Jeffrey S. Pagliuca
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Client |
48
Very Strong
|
120 | |
|
person
GHISLAINE MAXWELL
|
Legal representative |
21
Very Strong
|
26 | |
|
person
GHISLAINE MAXWELL
|
Professional |
10
Very Strong
|
73 | |
|
person
Laura A. Menninger
|
Professional |
10
Very Strong
|
8 | |
|
person
Ms. Maxwell
|
Client |
9
Strong
|
3 | |
|
person
ALISON J. NATHAN
|
Legal representative |
7
|
3 | |
|
person
Laura A. Menninger
|
Business associate |
7
|
3 | |
|
person
Ms. Maxwell
|
Professional |
7
|
2 | |
|
person
ALISON J. NATHAN
|
Professional |
6
|
2 | |
|
organization
HADDON, MORGAN & FOREMAN P.C.
|
Professional employment |
6
|
1 | |
|
person
MAXWELL
|
Professional |
5
|
1 | |
|
person
Counsel of record
|
Professional |
5
|
1 | |
|
organization
Haddon, Morgan & Foreman, P.C.
|
Professional employment membership |
5
|
1 | |
|
person
MS. MENNINGER
|
Professional |
5
|
1 | |
|
person
Nicole Simmons
|
Business associate |
5
|
1 | |
|
person
Nicole Simmons
|
Legal representative |
5
|
1 | |
|
person
Nicole Simmons
|
Professional |
2
|
2 | |
|
organization
Haddon, Morgan and Foreman, P.C.
|
Employment affiliation |
1
|
1 | |
|
person
GHISLAINE MAXWELL
|
Potentially defense counsel |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2025-08-07 | N/A | Order Granting Motion to Withdraw | Southern District of New York | View |
| 2025-08-06 | Legal proceeding | A proposed order was filed granting the motion for attorneys Jeffrey S. Pagliuca and Laura A. Men... | UNITED STATES DISTRICT COUR... | View |
| 2025-08-06 | Legal filing | The declaration regarding the change of counsel and withdrawal of HMF was dated and submitted. | N/A | View |
| 2025-08-05 | N/A | Attorneys Pagliuca and Menninger sign motion to withdraw as counsel. | Denver, CO (implied by sign... | View |
| 2022-06-15 | Legal filing | Document 662 was filed in Case 1:20-cr-00330-PAE. | N/A | View |
| 2022-06-15 | N/A | Filing of Sentencing Memorandum on behalf of Ghislaine Maxwell | Southern District of New York | View |
| 2022-03-11 | N/A | Filing of Reply Memorandum | United States District Cour... | View |
| 2022-03-11 | Court filing | Filing of "GHISLAINE MAXWELL’S REPLY IN SUPPORT OF HER MOTION FOR A NEW TRIAL". | UNITED STATES DISTRICT COUR... | View |
| 2022-03-11 | Legal filing | Filing of 'GHISLAINE MAXWELL’S MOTION FOR A NEW TRIAL' with the court. | UNITED STATES DISTRICT COUR... | View |
| 2022-03-11 | Legal filing | Filing of Document 642 in Case 1:20-cr-00330-PAE. | N/A | View |
| 2022-03-02 | Legal filing | A document was filed with the court requesting a continuance. | N/A | View |
| 2022-02-24 | Legal filing | Document 616 was officially filed with the court in case 1:20-cr-00330-PAE. | N/A | View |
| 2022-02-24 | Legal filing | Ghislaine Maxwell's attorneys filed a reply in support of her motion for a new trial. | UNITED STATES DISTRICT COUR... | View |
| 2022-02-24 | Legal filing | Document 612 was filed in Case 1:20-cr-00330-PAE. | Court associated with Case ... | View |
| 2022-02-24 | Legal filing | A motion for a new trial was filed on behalf of Ghislaine Maxwell. | UNITED STATES DISTRICT COUR... | View |
| 2022-02-24 | Legal filing | Document 613-1 was filed in case 1:20-cr-00330-PAE. | N/A | View |
| 2022-02-11 | N/A | Filing of legal motion seeking to vacate conviction and enter judgment of acquittal | New York, New York | View |
| 2022-02-11 | Legal filing | Filing of an Omnibus Memorandum in Support of Her Post-Trial Motions by Ghislaine Maxwell's attor... | UNITED STATES DISTRICT COUR... | View |
| 2022-02-09 | Legal filing submission | A legal document was dated and submitted, requesting a new trial or an evidentiary hearing to exa... | N/A | View |
| 2022-02-09 | N/A | Submission of legal motion requesting a new trial or an evidentiary hearing to examine jurors. | New York (Southern District... | View |
| 2022-01-05 | Legal filing | Filing of a letter by Jeffrey S. Pagliuca to Judge Nathan in the case of United States v. Ghislai... | United States District Cour... | View |
| 2021-12-29 | Jury trial | Jury Trial for the case of United States of America v. Ghislaine Maxwell, Case 1:20-cr-00330-PAE,... | New York, N.Y. | View |
| 2021-12-28 | Jury trial | Court proceedings for the jury trial in the case of United States of America v. Ghislaine Maxwell. | United States District Cour... | View |
| 2021-12-27 | Jury trial | Jury Trial for the case of United States of America v. Ghislaine Maxwell, Case 20 CR 330 (AJN). | United States District Cour... | View |
| 2021-12-22 | N/A | Jury Trial proceedings in USA v. Ghislaine Maxwell | New York, N.Y. | View |
22-1426_Documents.pdf
This document consists of a Docketing Notice from the Second Circuit Court of Appeals dated July 8, 2022, for the appeal of Ghislaine Maxwell (Case 22-1426), and a Notice of Appeal and Criminal Docket from the Southern District of New York (Case 1:20-cr-00330-AJN) filed July 7, 2022. It details Maxwell's conviction and sentencing, including multi-year imprisonment terms and a $750,000 fine for charges related to conspiracy to entice minors for illegal sex acts, transport minors for sexual activity, and sex trafficking, with some counts dismissed or deemed multiplicitous.
