This document is a Proffer Agreement dated July 24, 2025, between Ghislaine Maxwell (represented by attorney David Oscar Markus) and the United States Government (represented by Deputy Attorney General Todd Blanche). The agreement outlines the terms for a meeting in Tallahassee, Florida, stipulating that statements made by Maxwell generally cannot be used against her in the government's case-in-chief but can be used for leads or impeachment. It explicitly states this is not a cooperation agreement.
A Record of Proceedings from the Superior Court of the Virgin Islands dated March 17, 2023, regarding a civil debt case (ST-2020-CV-00155) filed by Ghislaine Maxwell against the Estate of Jeffrey E. Epstein. Maxwell appeared pro se for a status conference and confirmed her intent to proceed with the lawsuit while requesting 60 days to find new counsel, which the defense did not oppose. The proceedings lasted from 10:00 a.m. to 10:04 a.m.
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands, dated August 9, 2022. It concerns case ST-2020-CV-00155, a debt action filed by Ghislaine Maxwell against the Estate of Jeffrey E. Epstein. The notice informs legal counsel that an order was entered on that date.
This document is a Record of Proceedings from the Superior Court of the Virgin Islands dated July 29, 2022, regarding a civil debt case (ST-2020-CV-00155) between plaintiff Ghislaine Maxwell and the Estate of Jeffrey E. Epstein. The hearing was a status conference presided over by Judge Harold W.L. Willocks, where parties were directed to meet and confer regarding oral arguments for a Motion to Dismiss and a Government motion to intervene. The document lists attorneys present for both sides and notes a related case, ST-2020-CV-00014.
Record of Proceedings from the Superior Court of the Virgin Islands dated March 9, 2022, regarding a civil debt case (ST-2020-CV-00155) filed by Ghislaine Maxwell against the Estate of Jeffrey Epstein and its executors, Darren Indyke and Richard Kahn, as well as NES, LLC. The document details a status hearing presided over by Judge Harold W.L. Willocks, attended by attorneys Kyle R. Waldner and Christopher A. Kroblin. The court set a deadline of August 1, 2022, for the parties to file briefs.
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands filed on December 7, 2021. It pertains to three consolidated cases involving the Government of the USVI, the Estate of Jeffrey Epstein (with Darren K. Indyke as executor), and Ghislaine Maxwell (seeking indemnification). The notice lists numerous recipients, including judges and attorneys involved in the proceedings.
A 'Notice of Entry of Order' filed on March 17, 2021, in the Superior Court of the Virgin Islands (Case ST-2020-CV-00155). The document notifies attorneys Kyle R. Waldner, Christopher A. Kroblin, and Ariel M. Smith that an order was entered in the debt case between Plaintiff Ghislaine Maxwell and the Defendants, the Estate of Jeffrey E. Epstein.
A 'Notice of Entry of Order' filed in the Superior Court of the Virgin Islands on May 11, 2020. The document notifies attorneys Kyle R. Waldner and Christopher A. Kroblin that an order was entered on May 9, 2020, in the debt case (ST-2020-CV-00155) where Ghislaine Maxwell is suing the Estate of Jeffrey E. Epstein.
This document is a 'Notice of Entry' filed in the Superior Court of the Virgin Islands on February 7, 2022, regarding the estate of Jeffrey E. Epstein (Case ST-2021-RV-00005). It notifies relevant legal parties, including Chief Deputy Attorney General Carol Thomas-Jacobs and attorney Christopher Allen Kroblin, that a Memorandum Opinion and Order dated February 4, 2022, has been entered into the court record.
This document is an email thread from July 8-9, 2019, between defense attorney Marc Fernich and an Assistant U.S. Attorney regarding the case U.S. v. Epstein. The correspondence covers the filing of the government's bail memorandum to Judge Pitman and Judge Berman. Additionally, Fernich requests the return of Jeffrey Epstein's personal effects (phone and cash) seized upon arrest, leading to coordination with a Special Agent.
