Defense
OrganizationRelationship Network
Event Timeline
| 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 |
|---|---|---|---|---|
| 2021-11-08 | Legal deadline | Deadline for Defense disclosures pursuant to Rules 16(b)(1)(A) and 16(b)(1)(B) materials. | N/A | View |
| 2021-11-08 | N/A | Simultaneous filing of requests to charge and verdict sheet | SDNY Court | View |
| 2021-11-08 | N/A | Defense disclosures pursuant to Rules 16(b)(1)(A) and 16(b)(1)(B) | SDNY Court | View |
| 2021-11-06 | Legal disclosure | Notes from an interview with Jane were provided to the defense. | N/A | View |
| 2021-11-06 | N/A | Court's order regarding Minor Victim-3 issued 'yesterday' relative to the email date. | Southern District of New York | View |
| 2021-11-05 | N/A | Tentative date for hearing regarding Rule 412 motions. | SDNY Court | View |
| 2021-11-03 | N/A | Requested new deadline for filing joint proposed jury charge and verdict sheet. | SDNY | View |
| 2021-11-03 | N/A | New deadline to file joint proposed jury charge and verdict sheet. | USDC SDNY | View |
| 2021-11-03 | N/A | Government submits joint request to charge and proposed verdict sheet to the Court. | Southern District of New York | View |
| 2021-11-01 | Evidence inspection | The defense personally inspected a document exhibit made available by the government. | N/A | View |
| 2021-11-01 | N/A | Jury selection and Thanksgiving holiday. | Court | View |
| 2021-11-01 | N/A | Defense expert disclosures | SDNY Court | View |
| 2021-11-01 | N/A | Responses to motions in limine | SDNY Court | View |
| 2021-11-01 | N/A | Deadline for defense to send redlined version of jury charge to government (7:00 p.m.). | N/A | View |
| 2021-11-01 | N/A | Court Conference | Court | View |
| 2021-11-01 | N/A | Pretrial conference where the Court directed parties to file this joint letter. | Southern District of New York | View |
| 2021-11-01 | N/A | Court conference where the Court precluded affirmative evidence regarding the thoroughness of the... | S.D.N.Y. | View |
| 2021-11-01 | N/A | Agreed deadline for defense to send redlined counterproposals to government (by 7:00 p.m.). | N/A | View |
| 2021-11-01 | N/A | Pretrial Conference | Court | View |
| 2021-10-29 | N/A | Filing of Document 397 | US District Court (SDNY imp... | View |
| 2021-10-29 | Court filing | Filing of Document 383 in Case 1:20-cr-00330-PAE, arguing against the admissibility of a Non-Pros... | N/A | View |
| 2021-10-29 | Legal filing | Filing of Document 383 in Case 1:20-cr-00330-PAE. | N/A | View |
| 2021-10-29 | N/A | Deadline to file public docket briefing with proposed redactions and joint justification letter. | USDC SDNY | View |
| 2021-10-29 | N/A | Filing of Document 397-1 in Case 1:20-cr-00330-PAE. | Court Record | View |
| 2021-10-27 | N/A | Deadline to file a joint proposed RTC (Requests to Charge) in the Maxwell case. | Court | View |
EFTA00038003.pdf
An email from an Assistant US Attorney (SDNY) dated July 6, 2020, discussing the logistics of property transported with Ghislaine Maxwell. While her personal effects (clothes, jewelry, phone) were released to her defense counsel, the US Marshals requested that specific security footage from the local jail where she was held be picked up from 500 Pearl Street and stored in files, as the Bureau of Prisons (BOP) refused to keep it.
EFTA00032906.pdf
This document is an 'Access to Justice' email newsletter from Law360 dated April 20, 2020. It aggregates various legal news stories, primarily focused on the impact of the COVID-19 pandemic on the justice system, including court closures, remote hearings, and bankruptcy issues. It is relevant to the Epstein files because it contains a summary of a recent Eleventh Circuit ruling that the Crime Victims' Rights Act protections do not arise until after a formal criminal charge is filed, which is described as a blow to Epstein's victims.
EFTA00031115.pdf
This document is an email chain from November 24, 2021, between unidentified legal professionals (likely DOJ prosecutors) regarding legal strategy. They are discussing a request for briefing materials to counter defense counsel's attempt to call numerous agents to testify in an effort to 'impeach the investigation.' One participant notes they are dealing with this same issue in the 'Maxwell' case (Ghislaine Maxwell) and shares a ruling from Judge Nathan (AJN) and relevant motions in limine (MIL).
