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-00003041.jpg
This legal document is a page from a court filing, likely a motion from the defendant, Maxwell. The text argues against the Government's position by citing legal precedents like Palmieri and Martindell and contrasting the differing rulings of two judicial officers, Judge Netburn and Chief Judge McMahon, on the matter of sealing orders and grand jury secrecy. The core issue revolves around whether exceptional circumstances exist to justify the Government's actions, with Maxwell siding with Judge Netburn's finding that the Government's arguments were 'unpersuasive'.
DOJ-OGR-00003039.jpg
This document is a page from a legal filing, dated April 16, 2021, discussing legal precedents concerning the modification of protective orders in the face of a grand jury subpoena. It cites several Second Circuit cases, including Martindell and Davis, to argue that a grand jury's broad investigative powers often outweigh a party's reliance on a protective order, particularly for pre-existing documents. The text emphasizes that the need for a grand jury to gather evidence in a criminal investigation is a powerful reason to permit modification of such orders.
DOJ-OGR-00003037.jpg
This legal document is the Government's response arguing against Defendant Maxwell's motion to suppress evidence. The Government asserts that it lawfully obtained materials from the law firm Boies Schiller via a grand jury subpoena, following the correct legal procedure under the Martindell precedent by getting judicial authorization to modify a protective order. The document contends that Maxwell's motion is based on incorrect facts and law and should therefore be denied.
DOJ-OGR-00003034.jpg
This legal document details a ruling by Chief Judge McMahon concerning a government investigation related to a civil lawsuit between Giuffre and Maxwell. The judge concluded that Giuffre's law firm, Boies Schiller, did not improperly instigate the government's investigation and, due to "extraordinary circumstances," granted the government's request to access certain materials previously under a protective order. The ruling permitted the Government to share a specific court order with Boies Schiller to aid its investigation.
DOJ-OGR-00003033.jpg
This legal document describes a ruling made on April 9, 2019, by Chief Judge McMahon, who granted the Government's application to modify a protective order. The judge analyzed the case using Martindell factors and Second Circuit case law, concluding that while the order was necessary for Giuffre to depose Maxwell, Maxwell's reliance on it to shield information from law enforcement was unreasonable. Ultimately, the judge granted the government's application for modification.
DOJ-OGR-00003031.jpg
This legal document page, filed on April 16, 2021, details discussions from an April 9, 2019 hearing. Chief Judge McMahon questions the Government's request for materials from a civil libel case involving Maxwell, expressing concerns about potential criminal proceedings and the invocation of the Fifth Amendment. The judge also probes into prior contacts between the U.S. Attorney's Office (USAO-SDNY) and the law firm Boies Schiller related to the investigation.
DOJ-OGR-00003025.jpg
This legal document, filed on April 16, 2021, recounts events from 2016 concerning the civil litigation between Giuffre and Maxwell. It details the process of establishing a protective order for discovery materials, initiated by Maxwell's motion on March 2, 2016, contested by Giuffre's counsel (Boies Schiller), and ultimately entered by Judge Robert W. Sweet on March 18, 2016. The document also asserts that the USAO-SDNY did not open an investigation into Epstein or Maxwell in 2016 and that the government has no record of email communication between AUSA-1 and Boies Schiller attorneys after May 3, 2016.
DOJ-OGR-00003018.jpg
This legal document, filed on April 16, 2021, is a rebuttal to a defendant's accusation that the Government delayed an indictment for tactical advantage. The author contrasts the Government's decision to stay the civil case of *Doe v. Indyke* with its inaction in the settled case of *Giuffre v. Maxwell*, arguing the different procedural postures and the risk of witness deposition in the active *Doe* case justified the different legal strategies. The document asserts that the Government's actions were logical and not part of a conspiracy to gain an advantage in the criminal case.
DOJ-OGR-00003017.jpg
This document is a page from a legal filing in which the prosecution (Government) argues against a motion by the defendant, Maxwell, to dismiss her indictment due to pre-indictment delay. The Government cites several legal precedents (Pierre-Louis, Burke, Carbonaro) to argue that the defendant has failed to show the delay was improper or for a tactical advantage. The document also addresses Maxwell's specific claim that the Government delayed the indictment to benefit from a separate civil litigation involving Giuffre, a claim the Government refutes.
DOJ-OGR-00003016.jpg
This legal document is a filing by the Government arguing that there was no due process violation regarding the timing of an indictment. The Government contends that the delay was justified because two critical witnesses, Minor Victim-1 and Minor Victim-3, only came forward to be interviewed in August and September 2019, less than a year before the indictment was sought in June 2020. The document cites legal precedents to support the position that delays caused by witness unavailability are permissible and that prosecutors can wait until an investigation is complete before seeking charges.
DOJ-OGR-00003015.jpg
This legal document is a section of a government filing arguing against a defendant's motion to dismiss charges due to pre-indictment delay. The government contends that the defendant has not shown the delay was an intentional strategic tactic, citing legal precedents like Lovasco to support that investigative delays are permissible. The filing refutes the defendant's timeline, stating the relevant investigation into Epstein and his co-conspirators began in late 2018, not decades prior.
DOJ-OGR-00003014.jpg
This document is page 80 of a legal filing (Document 204) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. The text presents legal arguments regarding the dismissal of an indictment due to pre-indictment delay, citing numerous Second Circuit precedents (such as Cornielle, Alameh, and Delacruz) to establish that a defendant must prove the Government intentionally delayed specifically to gain a 'tactical advantage.'
