GOVERNMENT
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Minor Victims
|
Protective |
7
|
2 | |
|
person
crime victim
|
Legal representative |
6
|
1 | |
|
person
MR. ROHRBACH
|
Representation |
6
|
2 | |
|
person
Epstein
|
Prosecution defendant |
6
|
1 | |
|
organization
district court
|
Legal representative |
6
|
2 | |
|
person
Susan Brune
|
Legal representative |
6
|
1 | |
|
person
MDC legal counsel
|
Professional |
6
|
1 | |
|
organization
BOP
|
Institutional |
6
|
2 | |
|
person
defendant
|
Adversarial professional |
6
|
1 | |
|
person
Ms. Sternheim
|
Professional |
6
|
2 | |
|
person
Catherine Conrad
|
Legal representative |
6
|
1 | |
|
organization
BSF
|
Professional |
6
|
1 | |
|
person
Mr. Everdell
|
Professional |
6
|
1 | |
|
person
Ms. Maxwell’s Counsel
|
Professional adversarial |
6
|
2 | |
|
person
Meder
|
Professional |
6
|
2 | |
|
person
MAXWELL
|
Adversarial investigative |
6
|
1 | |
|
person
Kimberly Meder
|
Witness |
6
|
1 | |
|
person
Kate
|
Legal representative |
6
|
2 | |
|
person
MS. POMERANTZ
|
Professional |
6
|
2 | |
|
person
Ms. Maxwell
|
Adversarial prosecutor defendant |
6
|
2 | |
|
person
Minor Victim-4
|
Legal representative |
6
|
1 | |
|
person
Epstein's Victims
|
Professional |
6
|
1 | |
|
person
Defendant (Maxwell)
|
Adversarial |
6
|
2 | |
|
person
Mr. Kelso
|
Professional potential rebuttal witness |
6
|
1 | |
|
person
Mr. Flatley
|
Professional witness |
6
|
1 |
| 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-00008549.jpg
This document is a legal instruction (Instruction No. 4) from a court case, filed on December 18, 2021. The judge directs the jury that they must decide the case based solely on their own recollection of the evidence, not on the arguments, objections, or statements made by the attorneys for the Government or the Defendant. The instruction explicitly states that statements from counsel and the court are not evidence and that the jury's memory of the facts is the ultimate authority.
DOJ-OGR-00008545.jpg
This document is page 7 of a 167-page legal filing (Document 563) from Case 1:20-cr-00330-PAE, filed on December 18, 2021. It is a table of contents for a set of jury instructions, listing topics from Instruction No. 42 to No. 59, which cover evidence, witness credibility, defendant's rights, and jury conduct.
DOJ-OGR-00008533.jpg
This document is Page 77 (marked 76 internally) of a court filing dated December 17, 2021, containing Jury Instruction No. 58 for the trial of Ms. Maxwell (Case 1:20-cr-00330-PAE). The instruction directs jurors to determine guilt based solely on evidence and explicitly prohibits them from considering potential punishment during deliberations, noting that sentencing is the sole responsibility of the judge.
DOJ-OGR-00008528.jpg
This document is a jury instruction, specifically Instruction No. 53, from case 1:20-cr-00330-PAE, filed on December 17, 2021. It directs the jury on how to consider electronic communications seized by the Government as evidence. The instruction clarifies that the use of this evidence is legal, and the jury must not let their personal opinions about the seizure influence their deliberations, but they are responsible for determining the weight of this evidence.
DOJ-OGR-00008513.jpg
This document is Instruction No. 40 regarding 'Venue' from a legal case (1:20-cr-00330-PAE) filed on December 17, 2021. It instructs the jury that the Government must prove, by a 'preponderance of the evidence,' that an act related to each charged crime occurred within the Southern District of New York, which includes several specified counties. The document clarifies that if the Government fails to meet this burden of proof for any specific charge, the jury must acquit the defendant, Ms. Maxwell, on that charge.
