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 |
EFTA00030904.pdf
A letter from the U.S. Attorney for the Southern District of New York to Ghislaine Maxwell's defense counsel, Jeffrey Pagliuca, denying a request to use criminal discovery materials in a separate civil lawsuit. The Government cites a Protective Order issued by Judge Alison J. Nathan which restricts the use of such materials solely to the defense of the criminal case to protect an ongoing investigation. The letter suggests counsel use FOIA or Touhy requests if seeking records for civil litigation purposes.
EFTA00030757.pdf
This document contains an email chain forwarding a Notice of Electronic Filing (NEF) from the U.S. District Court (SDNY) regarding the case USA v. Maxwell (1:20-cr-00330-AJN). The NEF details a court order by Judge J. Nathan dated December 8, 2020, which denies Ghislaine Maxwell's request to summon Warden Heriberto Tellez to testify about her confinement conditions. However, the order mandates that the Government submit written updates every 60 days regarding Maxwell's access to legal materials and ability to communicate with counsel.
EFTA00030686.pdf
This document is a Notice of Electronic Filing from the U.S. District Court (SDNY) regarding the case USA v. Maxwell. The filing is a Court Order dated December 8, 2020, in which Judge Nathan denies Ghislaine Maxwell's request to summon Warden Heriberto Tellez to testify regarding her conditions of confinement. The order mandates that the Government provide written updates on Maxwell's conditions, specifically regarding legal access, every 60 days.
EFTA00029816.pdf
This document is a legal memorandum filed by Ghislaine Maxwell's defense team on January 25, 2021, seeking to suppress evidence obtained via subpoena from the law firm Boies Schiller Flexner. The defense argues that the government made false representations to Judge McMahon to bypass a civil protective order and obtain confidential deposition transcripts, alleging collusion between the civil plaintiff's lawyers (Boies Schiller) and federal prosecutors. The document details the history of the civil defamation case, specific deposition questions regarding sexual acts and Epstein, and the procedural history of the protective order modification.
EFTA00029590.pdf
Defense attorney Jeffrey Pagliuca writes to Judge Nathan objecting to the government's recent attempts to avoid disclosing the identities of unnamed co-conspirators and specific co-conspirator statements intended for trial. The defense characterizes the government's position as an improper 'motion to reconsider' prior court orders without showing extraordinary circumstances. The letter requests the Court confirm its orders requiring disclosure by October 11, 2021, to allow the defense to prepare motions in limine regarding the admissibility of statements from Jeffrey Epstein and an unnamed employee.
EFTA00029100.pdf
This legal filing is a Reply Memorandum by Ghislaine Maxwell's defense team, arguing for the suppression of evidence and dismissal of charges based on government misconduct. The defense asserts that prosecutors misled Chief Judge McMahon about the extent of their prior coordination with civil attorneys (Boies Schiller Flexner) to obtain a grand jury subpoena, thereby circumventing a civil protective order. The document details a specific meeting on February 29, 2016, where civil attorneys 'pitched' the prosecution of Maxwell and provided documents, including flight records (though the specific flight data is not listed in this text), which the prosecution later failed to disclose to the judge.
EFTA00028974.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts 1-4 of the superseding indictment. The defense argues that the indictment lacks specificity regarding names, dates, and details of the allegations, preventing Maxwell from preparing an adequate defense. The filing criticizes the government for using vague categories like 'Minor Victims' and 'multiple minor girls' without clarification and cites legal precedents to argue that the lack of specificity violates due process.
EFTA00028968.pdf
This document is a Reply Memorandum filed on March 15, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that Counts 1 and 3 of the Superseding Indictment are multiplicitous (charging the same crime twice based on identical facts) and requests the Court order the government to elect one count to prosecute and dismiss the other prior to trial to avoid jury prejudice. The filing contends that the government has failed to prove the existence of two distinct conspiracies.
EFTA00028929.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell in the United States District Court, Southern District of New York, requesting the suppression of evidence obtained from a government subpoena to Boies Schiller and dismissal of counts five and six. It includes a Table of Contents, Table of Authorities citing various legal cases and rules, and a Table of Exhibits detailing communications and notes related to the case from 2016 to 2021, many involving AUSAs and individuals like Peter Skinner, Stan Pottinger, Brad Edwards, and Sigrid McCawley. The memorandum argues that the government misled the court and that the evidence should be suppressed due to due process violations.
EFTA00028903.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts one through four of her indictment as time-barred. The defense argues that the 2003 Amendment to 18 U.S.C. § 3283, which extended the statute of limitations, cannot be applied retroactively because Congress explicitly rejected a retroactivity provision. Additionally, the defense contends that the Mann Act offenses charged (enticement to travel and transportation of a minor) do not 'necessarily entail' the sexual abuse of a child, and thus the extended statute of limitations under § 3283 does not apply.
