SOUTHERN DISTRICT OF NEW YORK
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This is page 2 of a legal filing (Document 526) from the Ghislaine Maxwell case (Case 1:20-cr-00330-AJN), filed on December 3, 2021. It serves as the signature page for the prosecution, submitted by U.S. Attorney Damian Williams and signed by Assistant U.S. Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach of the Southern District of New York.
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This legal document, filed on December 5, 2021, is a request from the U.S. Government to the Court in case 1:20-cr-00330-PAE. The Government proposes a specific limiting instruction for the jury to be read before a witness, identified as "Witness-3," testifies. The instruction aims to prevent prejudice by clarifying that any testimony about sexual conduct between Witness-3 and Mr. Epstein is not part of the charged crimes and cannot be used to judge the character or propensity of either Mr. Epstein or Ms. Maxwell.
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This is a letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case against Ghislaine Maxwell, dated December 5, 2021. The prosecution outlines its plan to question 'Witness-3' about sexual activity with Epstein, adhering to the court's order to avoid explicit details. The government expresses concern that this limited questioning could be misinterpreted by the jury as a lack of witness credibility, especially in light of the defense's opening argument.
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This is a legal filing from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 4, 2021, in the criminal case against Ghislaine Maxwell. The prosecution is moving to admit photographs from inside Jeffrey Epstein's New York residence as evidence. The government argues that these photographs are relevant to the case because they serve to corroborate the testimony of a witness identified by the pseudonym 'Jane'.
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Page 4 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell) dated December 10, 2020. The text records the opening of a remote arraignment and bail hearing, with the Judge (The Court) confirming the presence of counsel Ms. Moe, Court Reporter Kristen Carannante, and Pretrial Services Officer Leah Harmon. The Judge notes the proceeding is being held remotely due to the COVID-19 pandemic under the CARES Act.
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This document is the cover page for the court transcript of an arraignment and bail hearing for Ghislaine Maxwell, held via teleconference on July 14, 2020. The case, United States of America v. Ghislaine Maxwell, was heard in the Southern District of New York before District Judge Alison J. Nathan. The page lists the legal counsel appearing for both the prosecution, led by U.S. Attorney Audrey Strauss, and the defense, represented by attorneys from the law firms Cohen & Gresser, LLP and Haddon Morgan & Foreman, P.C.
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This is a letter dated November 25, 2020, from Ghislaine Maxwell's attorneys at Cohen & Gresser LLP to Judge Alison J. Nathan. The attorneys state their intention to file a renewed motion for bail for Ms. Maxwell and request an 'in camera' conference to discuss filing portions of the motion and supporting materials under seal. They argue for sealing to protect sensitive and private information concerning Ms. Maxwell and the third-party sureties (family and friends) supporting her bail application.
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This is a court order filed on December 3, 2020, by Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The order addresses a request by Maxwell's defense counsel to seal letters related to a renewed motion for bail. The court approves the defense's proposed redactions, noting that the Government does not oppose them, based on legal standards regarding judicial documents and privacy interests.
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This is a court order from Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell, filed on December 1, 2020, in the Southern District of New York. The order compels the Government to respond by December 2, 2020, to two letter requests filed by the Defendant, Ghislaine Maxwell, on November 25 and November 30, which concern proposed redactions. The judge orders that the letters remain temporarily sealed pending the court's decision on the redaction request.
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This document is the second page of a filing from the United States Attorney's Office regarding the conditions of confinement for a defendant (implied to be Ghislaine Maxwell based on the case number) at the MDC. It details the schedule for legal calls, discovery review, and isolation, asserting that the defendant has more access than other inmates and that the Government is actively communicating with defense counsel regarding any concerns.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated October 6, 2020, regarding the case against Ghislaine Maxwell. The prosecution requests permission to delay the disclosure of sensitive evidence, specifically photographs and documents related to victims of Jeffrey Epstein, to the defense until eight weeks before trial. The government argues this delay is necessary to protect an ongoing investigation and prevent the premature release of sensitive victim information, citing Federal Rule of Criminal Procedure 16(d)(1) as legal justification.
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This legal document is a filing by the U.S. Government in case 1:20-cr-00330-AJN, requesting an extension for producing approximately 1.2 million documents seized from Epstein's residences. The Government asks to move the deadline to November 23, 2020, and to extend the motions schedule. Judge Alison J. Nathan grants the request in an order dated November 9, 2020, setting new deadlines for motions into early 2021.
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This document is page 2 of a court order filed on November 9, 2020, dismissing Ghislaine Maxwell's appeal for lack of jurisdiction. Maxwell sought to appeal a lower court's denial of her request to modify a protective order and attempted to consolidate this with the 'Giuffre v. Maxwell' civil case. The court outlines legal precedents regarding the 'final judgment rule' and 'collateral order exception' to justify the dismissal.