DOJ-OGR-00008511.jpg
This legal document is a jury instruction (Instruction No. 39) from a criminal case, filed on December 17, 2021. It defines the legal concept of "conscious avoidance" or "willful blindness," explaining to the jury how a defendant's deliberate act of ignoring facts can be considered the legal equivalent of knowledge. The instruction clarifies that this is a factor the jury can use to determine if the defendant acted "knowingly," a required element for the crimes charged by the Government.
DOJ-OGR-00008508.jpg
This document is page 52 of a legal filing from December 17, 2021, in the case against Ms. Maxwell. It contains jury instructions regarding the legal definition and requirements for proving an "overt act" as part of a conspiracy. The instructions clarify that the government does not need to prove Maxwell herself committed the act, that the act does not have to be one specifically listed in the indictment, and that a conviction on certain counts cannot be based solely on the testimony of a witness named Kate.
DOJ-OGR-00008506.jpg
This document outlines Jury Instruction No. 36 regarding the 'Third Element' of a conspiracy charge, specifically requiring proof of an 'overt act.' It details specific allegations from the indictment against Maxwell involving Epstein and victims identified as Jane, Annie, Kate, and Carolyn across various years and locations.
DOJ-OGR-00008504.jpg
This legal document, page 48 of a court filing from December 17, 2021, appears to be part of jury instructions in a criminal case against Ms. Maxwell. It clarifies the legal standard for finding someone guilty of conspiracy, stating that the prosecution does not need to prove the defendant knew all details, all participants, or was involved from the start. The text emphasizes that as long as Ms. Maxwell was aware of the conspiracy's criminal aims and knowingly participated, even in a limited capacity, she can be held responsible for all acts of the conspiracy during her membership.
DOJ-OGR-00008500.jpg
This legal document discusses the existence of a conspiracy and the evidence needed to prove it. It mentions the Government's role in proving the conspiracy beyond a reasonable doubt, referencing Counts One, Three, and Five of the Indictment.
DOJ-OGR-00008495.jpg
This legal document, filed on December 17, 2021, as part of case 1:20-cr-00330-PAE, provides jury instructions on the charge of aiding and abetting. It specifies that for the defendant, Ms. Maxwell, to be found guilty, the government must prove she willfully and knowingly took action to help another person's crime succeed. The document explicitly states that mere presence at the scene or knowledge of the crime is insufficient for a conviction.
DOJ-OGR-00008491.jpg
This legal document, filed on December 17, 2021, is a jury instruction (No. 27) from a criminal case (1:20-cr-00330-PAE). It pertains to Count Six, 'Sex Trafficking of a Minor,' and directs the jury on the second element the Government must prove: that the defendant, Ms. Maxwell, knew that the victim, Carolyn, was under eighteen years of age.
DOJ-OGR-00008485.jpg
This legal document is a jury instruction (Instruction No. 21) from a court case filed on December 17, 2021. It pertains to Count Four, the transportation of a minor named Jane by Ms. Maxwell for illegal sexual activity. The instruction clarifies that for a conviction, the government must prove that a 'significant or motivating purpose' of the interstate travel was for illegal sexual activity, not necessarily the 'sole purpose'.
DOJ-OGR-00008480.jpg
This document is a jury instruction from a legal case (1:20-cr-00330-PAE), filed on December 17, 2021. It details the third element of Count Two, 'Enticement to Engage in Illegal Sexual Activity,' specifically defining the legal standards for 'intent' and 'significant or motivating purpose' for the jury. The instruction clarifies that the prosecution (the Government) must prove beyond a reasonable doubt that a significant purpose of Ms. Maxwell encouraging 'Jane' to travel across state lines was for illegal sexual activity, and that this purpose was not merely incidental to the trip.
DOJ-OGR-00008479.jpg
This document is page 23 of a court filing (Document 562) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. It contains Jury Instruction No. 16 regarding Count Two: Enticement to Engage in Illegal Sexual Activity. The instruction defines the second element of the crime, specifically explaining the requirement to prove travel in 'interstate commerce.'
