Defense
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
GOVERNMENT
|
Legal representative |
13
Very Strong
|
21 | |
|
organization
GOVERNMENT
|
Adversarial |
11
Very Strong
|
10 | |
|
organization
GOVERNMENT
|
Professional |
8
Strong
|
3 | |
|
person
Mr. Everdell
|
Professional |
7
|
2 | |
|
person
Juror 50
|
Legal representative |
6
|
1 | |
|
person
Mr. Flatley
|
Professional subject of information |
6
|
1 | |
|
organization
The government
|
Legal representative |
6
|
2 | |
|
person
Unidentified Speaker (LCSCMAXT)
|
Professional |
6
|
1 | |
|
organization
The Court
|
Legal representative |
6
|
1 | |
|
person
Ms. Moe
|
Adversarial |
6
|
2 | |
|
person
Mr. Everdell
|
Representation |
6
|
2 | |
|
person
Government's witnesses
|
Legal representative |
5
|
1 | |
|
person
prosecution/government
|
Legal representative |
5
|
1 | |
|
organization
GOVERNMENT
|
Professional adversarial |
5
|
1 | |
|
person
prosecutor (speaker)
|
Professional |
5
|
1 | |
|
person
victims
|
Legal representative |
5
|
1 | |
|
organization
GOVERNMENT
|
Professional adversarial |
5
|
1 | |
|
person
Jonathan Schanzer
|
Employment |
5
|
1 | |
|
person
prosecution
|
Legal representative |
5
|
1 | |
|
person
MS. MENNINGER
|
Representative |
5
|
1 | |
|
person
Mr. Kelso
|
Witness |
5
|
1 | |
|
person
Dr. Loftus
|
Defense expert witness |
5
|
1 | |
|
person
Dr. Loftus
|
Expert witness |
5
|
1 | |
|
person
Dr. Dietz
|
Expert witness |
5
|
1 | |
|
person
prosecution
|
Adversarial |
5
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Legal Argument regarding NPA applicability | Court | 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 | Negotiation of the NPA (Non-Prosecution Agreement) | Unknown | View |
| N/A | N/A | Cross-examination | Court | View |
| N/A | N/A | Court rejected the defendant's request for additional instructions regarding Count Two. | Courtroom | View |
| N/A | N/A | Parties' extensive briefing on issues | Court | View |
| N/A | N/A | Production of discovery materials (>165,000 pages) by the Government. | N/A | View |
| N/A | N/A | Defense filed an agreement with the state court. | State court | View |
| N/A | N/A | Entry into the NPA (Non-Prosecution Agreement) and declination. | Florida | View |
| N/A | N/A | Original bail hearing where defense argued the case was weak. | Court | View |
| N/A | N/A | Renewed Bail Motion | Court | View |
| N/A | N/A | Provision of Jencks Act materials | Unspecified | View |
| N/A | N/A | Stipulation regarding Defense Exhibit A-1 being received in evidence. | Court | View |
| N/A | Post-trial hearing | A hearing conducted by the District Court where it allegedly abused its discretion by limiting th... | N/A | View |
| N/A | Legal proceeding | The Defense proposes a set of 14 conditions for Mr. Epstein's release on bail. | Court | View |
| N/A | Legal dispute | The defense is arguing that the government must produce unredacted reports containing Brady mater... | Court | View |
| N/A | Legal filing | The defense submitted a financial report to the Court detailing the defendant's assets as part of... | Court | View |
| N/A | Court ruling | A judge makes several rulings on objections from the government and defense regarding the admissi... | Courtroom | View |
| N/A | Legal proceeding | A judge overrules objections made by the defendant, Ms. Maxwell, to paragraphs 79 and 81 of a doc... | N/A | View |
| N/A | N/A | Defense advanced an argument which the Court rejected; Court referred jury to instructions. | Courtroom | View |
| N/A | Legal proceeding | The defense cross-examined Jane at length about her timeline and recollection of the trip to see ... | Court | View |
| N/A | Filing | The defense submitted a brief financial summary of Mr. Epstein's assets to the Court under seal. | Court | View |
| N/A | N/A | Destruction or return of materials to the Government following the conclusion of the case. | N/A | View |
| N/A | Trial | The document discusses the scope of a trial, arguing that introducing certain evidence about gove... | N/A | View |
DOJ-OGR-00013285.jpg
This document is an excerpt from a court transcript dated August 10, 2022, where the Court discusses a proposed limiting instruction for the jury. The instruction clarifies that testimony from a witness about alleged sexual conduct with Mr. Epstein in New Mexico is not considered 'illegal sexual activity' as charged by the government in the indictment. The Court also references a prior November 23rd conference where the defense agreed with the instruction, and notes complications related to New Mexico law.