DOJ-OGR-00003008.jpg
This legal document is a filing that argues against a defendant's motion. The defendant claims that testimony from Michael Casey (agent for Minor Victim-1) and Detective Recarey would have been exculpatory. The filing counters that this proposed testimony is speculative, unsubstantiated, likely inadmissible hearsay, and ultimately irrelevant to the charges that the defendant assisted Epstein in the grooming and abuse of other victims.
DOJ-OGR-00003003.jpg
This legal document is a portion of a government filing arguing against a defendant's motion to dismiss charges based on pre-indictment delay. The government asserts that the defendant has failed to meet the two-prong test required by the Second Circuit: demonstrating actual prejudice and proving the delay was for an improper government purpose. The filing cites several legal precedents to support its position that the defendant's due process claim is meritless and should be denied.
DOJ-OGR-00002983.jpg
This legal document is a portion of a court filing arguing against a defendant's motion for an evidentiary hearing. The author contends that the defendant has failed to provide sufficient evidence, such as affidavits, to establish a genuine factual dispute that would warrant a hearing. The filing contrasts the current defendant's lack of evidence with several precedent cases (Aleman, Sattar, Feldman) where hearings were granted because defendants submitted supporting affidavits or made uncontested assertions.
DOJ-OGR-00002978.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents the government's argument against defendant Maxwell's motion to dismiss an indictment. The government contends that a Non-Prosecution Agreement (NPA) does not cover the specific crimes Maxwell is charged with under the Mann Act, as the statutes listed in the NPA differ from those in the indictment. Furthermore, the document argues that the NPA does not confer enforceable rights upon Maxwell to preclude the current prosecution, even under contract law principles.
DOJ-OGR-00004897.jpg
This document is a court transcript from a sealed case, filed on July 2, 2021. In the transcript, the judge questions a government representative, Mr. Rossmiller, about a procedural issue: why the government has filed a motion for relief from a protective order on behalf of a third party, rather than the third party's own law firm, Boies Schiller, filing it. The judge expresses skepticism about this arrangement and asserts their judicial authority, referencing the Martindell case as applicable precedent.
DOJ-OGR-00004888.jpg
This document is page 76 of a legal filing submitted on July 2, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text is an excerpt from the Pennsylvania Supreme Court opinion (J-100-2020) overturning Bill Cosby's conviction, specifically discussing the binding nature of prosecutorial promises and due process. It appears to be submitted by the defense as legal precedent to argue for the enforcement of a non-prosecution agreement (likely the Epstein NPA).
DOJ-OGR-00004877.jpg
This legal document analyzes D.A. Castor's decision and press release concerning Cosby, asserting that Castor's intent was to induce Cosby's reliance, which led Cosby to testify in Constand's civil case without invoking his Fifth Amendment rights. The text further discusses the Fifth and Fourteenth Amendments of the United States Constitution, highlighting the right against self-incrimination as an "essential mainstay" of criminal justice, citing the Supreme Court case *Malloy v. Hogan*.
DOJ-OGR-00004808.jpg
This legal document, filed by the Government on July 1, 2021, to Judge Alison J. Nathan, argues that statements made to the media by defense appellate counsel, Mr. Markus, violate Local Rule 23.1. The filing specifically cites a recent Op-Ed where Markus compared his client's case to Bill Cosby's, arguing these extrajudicial comments are designed to prejudice potential jurors and interfere with a fair trial. The Government asserts that relief is warranted to prevent further prejudicial statements.
DOJ-OGR-00004806.jpg
This is a court order issued by Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell on July 1, 2021. The order lifts the temporary seal on a previous opinion regarding Maxwell's motions to suppress evidence. It also unseals a memorandum decision, an order, and hearing transcripts from a related civil case, Giuffre v. Maxwell, and orders Maxwell to file these documents on the public docket without redaction by July 2, 2021.
DOJ-OGR-00004802.jpg
This page is from a legal ruling in the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The court rejects arguments for suppression under 'Franks,' ruling that even if the Government failed to disclose a 2016 meeting with the law firm BSF to Judge McMahon, she would still have granted the modification of the protective order due to 'extraordinary circumstances' and 'significant public interest.' The text establishes that protective orders do not guarantee immunity from criminal subpoenas.
DOJ-OGR-00004799.jpg
This document page discusses the legal standards applicable to the defendant Maxwell's request for an evidentiary hearing, specifically debating the applicability of the 'Franks' standard. The Court concludes that despite differences in context (Fourth vs Fifth Amendment), the 'Franks' standard is appropriate and Maxwell must make a substantial preliminary showing to justify a hearing.
DOJ-OGR-00004794.jpg
This legal document, filed on June 25, 2021, argues that a person named Maxwell has no reasonable expectation of privacy regarding documents produced during a prior civil litigation. It asserts that because a protective order allowed these documents to be widely shared among various parties (attorneys, witnesses, court staff), they were not truly private. The document cites Supreme Court and Second Circuit precedents, such as Carpenter and Andover, to support the position that such information can be used by the Government in a subsequent criminal prosecution.
DOJ-OGR-00004788.jpg
This legal document, filed on June 25, 2021, describes a court proceeding from April 9, 2019, where Judge McMahon granted the Government's application to modify a protective order. The judge found extraordinary circumstances allowed the modification, enabling the Government to obtain information for its investigation into high-profile targets, including Maxwell, without tipping them off. Consequently, the law firm BSF turned over records from a civil litigation, including transcripts of Maxwell's depositions, to the Government.
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