EFTA00028880.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting her motion to dismiss the indictment based on the Non-Prosecution Agreement (NPA) Jeffrey Epstein signed in Florida. Maxwell argues that the NPA's clause immunizing 'potential co-conspirators of Epstein' explicitly covers her and bars the current prosecution in the Southern District of New York. The defense contends that the government's attempt to limit the NPA geographically (to Florida) or to specific crimes is contradicted by the plain text of the agreement and legal precedent regarding plea agreements.
EFTA00027169.pdf
Defense attorney Jeffrey Pagliuca writes to Judge Alison Nathan arguing against the government's request to defer ruling on Ghislaine Maxwell's motion to suppress evidence until after the trial on non-perjury counts. The defense contends that an evidentiary hearing is necessary immediately because the government's alleged misconduct (misleading a judge to obtain a subpoena) constitutes a due process violation that could suppress all 90,000 pages of evidence and any derivatives ('fruit of the poisonous tree'). Furthermore, the defense argues that Maxwell cannot knowingly decide whether to testify without knowing the admissibility of this evidence, as the government has only promised not to use it in its case-in-chief but reserved rights for impeachment.
EFTA00024708.pdf
This document contains a court order from Judge Alison J. Nathan in the case of USA v. Maxwell, dated May 14, 2021, and an associated email chain circulating the order. The order denies Maxwell's request to alter detention protocols regarding flashlight checks every 15 minutes, ruling that the checks are necessary for safety in a high-profile case and do not violate her rights. The email chain shows the order being forwarded by a Staff Attorney at MDC Brooklyn.
EFTA00023047.pdf
This document is a 'Notice of Motion' filed on January 25, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The motion seeks to suppress all evidence obtained from a government subpoena to the law firm Boies Schiller and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The document lists the legal counsel representing Maxwell.
EFTA00022960.pdf
This document is a legal filing by Ghislaine Maxwell's defense team objecting to the unsealing of specific docket entries (143, 173, 199, 164, and 230) in the civil case brought by Virginia Giuffre. The defense argues that these documents contain sensitive information regarding non-parties ('Does'), inadmissible hearsay, and prejudicial materials such as flight logs and police reports that were improperly filed to bias the court. The filing emphasizes the need to protect the privacy of non-parties and the integrity of ongoing criminal investigations into Jeffrey Epstein's conduct.
EFTA00021944.pdf
This document is a motion filed by Ghislaine Maxwell's defense team on October 18, 2021, requesting the court to preclude the introduction of Government Exhibits 251, 288, 294, 313, and 606. The defense argues these items—including specific photographs, sex toys ('Twin Torpedos') seized in 2005, and a 'Household Manual'—are irrelevant, lack proper evidentiary foundation, or are unfairly prejudicial under Federal Rules of Evidence 401 and 403. The motion contends that these items do not prove any material fact regarding the charges against Maxwell and serve only to confuse issues or introduce character flaws of Jeffrey Epstein.
EFTA00021902.pdf
This document is a letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's attorney, Jeffrey Pagliuca, denying his request to use discovery materials from her criminal case in a separate civil lawsuit. The Government argues that the materials are related to an ongoing grand jury investigation and are subject to a Protective Order issued by Judge Alison J. Nathan, which explicitly restricts their use to the criminal defense only. The letter suggests that if Pagliuca seeks these records for civil litigation, he must utilize FOIA or a Touhy request.
EFTA00021019.pdf
This document is a Notice of Motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell (20 Cr. 330). The defense team, consisting of attorneys from three separate law firms, formally requests a severance and separate trial for Counts Five and Six of the Superseding Indictment. The filing includes the attorneys' contact information and signatures.
EFTA00019291.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on December 18, 2020, in support of her renewed motion for bail. The defense argues that the government lacks significant documentary evidence, relies solely on witness testimony from decades ago, and that Maxwell has strong ties to the U.S. through her spouse (whose name is redacted) and friends who have pledged assets. The document also addresses flight risk concerns, arguing that extradition from France or the UK is possible or unlikely to be needed due to waivers, and cites a COVID-19 surge at the detention center as further justification for release.
EFTA00018709.pdf
This document is a legal memorandum submitted on February 23, 2021, supporting Ghislaine Maxwell's third motion for release on bail in the SDNY. Maxwell proposes two new conditions to assure her appearance: formally renouncing her French and British citizenships to prevent flight to those countries, and placing all assets (except legal fees and living expenses) into a new account monitored by retired Judge William S. Duffey, Jr. The defense argues these unprecedented conditions, combined with her strong ties to the US, negate flight risk and claims she is being unfairly treated as a substitute for Jeffrey Epstein.
EFTA00018515.pdf
This document is a legal memorandum filed by Ghislaine Maxwell's defense team arguing against the government's motion for detention and requesting release on bail. The defense argues that the COVID-19 pandemic poses a severe health risk and impedes defense preparation, and asserts that Maxwell is not a flight risk, citing her presence in the U.S. since Epstein's arrest. They propose a $5 million bond secured by UK property and strict conditions including home confinement and GPS monitoring.
