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-00005347.jpg
This document is a page from a juror questionnaire filed in a federal criminal case (1:20-cr-00330-PAE) on October 22, 2021. The questions aim to gauge potential jurors' backgrounds and biases related to mental health, law, and law enforcement. The document also contains legal arguments between the prosecution (Government) and the defense, with the Government objecting to certain questions as burdensome and the defense arguing they are necessary to identify potential juror bias.
DOJ-OGR-00005343.jpg
This document is page 21 of a court filing (Document 367) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 22, 2021. It contains a draft juror questionnaire focusing on potential jurors' opinions on sex trafficking laws and personal history with sexual abuse. The document highlights a legal dispute where the Government objects to specific questions proposed by the Defense (highlighted in green text) regarding the jurors' personal victimization history, arguing they are inappropriate, while the Defense argues these questions are necessary to identify bias against Ms. Maxwell.
DOJ-OGR-00005340.jpg
This document is page 18 of a draft juror questionnaire filed on October 22, 2021, for the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains questions 13 and 14, which ask potential jurors about their exposure to media regarding Jeffrey Epstein and Ms. Maxwell, and whether they can remain impartial. The document highlights a dispute between the prosecution and defense, visible in sidebar comments, where the Government objects to defense-proposed questions (in green text) regarding jurors' specific reactions to media coverage.
DOJ-OGR-00005329.jpg
This document is page 7 of a juror questionnaire for a federal criminal case (1:20-cr-00330-PAE), filed on October 22, 2021. It questions potential jurors on their decision-making styles and views on wealth, while also outlining the trial schedule from November 16 to December 24, 2021. The document includes several objections from the Government, which argues that certain questions are too vague to be used for a for-cause challenge.
DOJ-OGR-00005324.jpg
This document is a jury instruction sheet for the criminal trial of Ghislaine Maxwell, filed on October 22, 2021. It summarizes the six-count indictment against Maxwell, which alleges she conspired with and aided Jeffrey Epstein in sex trafficking of minors between 1994 and 2004. The document provides strict instructions to potential jurors, prohibiting them from conducting outside research or discussing the case, and notes the trial is set to begin on November 29, 2021.
DOJ-OGR-00005319.jpg
This document is a page from a court filing containing instructions to potential jurors regarding the trial of Ghislaine Maxwell. It outlines the trial schedule, explains the nature of the charges involving Jeffrey Epstein, defines the burden of proof, and issues preliminary instructions restricting media consumption about the case.
DOJ-OGR-00005311.jpg
This document is a page from a legal filing in the criminal case of Ms. Maxwell (Case 1:20-cr-00330-PAE), dated October 22, 2021. It contains a series of questions for a potential juror to assess their ability to follow fundamental legal instructions, such as the presumption of innocence, avoiding media reports and independent research, and to confirm their availability for the trial scheduled between November 29 and January 15.
DOJ-OGR-00005247.jpg
This is page 2 of a legal filing (Document 354) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on October 15, 2021. The text argues that the Court has the authority to set an earlier deadline for the defense to file motions under Federal Rule of Evidence 412 (the rape shield law), citing various precedents to support the Government's request for an earlier briefing schedule. The document references multiple other cases (Andrews, Rivera, Dupigny, Backman, Valenzuela) to demonstrate that courts frequently set Rule 412 deadlines more than 14 days prior to trial.
DOJ-OGR-00002883.jpg
This legal document, dated March 22, 2021, is a submission by Sigrid S. McCawley arguing against a defendant's motion to subpoena evidence from a third party, BSF. The document contends that the requested materials—including communications, a Grand Jury subpoena, cowboy boots, and photographs involving individuals like Annie Farmer, Virginia Giuffre, and Jeffrey Epstein—are either obtainable from the government or not relevant enough to require pre-trial production. The author concludes that the defendant's motion should be denied.
DOJ-OGR-00002760.jpg
This legal document is a letter dated March 15, 2021, from attorney Christian R. Everdell to Judge Alison J. Nathan. The letter outlines the plan for submitting several reply memoranda, explaining that those containing confidential information will be redacted for the public docket. To facilitate this, the attorney will first submit both unredacted (under seal) and redacted versions to the Court and the government via email for review before any public filing.
DOJ-OGR-00002680.jpg
This document is a preliminary statement from a legal motion filed on behalf of Ghislaine Maxwell on February 4, 2021. The defense requests that the Court strike allegations related to 'Accuser-3' from the indictment, arguing that the alleged conduct occurred in England where Accuser-3 was above the age of consent and did not involve travel. The motion claims the government is improperly using these allegations to bolster its case regarding Mann Act violations involving 'Accuser-1' and Jeffrey Epstein.
DOJ-OGR-00020377.jpg
This legal document is a filing by the Government in response to an appeal by Maxwell regarding her pretrial confinement conditions. The Government argues that Maxwell's complaints about disruptive nighttime flashlight checks are unsubstantiated and do not demonstrably interfere with her trial preparation. The document also refutes Maxwell's accusations of misrepresentation, clarifying a statement made by Government counsel and explaining an acknowledged inaccuracy in information received from the MDC.