This document contains email metadata from February 18, 2021, with the subject 'RE: Question re SDFL Epstein file'. The correspondence involves entities abbreviated as 'USANYS' (likely a US Attorney's Office in NY) and 'SDFL' (Southern District of Florida). The identities of the sender and primary recipients are redacted.
This document is a photograph (EFTA00003437) depicting an individual in a striped costume (shirt and tights) and black boots posing or dancing at a venue. The background contains a speaker with a JBL logo and a wall plaque for the 'Gansevoort Market Historic District' designated by the New York City Landmarks Preservation Commission in September 2003, placing the location in New York City after that date. Several spectators are visible in the background.
This document is a photograph (Evidence ID EFTA00003436) depicting a social event or party. It shows a performer in heavy makeup and a striped costume dancing on a table. In the foreground, a guest is using a Samsung flip phone to take a picture of the performer. A wall plaque visible on the right suggests the location is within the Gansevoort Market Historic District in New York City.
This document is page 'vi' (Page 7 of 113) of a legal filing dated February 28, 2023, bearing the Bates stamp DOJ-OGR-00021054. It is a 'Table of Authorities' listing various legal precedents referenced in the main brief, including cases such as 'Hudson Valley Black Press v. I.R.S.' and 'Martin v. Hadix'. The document appears to be part of a larger Department of Justice filing, likely related to a FOIA case or appeal given the OGR marking.
This legal document argues that the defendant, Ms. Maxwell, was denied her Sixth Amendment right to a grand jury selected from a fair cross-section of the community. It cites a parallel case, U.S. v. Balde, and an expert analysis by Jeffrey Martin, which found significant underrepresentation of Black and Hispanic individuals in the White Plains jury wheel. Because Ms. Maxwell's grand jury was drawn from the same pool, the document contends this analysis applies to her case as well.
This legal document, filed on June 29, 2022, argues for the immediate unsealing of a defendant's motion for a new trial and related documents, such as juror questionnaires. The argument is based on the First Amendment right of public access to court proceedings, which is asserted to be particularly strong when allegations of juror misconduct are involved. The document contends that the public interest in transparency is significant, especially in a high-profile case, and that no sufficient justification for sealing the documents has been provided.
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.
This legal document, part of a court filing from April 16, 2021, presents an argument about the jurisdictional scope of plea agreements. The author refutes a defendant's motion by citing case law, primarily *Annabi*, to argue that a plea agreement only binds the specific U.S. Attorney's Office that made it, unless it explicitly states a broader scope. The document contrasts this with the defendant's argument that without an explicit limitation, an agreement should bind the entire federal government.
This document is a page from a 2007 Utah Law Review article (page 58 of 78 in the exhibit) discussing the legal rights of crime victims, specifically the appointment of counsel and the right to be heard regarding a defendant's release. It cites the case *United States v. Stamper* and the Crime Victims' Rights Act (CVRA). The document bears the name David Schoen and a House Oversight Bates stamp, suggesting it was submitted as evidence or background material in a congressional investigation, likely related to the handling of the Jeffrey Epstein case given Schoen's involvement as Epstein's lawyer.
This document is a page from a 2007 Utah Law Review article, produced as part of a House Oversight investigation (likely related to the Epstein case given David Schoen's name at the footer). The text analyzes the history of the Advisory Committee's amendments to Federal Criminal Rules and critiques the lack of support for crime victims' rights, specifically the failure to appoint counsel for indigent victims or clarify their role in plea processes under the Crime Victims' Rights Act (CVRA). It highlights the disparity between defendants, who are guaranteed counsel, and victims, who are not.
This is page 3 of a Civil Cover Sheet (Form CV-71) filed in the United States District Court for the Central District of California on April 26, 2016. The document is associated with Case 5:16-cv-00797 (visible in the blue header stamp). The form is signed by Katie Johnson as a self-represented litigant. The filer indicates that there are no identical or related cases previously filed in this court. The document bears a House Oversight Bates stamp.
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