20-3061_Documents.pdf
This document is the complete appellate record for case 20-3061, an interlocutory appeal by Ghislaine Maxwell against the United States. Maxwell appealed a District Court order denying her motion to modify a protective order, seeking permission to share confidential criminal discovery materials under seal with the judge in a related civil case (Giuffre v. Maxwell) to challenge the government's acquisition of evidence. The Second Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, ruling that the protective order decision was not a final judgment or an appealable collateral order, and denied Maxwell's motion to consolidate the criminal appeal with the civil appeal.
037.pdf
This court document from April 7, 2017, details a 'Notice of Submission of Witness Solicitation Materials' filed in the case of Bradley J. Edwards v. Ghislaine Maxwell. Plaintiff Virginia Giuffre submitted witness solicitation materials for in camera review as per a March 23, 2017, court ruling. The document also includes a certificate of service, confirming electronic filing and service to attorneys Laura A. Menninger and Jeffrey S. Pagliuca.
036.pdf
A legal filing (Sur-Reply) by Ghislaine Maxwell's attorneys arguing that Plaintiff Bradley Edwards must produce solicitation letters sent to former Epstein employees and their responses. The defense argues Edwards waived work-product privilege by failing to produce a privilege log and that the letters sent to third parties do not constitute work product.
033.pdf
This document is a Reply Memorandum filed by attorney Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell. Edwards argues that Maxwell's requests for his communications with 'prospective witnesses' are overbroad, unduly burdensome, and seek protected attorney work-product. The filing notably alleges that Maxwell has failed to explain her presence on 23 flights with a teenaged Virginia Giuffre or the message pads documenting underage girls calling Epstein's mansion for 'massages'.
030.pdf
This document is a Civil Docket Report for Case No. 0:16-mc-61262-JG, filed in the U.S. District Court for the Southern District of Florida on June 13, 2016. The case involves Plaintiff Bradley J. Edwards filing a motion to quash a subpoena against Defendant Ghislaine Maxwell. The docket records various motions, including requests to seal exhibits and appear Pro Hac Vice, culminating in an order on December 22, 2016, to transfer the motion to the Southern District of New York to be handled as part of the case Giuffre v. Maxwell (1:15-cv-07433-RWS). The case was terminated in the Florida court on December 23, 2016.
024.pdf
This document is a legal notice filed by Ghislaine Maxwell's attorneys on December 16, 2016, in the Southern District of Florida regarding a subpoena served on Bradley J. Edwards. Maxwell argues that rulings made by the Southern District of New York on a similar subpoena served on Paul Cassell (another attorney for Virginia Giuffre) should be binding (res judicata) on the Edwards subpoena. The filing includes a table comparing the requests in both subpoenas and the corresponding rulings from the SDNY court, asking the Florida court to issue a consistent order requiring production of certain documents and granting the motion to quash for others.
023.pdf
This document is a formal notice filed on December 16, 2016, in the Southern District of Florida, by attorneys for Ghislaine Maxwell. It informs the court and opposing counsel (specifically Bradley J. Edwards' attorney Jack Scarola) that 'Exhibit B' related to a subpoena status notice has been filed under seal. The underlying case referenced is Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York.
022.pdf
This document is a motion filed on December 16, 2016, by Ghislaine Maxwell's attorneys in the Southern District of Florida. The motion requests permission to file 'Exhibit B' under seal, noting that the exhibit is a sealed order from the Southern District of New York in the underlying 'Giuffre v. Maxwell' case. The document lists legal counsel for Maxwell and for Bradley J. Edwards, who is the subject of a subpoena in this miscellaneous action.