DOJ-OGR-00010770.jpg
This document is page 17 of 353 from a court filing (Document 688, filed June 29, 2022) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It displays a portion of a jury questionnaire filled out by 'Juror ID: 2'. The juror indicates 'No' to questions regarding whether previous experiences would prevent impartiality, whether they have financial disputes with the government, and whether they or their family work in law enforcement or the justice system.
DOJ-OGR-00010415.jpg
This is the signature page (page 2) of a legal document filed on May 11, 2022, in the case 1:20-cr-00330-PAE (the Ghislaine Maxwell criminal trial). It lists Damian Williams as the United States Attorney, with specific signatures from Assistant US Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach representing the Southern District of New York. The document indicates a copy was sent to the Defense Counsel via ECF.
DOJ-OGR-00009805.jpg
This document is page 7 of a court filing (Document 643) from March 11, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It details the voir dire responses of five specific jurors (63, 93, 113, 189, 239) who answered 'Question 48' affirmatively regarding past sexual abuse or harassment but were deemed impartial and not challenged for cause by either the prosecution or defense. The document highlights that despite personal histories of abuse, these jurors affirmed their ability to remain fair during the trial.
DOJ-OGR-00009651.jpg
This legal document, dated March 1, 2022, addresses the potential bias of Juror 50 in Case 1:20-cr-00330-PAE. It details questions posed to Juror 50 regarding his recollection of a jury questionnaire about sexual abuse, particularly in light of an interview he gave to a Daily Mail reporter. The document argues that Juror 50's childhood sexual abuse, similar to that of witnesses, is sufficient grounds for a 'for cause' challenge, citing legal precedent on implied and inferable bias.
DOJ-OGR-00009576.jpg
This document is page 14 of a court filing (Document 621) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It discusses a specific jury note sent during deliberations regarding 'Count Four' and whether aiding in the return flight of a victim named 'Jane' (but not the flight to New Mexico) constituted guilt if the intent was sexual activity. The text details the defense's attempt to add jury instructions to limit the scope of intent to New York, which the Court rejected.
DOJ-OGR-00009373.jpg
This document is a page from a court transcript (Page 312, Case 1:20-cr-00330-AJN) documenting the redirect examination of a witness named Ms. Brune by Mr. Davis. The proceedings involve the identification and admission of 'Government Exhibit 28,' which is described as a July 21st letter written by Ms. Brune to the Court. Following the admission of the letter into evidence without objection from Mr. Shechtman, the questioning turns to a Westlaw report attached as an exhibit.
DOJ-OGR-00003122.jpg
This document is a page from a legal filing arguing against a defendant's motion to strike allegations concerning 'Minor Victim-3'. The prosecution asserts that evidence regarding this victim is relevant and admissible for proving the conspiracies charged in Counts One and Three involving Epstein, citing established conspiracy law.
DOJ-OGR-00014676.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. The Judge expresses frustration to Ms. Comey (Government) about a three-hour delay in providing requested transcripts to the jury. The Judge also instructs court staff (Ms. Williams) to contact alternate jurors to inform them that deliberations are ongoing.
DOJ-OGR-00014561.jpg
This document is a court transcript from August 10, 2022, capturing a dialogue between a judge and several attorneys regarding the final preparations for trial exhibits. The counsel confirms that the exhibits have been reviewed by both the defense and the government and are ready for the jury. The judge provides instructions to mark the finalized list as a Court Exhibit.
DOJ-OGR-00020115.jpg
This page from a legal filing (Document 102) outlines arguments by Ghislaine Maxwell's defense team refuting the government's claim that she is a flight risk. The defense argues that her use of a trust and pseudonym to buy a home was for protection against harassment, not to hide, and emphasizes her willingness to waive extradition rights to France and the UK. It also addresses conflicting expert opinions regarding whether France would extradite her, contrasting expert William Julié's report with a general letter from the French Ministry of Justice.
DOJ-OGR-00020074.jpg
This document is page 14 of a court filing (Case 1:20-cr-00330-AJN, likely United States v. Ghislaine Maxwell) filed on December 28, 2020. The text argues that government evidence, including documentary evidence and witness testimony, 'virtually indisputably' proves that the defendant and Jeffrey Epstein interacted with minor victims. The document addresses a defense complaint regarding the volume of evidence produced in discovery, though specific details of the defense's argument and specific evidence are heavily redacted.