DOJ-OGR-00008478.jpg
This legal document, filed on December 17, 2021, is a jury instruction from a criminal case (Case 1:20-cr-00330-PAE). It details Instruction No. 15, which explains the first element the government must prove against the defendant, Ms. Maxwell, for Count Two: "Enticement to Engage in Illegal Sexual Activity." The document defines key legal terms for the jury, including "interstate commerce" and the standard for acting "knowingly."
DOJ-OGR-00008477.jpg
This legal document is a jury instruction (Instruction No. 14) from a court case filed on December 17, 2021. It details the three elements the Government must prove beyond a reasonable doubt to convict the Defendant on 'Count Two: Enticement to Engage in Illegal Sexual Activity'. The instruction specifies that this charge relates to actions involving an individual named 'Jane' between 1994 and 1997.
DOJ-OGR-00008469.jpg
This legal document is a jury instruction, specifically Instruction No. 7, from a criminal case (1:20-cr-00330-PAE) filed on December 17, 2021. It explains the legal principles of the presumption of innocence and the burden of proof, stating that the defendant, Ms. Maxwell, is presumed innocent and the Government has the sole responsibility to prove her guilt beyond a reasonable doubt. The instruction emphasizes that this burden never shifts to the defendant, even if she presents a defense.
DOJ-OGR-00008456.jpg
This is the final page of a legal filing from the U.S. Attorney's office for the Southern District of New York, dated December 19, 2021. The letter, submitted by U.S. Attorney Damian Williams and his assistants, informs the Court of the submission of exhibits GX 603-A and GX 604-A under a temporary seal. It also states that copies of other referenced exhibits will be provided the following morning.
DOJ-OGR-00008455.jpg
This document is page 3 of a court filing, so-ordered by a judge on December 19, 2021. In it, the Government outlines agreements with the defense regarding redactions for trial exhibits and requests the court's permission to submit certain exhibits into evidence and release others to the public before the jury begins deliberations. The filing details specific exhibit numbers and the rationale for their handling, such as protecting the privacy of third parties.
DOJ-OGR-00008430.jpg
This legal document is a filing from the U.S. Attorney for the Southern District of New York, arguing against a defense position regarding witness availability. The prosecution cites the precedent of *United States v. Jones*, where a judge rejected a similar defense attempt to compel the government to immunize a witness. The filing concludes that since the defense had the opportunity to call numerous witnesses, including Virginia Roberts, there is no reason to deviate from the standard jury instruction on the equal availability of witnesses.
DOJ-OGR-00008429.jpg
This legal document is a filing by the Government in case 1:20-cr-00330-PAE, arguing against two jury instructions proposed by the defense. The Government opposes a specific instruction on witness convictions, fearing it would overemphasize them, and argues against modifying the standard instruction for uncalled witnesses. It cites case law to assert that a witness invoking the Fifth Amendment is 'equally unavailable' to both the prosecution and the defense.
DOJ-OGR-00008414.jpg
This document is a court transcript from a legal case, filed on December 17, 2021. It captures a dialogue between the judge and two defense counsel, Ms. Sternheim and Ms. Menninger, regarding the scope of their opening statements. The defense argues that the government's indictment includes a conspiracy charge involving unnamed individuals, which makes evidence beyond the four main accusers relevant to the case.
DOJ-OGR-00008413.jpg
This document is a court transcript from a hearing dated December 17, 2021, in the case against Ms. Maxwell. The prosecution, represented by Ms. Moe, is arguing that the defense should be precluded from introducing statements from other alleged victims unless they first formally proffer which witnesses they intend to call. The government contends this is necessary to prevent the introduction of inappropriate hearsay evidence during opening statements or cross-examination.
DOJ-OGR-00008409.jpg
This legal document, filed on December 17, 2021, is a page from a court proceeding in the case against Ms. Maxwell. The judge is providing guidance on the admissibility of evidence, citing the 2013 case 'United States v. Borrero' as precedent. The court will permit the defense to cross-examine government witnesses about their prior statements that did not implicate Ms. Maxwell in order to impeach their credibility.
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