EFTA00029243.pdf
This document is an internal email chain from the US Attorney's Office for the Southern District of New York (USANYS) dated April 8, 2021. The emails discuss drafting a response to a letter from Ghislaine Maxwell's defense counsel regarding the 'S2 Indictment,' with a deadline set for the following day. The document includes file names for the draft response and the original defense letter.
EFTA00028278.pdf
This document is an email dated November 12, 2021, from an Assistant United States Attorney in the Southern District of New York to a colleague. The sender requests the preparation of a binder for an upcoming court appearance on the following Monday, attaching various legal documents related to the Ghislaine Maxwell trial, including motions regarding 'MV-3' (Minor Victim 3), expert witnesses Dietz and Loftus, and responses to the defense.
EFTA00027665.pdf
This document is an email chain from November 12, 2021, regarding the preparation and review of juror questionnaires for the 'US v. Maxwell' trial. It discusses uploading files to USAfx, sharing them with defense counsel, and setting deadlines for the legal team to review and object to juror batches. The attachment filename explicitly links the correspondence to the Ghislaine Maxwell trial.
EFTA00027303.pdf
An email chain from August 2021 among legal team members (likely prosecution) discussing the organization of witness files for an upcoming trial. The emails specifically mention filing notes for Larry Visoski (Epstein's pilot) into a 'testifying witness 3500 folder' and an 'Epstein share'. They also discuss deadlines for producing '3500' (Jencks Act material) and 'GX' (Government Exhibits) to the defense and court.
EFTA00027291.pdf
An email chain between US Attorneys regarding the retrieval and production of Epstein-related documents originating from the Bureau of Prisons (BOP). The discussion focuses on locating versions of FOIA documents without a 'translucent green watermark' for submission to the Court, with one attorney confirming they have a set previously produced to defense counsel.
EFTA00026699.pdf
An email dated October 12, 2021, between redacted parties (likely prosecution team members) discussing a revised letter regarding the length of the Ghislaine Maxwell trial. The sender asks the recipient to review the attached document before a scheduled 7:30 call so it can be forwarded to supervisors ('chiefs') and the defense team.
EFTA00024507.pdf
This document is an email chain from December 2019 between legal representatives for the Epstein Estate (Trustees) and Government officials (likely SDNY). The Estate is requesting search warrant inventories for Epstein's New York and New Mexico properties to aid in estate administration. The Government clarifies that previous defense counsel destroyed or returned discovery materials following Epstein's suicide but provides specific Bates numbers for relevant documents and discusses scheduling a meeting to resolve potential forfeiture claims.
EFTA00023728.pdf
This document contains a chain of emails between the FBI's NY CART team and the US Attorney's Office (SDNY) regarding the technical processing of digital evidence seized from Jeffrey Epstein's properties in New York and the Virgin Islands. The correspondence highlights significant technical challenges, including the incompatibility of forensic data with the 'Relativity' review platform, the massive volume of data (terabytes), and delays caused by FBI network upgrades and COVID-19 remote work. The US Attorney's office expresses frustration with the organization of the data, specifically requesting better linkage between emails and attachments and clearer identification of seized devices by serial number.
EFTA00019470.pdf
An email dated July 13, 2020, from a U.S. Pretrial Services Officer in the Southern District of New York regarding Ghislaine Maxwell. The email attaches a bail report (filename: 6653181._Maxwell,_Ghislaine.pdf) and notes that Maxwell is scheduled for a remote appearance the following day. It includes strict confidentiality warnings citing Local Rule 57.1 and Title 18 U.S.C. § 3153(c)(1).
EFTA00019194.pdf
An email exchange dated October 10, 2021, between unidentified parties (likely legal counsel) discussing the formatting and sharing of the 'Maxwell Jury Questionnaire' and a 'Joint Proposed Voir Dire' document. The sender expresses concern about accurately applying color-coded formatting changes (red to green, blue to purple) likely representing edits from the Defense and Government teams.
EFTA00019193.pdf
This document is an email header dated October 10, 2021, transmitting a document titled 'Maxwell Jury Questionnaire'. The attachment appears to be a legal draft coordinating jury selection questions between the Defense and the Government (prosecution), likely for the trial of Ghislaine Maxwell. The sender and recipient identities are redacted.