015.pdf
This document is a Motion to Seal filed on July 7, 2016, by attorney Jack Scarola on behalf of Bradley J. Edwards in the U.S. District Court for the Southern District of Florida. Edwards seeks to seal exhibits attached to his Motion to Quash a subpoena, specifically referencing confidential depositions of Ghislaine Maxwell and Rinaldo Rizzo, as well as documents related to Alan Dershowitz, which are already under seal in the Southern District of New York. The motion argues that sealing is necessary to comply with protective orders from the underlying case.
013.pdf
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
012.pdf
This document is a motion filed on July 7, 2016, in the Southern District of Florida by attorney Jack Scarola on behalf of Bradley J. Edwards. Edwards requests permission to file a reply exceeding the standard page limit (up to 25 pages) in support of his motion to quash a subpoena served by Ghislaine Maxwell. The motion explains that the extra length is necessary to address allegations made by Maxwell regarding Edwards' prior filings and alleged discovery withholding by his client, Virginia Giuffre.
010.pdf
Declaration by Jeffrey S. Pagliuca, attorney for Ghislaine Maxwell, filed on June 30, 2016, in the Southern District of Florida. The document lists 18 exhibits (A-R) supporting Maxwell's opposition to Bradley J. Edwards' motion to quash a subpoena. Several exhibits are filed under seal, while others include procedural documents from related cases (Cassell v. Dershowitz, Epstein v. Rothstein, Jane Doe v. US) and communications regarding discovery and subpoenas.
007.pdf
This document is a 'Notice of Filing' submitted to the U.S. District Court for the Southern District of Florida on June 29, 2016. It serves to notify the court and opposing counsel that Defendant Ghislaine Maxwell has filed Exhibits A, G, H, I, and N under seal. These exhibits are attached to a declaration by her attorney, Jeffrey S. Pagliuca, in support of her opposition to Bradley J. Edwards' motion to quash a subpoena.
006.pdf
This document is a motion filed on June 29, 2016, by attorneys for Ghislaine Maxwell in the Southern District of Florida. The motion requests permission to file specific exhibits (A, G, H, I, and N) under seal because they were designated as confidential in the underlying case (Giuffre v. Maxwell) in the Southern District of New York. The document includes a certificate of service indicating the motion was served electronically to attorney Jack Scarola representing Bradley J. Edwards.
005.pdf
This document is a Motion to Appear Pro Hac Vice filed on June 29, 2016, in the Southern District of Florida. Attorney Denise D. Riley requests that attorney Jeffrey S. Pagliuca of the Colorado firm Haddon, Morgan and Foreman be admitted to represent Defendant Ghislaine Maxwell in matters related to a subpoena issued to Bradley J. Edwards. The document includes contact information for the attorneys involved and a certificate of service to opposing counsel Jack Scarola.
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
005-01.pdf
This document is a formal certification filed by attorney Jeffrey S. Pagliuca in the United States District Court for the Southern District of Florida on June 29, 2016. It pertains to a subpoena issued to Bradley J. Edwards in relation to the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. Pagliuca certifies his compliance with local rules and his good standing with the Colorado bar.
001-05.pdf
This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.
001-03.pdf
This document is a subpoena issued by the US District Court (SDNY) on behalf of Defendant Ghislaine Maxwell to attorney Bradley J. Edwards in May 2016. It demands the production of various documents, including those related to previous litigation involving Jeffrey Epstein and Alan Dershowitz, communications with journalist Sharon Churcher, and records regarding the organization 'Victims Refuse Silence, Inc.' A check for $45.00 payable to Edwards is included, likely as a witness fee.
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
EFTA00038962.pdf
This document is an email forwarding a Notice of Electronic Filing from the U.S. District Court (SDNY) regarding the case USA v. Maxwell. On April 29, 2022, Judge Alison J. Nathan issued an Opinion & Order denying Ghislaine Maxwell's Rule 29 motion and confirming her conviction on Counts Three, Four, and Six, while dismissing other counts as multiplicitous. The order explicitly mentions Jeffrey Epstein as a co-conspirator in a scheme to abuse underage girls and confirms Maxwell's sentencing date for June 28, 2022.
EFTA00032234.pdf
This document is an email dated August 18, 2020, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers. The email serves to transmit a sealed Letter Motion, Affidavit, and ten exhibits on behalf of defendant Ghislaine Maxwell regarding a 'Request to Modify Protective Order' in the case United States v. Ghislaine Maxwell. The filing was made at the request of attorney Jeffrey S. Pagliuca.
