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-00005836.jpg
This document page discusses legal arguments regarding the admissibility of testimony from "Minor Victim-3" in a case involving Jeffrey Epstein and a defendant. The text argues against the defense's claim that such testimony would be unfairly prejudicial or cause confusion regarding United Kingdom law, asserting that jury instructions will be sufficient.
DOJ-OGR-00005834.jpg
This legal document, filed on October 29, 2021, is a prosecution argument asserting that evidence related to the defendant's involvement with "Minor Victim-3" is admissible in court. The prosecution argues these actions are direct evidence of the defendant's role in a conspiracy to provide minors to Jeffrey Epstein for sexual abuse. The document dismisses the relevance of United Kingdom law and clarifies that this evidence is crucial for demonstrating the defendant's knowledge and participation in the scheme, even if a conviction cannot be based solely on this victim's testimony due to the statute of limitations.
DOJ-OGR-00005831.jpg
This legal document, part of a court filing, argues against precluding the testimony of 'Minor Victim-3' in the trial of the defendant, Maxwell. The prosecution contends that even if the acts against this victim were uncharged, her testimony is crucial to establish a pattern of abuse, show the defendant's relationship with Epstein, and prove her knowing participation in a conspiracy. The document cites legal precedent to support delaying any decision to strike this evidence until after the government has presented its case at trial.
DOJ-OGR-00005830.jpg
This legal document, filed on October 29, 2021, argues for the admissibility of testimony from 'Minor Victim-3' and other victims as direct evidence in a conspiracy case. The prosecution contends this evidence, including overt acts detailed in the indictment, is probative of the defendant's intent and not inadmissible 'other-acts' evidence. The document cites legal precedents, such as United States v. James, to support the argument that acts like drug possession can be considered direct evidence of a conspiracy when charged as overt acts.
DOJ-OGR-00005828.jpg
This document is a page from a legal filing, specifically a memorandum of law, in the case of United States v. Maxwell. The section titled "Applicable Law" argues that the Government is permitted to introduce evidence of acts committed in furtherance of a charged conspiracy. Citing multiple legal precedents, the document asserts that such acts are not considered 'other' acts under Federal Rule of Evidence 404(b), but are rather direct evidence of the conspiracy itself and are therefore admissible at trial.
DOJ-OGR-00005826.jpg
This legal document, filed on October 29, 2021, details allegations against a defendant concerning their involvement with 'Minor Victim-3' and Epstein in London between 1994 and 1995. The defendant is accused of befriending the minor, introducing her to Epstein, and encouraging her to give him massages, which led to sexual abuse by Epstein. The document also outlines the government's opposition to the defendant's motion to strike these allegations from the indictment, arguing they are evidence of a broader criminal scheme.
DOJ-OGR-00005824.jpg
This document is a page from a legal brief filed by the Government on October 29, 2021, in case 1:20-cr-00330-PAE. The Government argues that it has provided sufficient and timely notice to the defense regarding Rule 404(b) evidence, citing the provision of extensive materials and relevant legal precedents. The brief refutes the defense's motion to preclude evidence based on claims of inadequate notice.
DOJ-OGR-00005819.jpg
This legal document is a filing by the Government in case 1:20-cr-00330-PAE, arguing for the admissibility of specific evidence and witness testimony at an upcoming trial. The Government contends that exhibits and the testimony of "Employee-1," a former employee of Jeffrey Epstein, constitute direct evidence of the offenses charged and should be admitted, citing an October 11, 2021 letter where this evidence was disclosed to the defense.
DOJ-OGR-00005811.jpg
This legal document, filed on October 29, 2021, argues for the admissibility of expert testimony from a Dr. Rocchio in a criminal case. The document outlines Dr. Rocchio's intended opinions on how grooming facilitates sexual abuse and why victims often delay disclosing trauma, asserting these opinions are reliable and supported by psychological literature. It distinguishes the defendant's alleged actions from 'grooming by proxy' and cites academic research to bolster the validity of the expert's claims about delayed disclosure.