DOJ-OGR-00020374.jpg
This legal document, part of a court filing, argues that a 'renewed motion' from a defendant named Maxwell is meritless. It cites legal precedents (United States v. Hochevar, Stack v. Boyle) and procedural rules to assert that the motion is not properly before the court. The document further states that a lower court judge, Judge Nathan, did not err in previously finding three times that Maxwell is a flight risk and denying bail.
DOJ-OGR-00020370.jpg
This page from a legal filing (Case 21-58) argues that Ghislaine Maxwell's motion should be denied. It details Judge Nathan's previous findings that MDC's security protocols—specifically regarding night monitoring and eye coverings—do not interfere with Maxwell's trial preparation. The document affirms that previous denials of bail and release have been upheld.
DOJ-OGR-00020368.jpg
This document page, part of a legal filing from May 2021, details the Government's response to Judge Nathan regarding 'flashlight surveillance' of Ghislaine Maxwell at the MDC. It explains that while general population inmates are checked hourly and SHU inmates every 30 minutes, Maxwell is checked every 15 minutes due to an 'enhanced security schedule' and 'heightened safety and security concerns,' despite not being on suicide watch.
DOJ-OGR-00020367.jpg
This legal document outlines the procedural history of a case involving a defendant named Maxwell. After Maxwell appealed two of Judge Nathan's bail decisions and was denied pretrial release on April 27, 2021, she did not file a renewed motion. Instead, on April 29, 2021, she submitted a letter to Judge Nathan requesting the court to order the MDC to stop or justify the 15-minute light surveillance that was disrupting her sleep.
DOJ-OGR-00020366.jpg
This legal document details the court's denial of a bail application filed by the defendant, Maxwell, on February 23, 2021. Judge Nathan found Maxwell's arguments about her confinement conditions unpersuasive and reiterated that her detention was necessary due to her being a flight risk, citing her substantial international ties, financial resources, and a "lack of candor regarding her assets" at the time of her arrest. The judge concluded that even a substantial bail package could not reasonably assure Maxwell's future appearance in court.
DOJ-OGR-00020352.jpg
This document is the cover page for Exhibit D, a legal filing from May 5, 2021, in Case 21-58. It is titled "Government's Response to Ghislaine Maxwell's conditions at Metropolitan Detention Center," indicating a formal reply by the government concerning the circumstances of Maxwell's incarceration.
DOJ-OGR-00020332.jpg
This document is page 8 of a legal filing (Case 21-58) dated May 17, 2021, arguing against the mistreatment of Ms. Maxwell, specifically regarding sleep deprivation and accusations about hygiene. The defense argues that the government misrepresented facts by claiming Maxwell caused a smell in her cell by not flushing, while the defense asserts the smell was due to MDC infrastructure issues. This claim is supported by testimony from another inmate, Tiffany Days, who described a 'feces flood' at the facility.
DOJ-OGR-00020331.jpg
This legal document argues that the government misrepresented information to the court regarding the treatment of inmate Ms. Maxwell. The government initially claimed that flashlight checks every 15 minutes were a routine procedure, but later admitted in a letter that Ms. Maxwell is the only inmate subjected to this treatment. The document contends this is a form of mistreatment being justified without proper evidence, such as an affidavit.
DOJ-OGR-00020317.jpg
This document is page 2 of a legal filing by attorney Bobbi C. Sternheim regarding the detention conditions of Ghislaine Maxwell at the MDC East Building. The text details unsanitary conditions involving mold and vermin, inadequate facilities for legal counsel meetings (described as a 'fishbowl' and 'death trap'), and Maxwell's deteriorating health due to lack of fresh air and sunlight over eight months. It also notes that a request for a legal call regarding pretrial motions was denied.
DOJ-OGR-00005862.jpg
This document is a page from a legal filing, specifically Case 1:20-cr-00330-PAE, filed on October 29, 2021. The text presents the prosecution's (Government's) argument that using the term "victim" to refer to witnesses is not prejudicial to the defendant's rights. The argument is supported by citing numerous legal precedents from various U.S. courts which have previously ruled on the matter.
DOJ-OGR-00005845.jpg
This legal document is a filing from the Government in response to a defense motion regarding co-conspirator statements. The Government refutes the defense's accusation that failing to provide an index of statements is an 'invitation to manufacture evidence,' calling the allegation baseless and offensive. The filing also addresses the defense's argument about the difficulty of calling co-conspirators as witnesses, citing a previous court opinion that questioned the credibility of potential testimony from Epstein.
DOJ-OGR-00005840.jpg
This document is a page from a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It details procedural disputes regarding the timing of the Government's disclosure of co-conspirator statements to the defense. The Court ruled that the Government's commitment to produce these statements six weeks before trial (alongside Jencks Act and Giglio materials) was sufficient, denying the defense's request for earlier identification.
DOJ-OGR-00005838.jpg
This legal document, filed on October 29, 2021, is a portion of a government motion arguing against the defense's proposed jury instruction. The Government contends that the defense's instruction regarding sexual activity with 'Minor Victim-3' is wrong on the law and that the relevance of United Kingdom's age of consent law should be disregarded. The document also states that the Government has already provided the defense with discovery materials, including the identities of alleged co-conspirators, making the defense's request to preclude their statements baseless.
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