EFTA00019111.pdf
An email chain from June 2020 involving attorney Bruce Barket acknowledging receipt of a sealed ex parte order from Judge Karas regarding case 16cr832. The correspondence involves defense counsel, firewall counsel, and representatives from the US Attorney's Office for the Southern District of New York (USANYS).
EFTA00019043.pdf
This document is an email dated October 8, 2021, concerning the preparation of jury questionnaires and voir dire questions, likely for the Ghislaine Maxwell trial as indicated by the attachment filename. The sender discusses difficulties in combining drafts from opposing legal teams and schedules a conferral for that afternoon to discuss the documents further.
EFTA00018264.pdf
An email chain between members of a legal team (likely the prosecution given the context of sharing materials *with* 'defense counsel') regarding the US v. Maxwell trial in November 2021. The correspondence focuses on the review, assignment, and sharing of juror questionnaires via the USAfx platform, with specific deadlines set for objections to juror batches. The attachment filename explicitly references 'US_v._Maxwell_Juror_Questionnaire_Review'.
EFTA00016734.pdf
An email exchange dated January 13, 2020, discussing scheduling a meeting. One party requests the availability of 'full brass' (leadership) for a presentation by defense counsel regarding a redacted individual on January 24, 2020. The respondent states they are out sick and cannot access calendars immediately.
DOJ-OGR-00018350.jpg
This document is a page from a court transcript dated August 10, 2022, detailing a discussion between an attorney, Mr. Rohrbach, and the Court. The conversation centers on the government's plan to question a witness about photos of celebrities and nude women in Epstein's residence without submitting the photos as evidence. The Court reserves judgment on the admission of any photo exhibits but indicates it finds the proposed line of questioning acceptable.
DOJ-OGR-00017628.jpg
This page from a court transcript (Case 1:20-cr-00330-PAE) details a discussion between the judge ('The Court') and attorneys Ms. Moe and Ms. Menninger. Ms. Moe updates the court on resolving prior disagreements, requests a sidebar regarding a witness issue, and flags anticipated Rule 408 objections regarding defense exhibits.
DOJ-OGR-00017615.jpg
This document is a page from a court transcript dated August 10, 2022. An attorney, Mr. Everdell, is arguing a procedural point to the judge about the defense's ability to introduce its own evidence through a witness called by the government. He provides two examples: a real one involving FedEx records and a hypothetical one involving a witness named Larry Visoski who recently testified about pictures of Little St. James Island.
DOJ-OGR-00008421.jpg
This is the signature page (page 3 of 3) of a legal document filed on December 17, 2021, in Case 1:20-cr-00330-PAE (the Ghislaine Maxwell trial). The document is submitted by United States Attorney Damian Williams and signed by Assistant US Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach representing the Southern District of New York. It notes that items 'have been read into the record' and indicates a copy was emailed to Defense Counsel.
DOJ-OGR-00008391.jpg
This legal document is a page from a court filing, specifically page 5 of 6 from Document 548 in case 1:20-cr-00330-PAE, filed on December 15, 2021. The Court denies the Defense's request for a witness to testify under a pseudonym, arguing that the witness does not qualify as a victim under the Crime Victims' Rights Act because her anticipated testimony is that she was not a target of sexual misconduct by Epstein or Ms. Maxwell. The Court distinguishes this situation from a prior ruling where pseudonyms were allowed to protect the identities of other, actual victims.
DOJ-OGR-00008390.jpg
This legal document, page 4 of a court filing dated December 15, 2021, details the Court's rejection of the Defense's request to allow a witness to testify under a pseudonym. The Court finds the request untimely, notes that other legal tools like a letter rogatory were available to compel testimony, and distinguishes the case from precedents involving undercover officers whose safety or operational effectiveness would be compromised by revealing their identity.
DOJ-OGR-00008337.jpg
This is a court transcript from a case filed on December 10, 2021, detailing a conversation between the judge and attorneys for the defense and government. The discussion focuses on whether the defense will call expert witnesses (LaPorte and Naso), with a defense attorney stating it's unlikely and was only considered as a precaution regarding 'Accuser No. 2'. A government attorney expresses concern about the potential for the defense to decide to call these experts in the middle of the trial.
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