arguing against a defendant's motion to strike allegations concerning 'Minor Victim-3'. The prosecution asserts that evidence regarding this victim is relevant and admissible for proving the conspiracies charged in Counts One and Three involving Epstein, citing established conspiracy law.
DOJ-OGR-00003115.jpg
This legal document, filed on April 16, 2021, is a portion of a legal argument defending an indictment against a motion to dismiss. The argument asserts that using pseudonyms for minor victims and providing an approximate date range (1994-1997) for the alleged crimes is legally sound, citing precedents like Stringer, Kidd, and Stavroulakis. It further argues the defendant is not prejudiced, as the government has provided and will provide specific details, such as victim birth information and witness names, during discovery.
DOJ-OGR-00003110.jpg
This legal document is a portion of a prosecution filing arguing against a motion by the defendant, Ms. Maxwell, to sever perjury charges from other substantive counts (Mann Act). The prosecution contends that trying the counts together is judicially efficient, not unduly prejudicial, and that the defendant's claims of prejudice are generalized and can be managed with jury instructions. The filing also dismisses the defendant's concern that her attorneys from a prior civil suit might be called to testify, arguing it does not meet the threshold for disqualification.
DOJ-OGR-00003108.jpg
This legal document is a portion of the prosecution's (the Government's) argument against a defendant's motion to sever perjury counts from other charges. The Government contends that a full re-litigation of a prior defamation action is not necessary and that any potential for 'spillover prejudice' can be managed through stipulations, using a pseudonym for a witness (Giuffre), and providing limiting instructions to the jury. The document cites several legal precedents to support the argument that juries are presumed to follow such instructions.
DOJ-OGR-00003103.jpg
This page from a legal filing argues against severing the indictment into separate trials, positing that evidence relevant to perjury counts (Count Six) is inextricably linked to the conspiracy charges (Counts One through Four). The Government contends that a joint trial is necessary to avoid forcing a minor victim (Minor Victim-2) to testify twice about sexual abuse and argues that the defendant's false statements demonstrate a consciousness of guilt relevant to all charges.
DOJ-OGR-00003098.jpg
This legal document is a filing arguing against a defendant's motion to dismiss a perjury charge. The prosecution contends that the defendant's false statements in a deposition for the 'Giuffre v. Maxwell' civil suit were material, as truthful answers could have corroborated claims that the defendant and Epstein recruited Giuffre and could have led to other victims or witnesses. The filing asserts that the issue of materiality is a question for the jury and should not be decided by the court at this stage.
DOJ-OGR-00003089.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents an argument that a jury could find the defendant's testimony to be false. The prosecution argues that the defendant, likely Maxwell, falsely claimed to be unaware of any minors at Jeffrey Epstein's properties besides Giuffre, contradicting an indictment alleging interactions with 'Minor Victim-1'. The document refutes the defense's claims that the questions were ambiguous or improper, citing the defendant's own statements that the events in question 'never happened'.
DOJ-OGR-00003078.jpg
This legal document, filed on April 16, 2021, provides the factual background for a case, detailing how Virginia Roberts Giuffre joined a lawsuit concerning a non-prosecution agreement with Epstein. Giuffre alleged that the defendant was a "primary co-conspirator" who procured underage girls for Epstein and participated in sexual abuse. The document cites Giuffre's specific allegations that the defendant persuaded her to go to Epstein's mansion and was involved in a sexual encounter there.
DOJ-OGR-00003077.jpg
This document is page 143 of a legal filing by the Government in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. The text argues against granting the defendant an evidentiary hearing regarding a 'Franks' analysis and asserts that the defendant failed to meet the burden of proof to obtain discovery or dismiss perjury counts. The Government contends that a jury should decide whether the defendant committed perjury during two depositions in a prior civil matter.
DOJ-OGR-00003072.jpg
This legal document argues that a district court's supervisory authority to suppress evidence is limited and should only be used when there is a clear violation of constitutional, statutory, or procedural law. Citing multiple legal precedents, the author contends that this power must be 'sparingly exercised' and that the defendant in this case has not established such a violation, and is therefore not entitled to an evidentiary hearing to challenge the government's actions.
DOJ-OGR-00003069.jpg
This document is page 135 of a legal filing (Case 1:20-cr-00330-PAE, U.S. v. Ghislaine Maxwell) dated April 16, 2021. It argues that the current case is distinguishable from past precedents regarding prosecutorial misconduct and the misuse of false evidence. The text asserts that the defendant has not been deprived of a fair trial and notes that a jury will determine if her statements during April and July 2016 depositions were perjurious.
DOJ-OGR-00003064.jpg
This legal document is a filing by the Government arguing against the defendant's (Maxwell's) claims. The Government refutes the defendant's assertion that she was protected by a civil protective order when giving deposition testimony, citing case law (e.g., Andover Data Servs., Davis) to establish that such orders do not provide the same protections as the Fifth Amendment. The document also dismisses the defendant's claim that the Government's conduct violated her due process rights as "meritless."
DOJ-OGR-00003063.jpg
This document page is from a legal filing in the case United States v. Ghislaine Maxwell (1:20-cr-00330). The text presents a legal argument distinguishing the current case from *United States v. Oshatz*, specifically regarding the enforceability of subpoenas for deposition transcripts and protective orders. It cites Chief Judge McMahon's finding that the Government demonstrated 'extraordinary circumstances' justifying the modification of a protective order, unlike in *Oshatz* where the government was characterzied as 'trolling for evidence'.
DOJ-OGR-00003060.jpg
This document is page 126 of a legal filing (Document 204) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal arguments regarding the 'state action' doctrine and the Fifth Amendment, specifically addressing whether a private entity acts as a government agent. The document explicitly argues that the law firm Boies Schiller is not an agent of the Government and that the defendant's claim fails for lack of demonstrated state action.
DOJ-OGR-00003059.jpg
This legal document, page 125 of a court filing from April 16, 2021, discusses the application of the Fifth Amendment privilege against self-incrimination to the act of producing documents. It cites several legal precedents to argue that the privilege only applies when the act of production itself is testimonial and incriminating, not merely because the documents' contents are incriminating. The document further asserts that the Fifth Amendment is primarily concerned with protecting individuals from governmental coercion, not from other moral or psychological pressures.
DOJ-OGR-00003048.jpg
This document is a page from a legal filing, dated April 16, 2021, that discusses the application of the Fourth Amendment's exclusionary rule. It cites numerous federal court cases, including from the Supreme Court, to argue that suppressing evidence is a 'last resort' intended to deter deliberate, reckless, or grossly negligent police misconduct. The text emphasizes the 'good-faith' exception, particularly when law enforcement acts in reasonable reliance on a search warrant, suggesting that suppression is generally not warranted in such cases.
DOJ-OGR-00003043.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, argues that a Fourth Amendment motion by an individual named Maxwell should be dismissed. The core argument is that Maxwell lacks legal standing to make the claim because she had no legitimate expectation of privacy in the files of a third-party law firm that represented her adversary in a separate civil litigation. The document cites numerous legal precedents to support the position that Fourth Amendment rights are personal and cannot be asserted on behalf of others.
DOJ-OGR-00003042.jpg
This document is a legal filing, likely from the Government, arguing against a motion by a defendant named Maxwell to suppress evidence. The Government contends that Maxwell has no legal basis for suppression under the 'Martindell' precedent and that the court should decline to review a prior, coequal judge's (Chief Judge McMahon) decision to modify a protective order. The filing cites several Second Circuit cases to support its position that suppression is not the proper remedy and that pre-existing documents are not covered by the protective order's presumptions.
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