EFTA00018214.pdf
This document is a subpoena from the US District Court (SDNY) in the case of USA v. Ghislaine Maxwell, issued to Jordana Feldman of the Epstein Victim's Compensation Program (EVCP). The defense (Maxwell's legal team) is demanding the production of all claim forms, communications, payment records, and releases related to four specific (redacted) accusers who submitted claims to the EVCP. The deadline for production was set for November 29, 2021.
EFTA00016720.pdf
This document is a letter from defense attorney Jeffrey Pagliuca to Judge Alison Nathan dated October 14, 2021, regarding the case United States v. Ghislaine Maxwell. The defense requests confirmation that the deadline for filing a motion under Federal Rule of Evidence 412 (regarding alleged victims' sexual behavior) is November 15, 2021. The letter argues that recent massive discovery disclosures (over 8,000 pages of 3500 material) and notices regarding Rule 404(b) witnesses received just three days prior require additional time for review, especially given Maxwell's incarceration.
EFTA00016268.pdf
This document is a defense expert witness disclosure letter in the case United States v. Ghislaine Maxwell, dated November 1, 2021. It details the qualifications and expected testimony of eight expert witnesses, covering topics such as false memory (Dr. Loftus), the lack of scientific basis for 'grooming-by-proxy' (Dr. Dietz), forensic psychiatry, prosecutorial misconduct, computer forensics, and document authentication. The defense strategy aims to challenge the reliability of memory, rebut government claims about grooming behaviors, and analyze financial and physical evidence.
EFTA00016206.pdf
This document is a motion in limine filed by Ghislaine Maxwell's defense team on October 18, 2021, seeking to exclude evidence offered by the government under Rule 404(b) due to lack of proper notice. The defense argues the government failed to identify specific evidence or articulate a non-propensity purpose for its admission. The motion references disputed evidence including emails between Maxwell and 'influential men' regarding dates, testimony from a former Epstein employee (2005-06) regarding 'sexualized massages,' and various exhibits including flight logs (GX-661 & 662) and financial statements.
| 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 |
Contact Information
Email: jpagliuca@hmflaw.com, Phone: 303.831.7364, Fax: 303.832.2628
Case 1:20-cr-00330-AJN
Email address jpagliuca@hmflaw.com provided for Jeffrey S. Pagliuca, lead attorney for Ghislaine Maxwell.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Maxw...
A request from Ghislaine Maxwell's counsel to postpone a court hearing because her legal team is unavailable due to scheduling conflicts with other trials.
Request for adjournment
Maxwell's Request for adjournment of hearing on Motion for New Trial.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
A letter arguing against the government's request for a hearing regarding a juror's statements, asserting that the court can and should order a new trial based on existing information.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Legal argument regarding witness impeachment, inconsistent statements, and the '3500 material' (Jencks Act material).
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
A letter from Ghislaine Maxwell's defense attorney to the presiding judge, responding to the government's motion to preclude certain testimony by a potential witness, Alexander Hamilton, concerning an individual named Kate.
Jack Scarola, Brad Edwards and Robert Glassman
Letter with attachments filed under seal.
Jack Scarola, Brad Edwards and Robert Glassman
Letter regarding Scarola, Edwards, and Glassman with attachments filed under seal.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Defense counsel alerting the court regarding questions to be asked of attorneys Scarola, Edwards, and Glassman, arguing these questions do not violate attorney-client privilege.
Exhibit 52
Letter regarding Exhibit 52.
Exhibit 52
Letter regarding Exhibit 52.
Exhibit 52
Letter regarding Exhibit 52 filed by Ghislaine Maxwell
Response to the Government's Letter Regarding 900 Series ...
Letter filed by defense regarding exhibits.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Defense response to government's letter regarding the admissibility of the '900 series photos'.
Response to the Government's Letter Regarding 900 Series ...
Letter regarding exhibits filed by defense.
Witness Jane's Testimony
Filed Under Seal
Fed. R. Crim. P. 16(b)(1)(A)
Regarding Federal Rules of Criminal Procedure.
Pseudonyms
Regarding Pseudonyms.
Pseudonyms
Letter by Ghislaine Maxwell regarding Pseudonyms
Fed. R. Crim. P. 16(b)(1)(A)
Letter regarding Federal Rules of Criminal Procedure
Court's Proposed Preliminary Instructions to the Jury
Letter regarding jury instructions
United States v. Ghislaine Maxwell - Objections to Proffe...
Defense counsel objects to the admission of certain hearsay statements by Epstein and co-conspirators, arguing they are outside the scope or timeframe of the alleged conspiracy.
Fed. R. Evid. 412 and 702 Motions Hearing Date
Joint letter regarding scheduling of motions hearing.
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