DOJ-OGR-00005779.jpg
This legal document is a motion arguing for the exclusion of certain evidence in the case against Ms. Maxwell. The defense claims that a photograph of Maxwell found at Jeffrey Epstein's house (Exhibit 313) and a "Household Manual" dated 2005 (Exhibit 606) are irrelevant and unfairly prejudicial. The document cites legal standards, such as Rule 401, to argue that this evidence has no bearing on the case and was created outside the timeframe of the alleged indictment.
DOJ-OGR-00005743.jpg
This document is a page from a legal filing, specifically page 6 of 8 from Case 1:20-cr-00330-PAE, filed on October 29, 2021. It outlines the legal standard for challenging the admissibility of identification testimony, citing several precedents like Raheem v. Kelly and Simmons v. United States. The text explains the two-part inquiry courts must use to determine if a pretrial identification procedure was unduly suggestive and, if so, whether the identification is still independently reliable based on factors established in Neil v. Biggers.
DOJ-OGR-00005742.jpg
This document is a legal argument from a court filing, dated October 29, 2021, in case 1:20-cr-00330-PAE. The defense argues that a photographic identification of Ms. Maxwell conducted on June 23, 2021, was suggestive and tainted, and therefore should be suppressed by the Court. The argument cites several U.S. Supreme Court cases to support the claim that the procedure violated the defendant's right to due process.
DOJ-OGR-00005741.jpg
This document is a page from a defense motion filed on October 29, 2021, in the case against Ghislaine Maxwell. The defense argues to prohibit testimony from 'Accuser 4' identifying Maxwell as a perpetrator, claiming that in 2007 FBI interviews and subsequent civil lawsuits against Epstein, the accuser never identified Maxwell and instead identified another individual as the one who took nude photographs. The defense asserts that any current identification is the result of suggestive government procedures.
DOJ-OGR-00005708.jpg
This legal document, filed on October 29, 2021, presents an argument against introducing evidence of alleged false statements (perjury counts) in Ms. Maxwell's trial. The filing contends that such evidence would substantially prejudice the jury by introducing unrelated allegations, risk the disqualification of her counsel, and create a distracting side-show, thereby jeopardizing her Sixth Amendment right to a fair trial. The arguments heavily rely on the Court's reasoning from a prior severance ruling.
DOJ-OGR-00002914.jpg
This legal document, filed on April 9, 2021, details the Government's investigative actions concerning "Minor Victim-4" and the "defendant." It outlines a series of interviews with Minor Victim-4, conducted via video and in-person between summer 2020 and January 2021, alongside further investigative steps. The document asserts that a superseding indictment (S2 Indictment) was timely presented to a grand jury in late March, refuting the defense's claims of intentional delay or that the indictment acknowledges the strength of pretrial motions.
DOJ-OGR-00002897.jpg
This is page 8 of a court filing (Document 195) in Case 1:20-cr-00330-PAE (US v. Maxwell), filed on April 5, 2021. The Government argues against the defendant's attempt to issue a subpoena to 'BSF' (Boies Schiller Flexner), characterizing it as an improper 'fishing expedition' for victim information and impeachment material that violates the 'Nixon test.' The Government also notes that the defendant failed to file a required response by the April 2, 2021 deadline.
DOJ-OGR-00002836.jpg
This legal document is a portion of a brief arguing against a defendant named Schulte's challenge to the jury selection process. The argument asserts that Schulte fails to prove 'systematic exclusion' because the alleged underrepresentation of minority jurors was due to external factors, not the jury selection system itself, citing multiple legal precedents. Schulte's specific claim that the Government sought an indictment in White Plains to avoid the more diverse jury pool of Manhattan is presented as the core of his foreclosed allegation.