EFTA00031918.pdf
This document is a Reply Memorandum filed on March 16, 2021, by Ghislaine Maxwell's defense team in support of her third motion for bail. The defense proposes a comprehensive bail package including a $28.5 million bond, asset monitoring by a retired federal judge, and renunciation of her British and French citizenships to mitigate flight risk concerns. Attached as Exhibit A is a legal opinion from French attorney William Julié arguing that if Maxwell renounces her French citizenship, she would no longer be protected from extradition by France, countering the French Ministry of Justice's position.
EFTA00031690.pdf
This document is an email chain from May 3, 2021, forwarding a 'Notice of Electronic Filing' from the U.S. District Court for the Southern District of New York regarding the case USA v. Maxwell. The notice contains the text of an order by Judge J. Nathan granting a continuance of the trial until Fall 2021 to allow the defense time to prepare for additional charges in the S2 indictment. The order mandates that the parties meet and confer by May 10, 2021, to propose a specific trial start date.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2016-06-29 | Paid | Jeffrey S. Pagliuca | United States Dis... | $75.00 | Admission fee for pro hac vice appearance | View |
Ms. Maxwell's Fed. R. Evid. 412 Motion
Letter regarding evidence motion
Ms. Maxwell's Fed. R. Evid. 412 Motion
A letter filed by Ghislaine Maxwell's counsel, Jeffrey S. Pagliuca, to Judge Alison J. Nathan regarding a motion under Federal Rule of Evidence 412.
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Notification that Maxwell's Omnibus Response to Government's Motions in Limine was filed under seal to allow time for redaction review.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Letter regarding the case.
Request to reserve the right to file additional/supplemen...
A letter from Ms. Maxwell's counsel to the judge arguing that there has been insufficient time to review recent government disclosures and prepare filings by the deadline. The letter reserves the right to file additional motions after the deadline, citing a previous court order and issues with accessing encrypted files provided by the government.
United States v. Ghislaine Maxwell, 20 Cr. 330
Correspondence regarding the case.
United States v. Ghislaine Maxwell, 20 Cr. 330
General correspondence letter regarding the case
Deadline for Filing Motion under Federal Rule of Evidence...
Request concerning Rape Shield Law motions.
Deadline for Filing Motion under FRE 412
Letter regarding deadline for filing motion under Federal Rule of Evidence 412
Deadline for Filing Motion under Federal Rule of Evidence...
Request to confirm November 15, 2021 as the deadline for filing a Rule 412 motion, citing recent discovery disclosures and procedural rules.
Filing of a Rule 412 motion
A letter from counsel Jeffrey S. Pagliuca to Judge Alison J. Nathan stating that Ms. Maxwell will file a Rule 412 motion on or before November 15, 2021. The letter argues this timing is necessary to allow counsel to adequately consult with Ms. Maxwell and prepare the motion.
Filing of a Rule 412 motion
A letter from counsel Jeffrey S. Pagliuca to Judge Alison J. Nathan stating that Ms. Maxwell will file a Rule 412 motion on or before November 15, 2021. The letter argues this timing is necessary to allow counsel to adequately consult with Ms. Maxwell and prepare the motion.
Deadline for Filing Motion under Federal Rule of Evidence...
Procedural inquiry regarding Rule 412 motions.
Response to Government Letter dated August 18, 2021
Defense response arguing against government's objection to disclosing co-conspirator identities and statements.
Reply to Government Letter dated May 14 Regarding Propose...
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Response to subpoena
Letter regarding response to subpoena
defense witness disclosures
Joint letter regarding defense witness disclosures (Dkt. No. 250)
Response to Dkt. No. 227, Government's April 21, 2021 Let...
Defense response arguing against deferring resolution of suppression motions, emphasizing the need for an evidentiary hearing due to potential constitutional violations and 'fruit of the poisonous tree' issues.
Response to Government's April 5, 2021 Letter re. Ms. Max...
Letter dated April 15, 2021 filed on docket.
Response to Government's April 5, 2021 Letter re. Ms. Max...
Letter dated April 15, 2021 responding to Government correspondence.
Response to Government's April 5, 2021 Letter re. Ms. Max...
Letter dated April 15, 2021 responding to government regarding subpoena.
Response to Letter Motion to Quash Rule 17 Subpoena to Bo...
Filed on docket 04/23/2021.
Response to the Governments October 7, 2020 letter
Defense response to government correspondence
Response to the Governments October 7, 2020 letter
Defense response to the government's Oct 7 letter.
Impediments to defense preparation for Ms. Maxwell
A letter from defense counsel to the judge complaining that the BOP and MDC are preventing Ms. Maxwell from properly reviewing legal documents with her attorneys. It requests the court to intervene and order the BOP to allow counsel to pass papers to her during visits.
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