DOJ-OGR-00005600.jpg
This legal document is a filing by Ms. Maxwell's defense team arguing that the government has violated a court order regarding pre-trial disclosure. The defense claims that instead of identifying specific co-conspirator statements as ordered, the government has improperly directed them to sift through hundreds of thousands of statements from devices seized from Epstein. This tactic, they argue, makes it impossible to prepare for trial and subverts the Court's intention to have such issues litigated in advance.
DOJ-OGR-00005569.jpg
This document is page 15 of a Government filing dated October 29, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330). It discusses the Government's proposal to protect the identities of Minor Victims 1, 3, 4, and 6 through the use of pseudonyms or first names only during testimony. The text explicitly links the 'intimate details of childhood sexual abuse' to both the defendant and Jeffrey Epstein.
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-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-00005245.jpg
This document is Page 3 of a legal filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), dated October 15, 2021. It contains a submission by the US Attorney's office followed by a 'SO ORDERED' endorsement from the Judge (Alison J. Nathan). The Judge denies a specific order requested by the defense but establishes a firm expectation that Maxwell should receive legal mail within approximately one business day to ensure she can prepare for trial.
DOJ-OGR-00005227.jpg
This document is page 2 of a legal filing addressed to Judge Alison J. Nathan regarding the case of Ms. Maxwell. The defense counsel argues against the government's proposed deadline for a Rule 412 motion, requesting more time to review over 8,000 pages of recently disclosed material and witness information. The defense asserts that a deadline before November 15 is unreasonable given the volume of new evidence and the defendant's custodial status.
DOJ-OGR-00017599.jpg
This document is a court transcript filed on August 10, 2022, capturing a procedural discussion between a judge and several attorneys (Ms. Comey, Ms. Menninger, Ms. Moe). The main topics are setting a 9:00 p.m. deadline for both the government and defense to submit letters regarding a dispute over Rule 16, and initiating a discussion on how to handle witness identifying information.
DOJ-OGR-00011664.jpg
This is the final page (43) of a court transcript from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The proceedings conclude with the Judge instructing Ms. Comey (Government) and Ms. Sternheim (Defense) to confer regarding rebuttal witnesses and submit a letter by Saturday if there is a disagreement. The court adjourns for the Thanksgiving holiday.
DOJ-OGR-00011642.jpg
This document is a partial court transcript from a case filed on August 10, 2022, discussing the anticipated testimony of Mr. Flatley. His testimony concerns the retrieval of metadata from devices seized from Epstein's home, and the possibility of Mr. Kelso serving as a rebuttal witness. The government and defense are preparing for this testimony and related disclosures, with Mr. Flatley having given similar testimony in other cases.
DOJ-OGR-00011537.jpg
This document is a partial transcript from a court hearing on July 22, 2022, discussing factual objections and the calculation of sentencing guidelines. The Court, Mr. Everdell, and Ms. Moe participate in the discussion, with the Court adopting PSR recitations and outlining the process for guideline calculation. The defense contends a guideline calculation of 51 to 63 months' imprisonment, while the government's contention is cut off.
HOUSE_OVERSIGHT_019622.jpg
This document is the first page of Chapter 14, titled "The Crime Scene Investigation." It opens with a quote from Edward Snowden regarding NSA security vulnerabilities and begins a narrative description of a secure NSA facility located near Honolulu, Oahu, detailing its history from World War II to its modern role in intelligence gathering.
HOUSE_OVERSIGHT_031584.jpg
This document discusses the progress in negotiations regarding the Cyprus problem, highlighting the Joint Declaration of February 11, 2014, as a key milestone toward a solution. It analyzes the far-reaching consequences of the conflict, noting how it hinders broader cooperation, specifically negatively affecting Turkey-Greece relations, Turkey's EU accession bid, and EU-NATO strategic cooperation due to objections from the Greek Cypriot side.
HOUSE_OVERSIGHT_020894.jpg
The document consists of two presentation slides, likely from a KPCB 'USA Inc.' report, analyzing US government spending trends. Slide 105 compares government healthcare spending (rising from 1.2% to 8.2% of GDP) against education spending between 1960 and 2009. Slide 106 details the shift in healthcare funding sources, highlighting the growth of Medicare and Medicaid from 0% in 1960 to 35% of total spending in 2008, alongside a massive increase in total healthcare spending from $187B to $2.5T. The document bears a 'HOUSE_OVERSIGHT' Bates stamp.
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