DOJ-OGR-00002829.jpg
This document is page 8 of a court order filed on March 26, 2021, in the case of United States v. Schulte (Case 1:17-cr-00548). The text addresses a legal dispute regarding 'Underrepresentation' in jury selection, specifically defining the 'Relevant Jury Venire.' The defendant (Schulte) argued for the use of the White Plains 'qualified wheel,' while the Government argued for the 'master wheel.' The Court ruled in favor of the Government, concluding that the White Plains master wheel is the relevant jury venire for the fair cross-section analysis.
DOJ-OGR-00002824.jpg
This document is page 3 of a court filing (likely an opinion or order) in the case of United States v. Schulte (Case 1:17-cr-00548). It discusses Schulte's motion to dismiss his indictment regarding the alleged transmission of national defense information to WikiLeaks. Schulte argues that the White Plains grand jury venire violated his constitutional rights by failing to represent a fair cross-section of African American and Hispanic American populations. Note: While the prompt identifies this as 'Epstein-related,' the text exclusively concerns Joshua Schulte; however, this document may be part of a larger FOIA production covering SDNY cases or MCC New York issues.
DOJ-OGR-00002823.jpg
This legal document details the procedural history of the criminal case against Schulte, a former CIA employee. It covers his August 2017 arrest for leaking national defense information, subsequent indictments, and a trial in early 2020 which resulted in a guilty verdict on two counts and a mistrial on eight others. The document concludes by noting that the onset of the COVID-19 pandemic in New York City immediately after the trial caused a suspension of court proceedings.
DOJ-OGR-00002822.jpg
This legal document is an "Opinion & Order" from the U.S. District Court for the Southern District of New York, dated March 24, 2021, in the case of United States v. Joshua Adam Schulte. The court denies a motion by Schulte, a former CIA employee accused of leaking information to Wikileaks, to dismiss a superseding indictment. Schulte argued the grand jury was unconstitutional due to the impact of the COVID-19 pandemic, but the court rejected this claim, allowing the prosecution to proceed towards a second trial.
DOJ-OGR-00002752.jpg
This legal document is a court filing arguing against a defendant's proposed bail package. The prosecution contends that the defendant's offer to renounce her foreign citizenships (French and British) does not sufficiently mitigate the risk of her fleeing the country. The document argues the renunciation's validity is unclear and could be challenged later, and it cites a previous case (United States v. Cohen) where similar offers were deemed insufficient to assure the court that the defendant was not a flight risk.
DOJ-OGR-00002720.jpg
This document is page 4 of a legal filing, Case 1:20-cr-00330-AJN, filed on February 4, 2021. It contains a series of questions (numbered 27-29) directed at the Government, seeking specific details about allegations against Ms. Maxwell. The questions ask for clarification on who she was allegedly concealing crimes from, the specific acts of abuse she allegedly lied about, and why her statements are considered material to the perjury charges in the Superseding Indictment.
DOJ-OGR-00002718.jpg
This legal document, a "List of Particulars" filed on February 4, 2021, in case 1:20-cr-00330-AJN, is a series of requests for the prosecution to provide specific details about allegations against Ms. Maxwell. The requests seek information such as dates, locations, and specific actions related to Ms. Maxwell's alleged involvement with Jeffrey Epstein in the grooming and sexual abuse of individuals identified as Minor Victim-1 and Minor Victim-2. The document also requests clarification on alleged travel across state lines for the purpose of sexual encounters.
DOJ-OGR-00002710.jpg
This legal document is a motion filed on behalf of Ms. Maxwell in case 1:20-cr-00330-AJN on February 4, 2021. The motion requests the court to order the government to disclose favorable evidence and, more significantly, to hold a pretrial hearing to determine the admissibility of statements from alleged co-conspirators, particularly the deceased Jeffrey Epstein. The defense argues that admitting such testimonial statements without the possibility of cross-examination would be highly prejudicial and cites legal precedents like the 'Geaney rule' to support the need for a prior hearing.
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