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This legal document is an affidavit filed on November 6, 2020, by Assistant U.S. Attorney Maurene Comey in the case of U.S. v. Ghislaine Maxwell. Comey certifies that the government attempted to negotiate in good faith with Maxwell's defense counsel for a two-week extension (from November 9 to November 23, 2020) for the production of documents seized from Jeffrey Epstein, but the parties were unable to reach an agreement. The extension was requested to allow an outside vendor to complete bates stamping and downloading of the electronic evidence.
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This document is a Court Order filed on November 5, 2020, by Judge Alison J. Nathan in the Southern District of New York (Case 1:20-cr-00330, likely U.S. v. Ghislaine Maxwell). The order formally reminds the prosecution (the Government) of its continuing legal obligations to disclose exculpatory evidence (Brady material) and impeachment evidence (Giglio material) to the defense pursuant to the Due Process Protections Act and Federal Rule of Criminal Procedure 5(f).
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This document is the final page of a Government filing (dated Oct 30, 2020) regarding the detention conditions and discovery process for the defendant (Ghislaine Maxwell) at the Metropolitan Detention Center (MDC). The Government argues against the need for a court order regarding MDC issues, citing that protocols are already in place for passing papers, COVID-19 safety (Plexiglas barriers), and laptop viewing. The filing asserts that the defendant has access to discovery materials for approximately 13 hours a day—more than any other inmate—and details technical efforts to resolve file viewing issues mentioned in a footnote.
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This legal document, dated October 23, 2020, is a filing on behalf of Ms. Maxwell arguing that the U.S. Government is improperly withholding critical information. The defense claims the government has not provided details about Jeffrey Epstein's 2007 Non-Prosecution Agreement or meetings held in 2016 to investigate Maxwell. The filing accuses the government of contradicting its earlier court assurances by now disclaiming responsibility for investigative files from Florida that were transferred to the New York F.B.I. office.
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This document is the conclusion page (page 8) of a legal filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), dated October 7, 2020. Submitted by Acting US Attorney Audrey Strauss and Assistant US Attorneys Comey, Moe, and Pomerantz to Judge Alison J. Nathan, the text affirms the Government's commitment to its disclosure obligations following representations made at an initial conference.
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This document is Page 3 of a legal filing (Case 1:20-cr-00330-AJN, likely United States v. Ghislaine Maxwell) dated October 7, 2020, addressed to Judge Alison J. Nathan. The text outlines legal precedents determining the scope of the 'prosecution team' for discovery purposes (Rule 16 and Brady), arguing that the prosecution is not obligated to produce records from other government agencies (like the SEC or components of the DOJ/FBI) unless a specific 'joint investigation' occurred. It cites various cases (Middendorf, Collins, Stein) to establish the criteria for what constitutes a joint investigation.
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This document is page 3 of a legal filing submitted on October 7, 2020, by the Acting US Attorney Audrey Strauss and Assistant US Attorneys (Comey, Moe, Pomerantz) in the Southern District of New York (Case 1:20-cr-00330-AJN). The Government argues against the premature disclosure of witness identities and sensitive materials to the defense, citing risks to the ongoing investigation and the potential to deter other victims from coming forward. They request the Court to approve a delay in disclosing these materials pursuant to Rule 16(d).
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This document is the final page (Page 3) of a legal filing (Document 60) submitted on October 6, 2020, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Government, represented by Acting US Attorney Audrey Strauss and Assistant US Attorneys Comey, Moe, and Pomerantz, requests a delay in disclosing witness identities and sensitive materials to the defense to prevent jeopardizing the ongoing investigation and to encourage victims to come forward. The filing cites Rule 16(d) as the legal basis for this protective measure.
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This document is a Notice of Appearance filed on October 5, 2020, in the U.S. District Court for the Southern District of New York for the case of United States v. Ghislaine Maxwell. Attorney Bobbi C. Sternheim formally notifies the court that she will be serving as legal counsel for the defendant, Ghislaine Maxwell.
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This document is a Notice of Appeal filed on behalf of Ghislaine Maxwell in the case of United States of America v. Ghislaine Maxwell. Dated September 3, 2020, it formally notifies the court of her intent to appeal the district court's September 2, 2020 decision, which denied her motion to modify a protective order. The appeal is directed to the United States Court of Appeals for the Second Circuit.
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This legal document, dated August 17, 2020, is a filing addressed to Judge Alison J. Nathan on behalf of Ms. Maxwell. It argues for the court's discretion in handling certain materials, citing legal precedent from the Second Circuit for staying civil proceedings during a related criminal case to protect Fifth Amendment rights. The filing also discusses the proper jurisdiction for interpreting a protective order from a separate civil case, suggesting the government has previously agreed that the civil court, not this criminal court, is the appropriate forum.
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This document is a letter motion dated August 17, 2020, from attorney Jeffrey Pagliuca on behalf of his client, defendant Ghislaine Maxwell, to Judge Alison J. Nathan of the U.S. District Court for the Southern District of New York. The motion requests a modification of the existing protective order to allow Maxwell's defense to refer to and file under seal certain discovery materials provided by the government on August 5 and August 13, 2020. The defense argues this is necessary for the fair determination of issues in what is referred to as the "Other Matters".
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