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defense

Person
Mentions
14
Relationships
0
Events
1
Documents
7
Also known as:
Defense Council Defense Counsel (Thomas) Court and Defense Counsel Defense Counsel (Laura) Counsel for Government and Defense Defense Counsel (Cassidy, Guha, Necheles) Defense Counsel (Jay)
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Event Timeline

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Date Event Type Description Location Actions
2020-10-19 N/A Government sends 'preliminary statement of facts' to defense counsel to discuss potential resolut... Email correspondence View

EFTA00027491.pdf

This document is an email chain between the US Attorney's Office (SDNY) and the FBI's NY Computer Analysis Response Team (CART) regarding the forensic processing of digital evidence seized from Jeffrey Epstein's properties in New York and the US Virgin Islands. The correspondence reveals significant friction caused by technical incompatibility between the FBI's forensic tools and the USANYS's 'Relativity' review platform, exacerbated by delays due to COVID-19 and FBI network infrastructure updates. The document lists specific seized hardware (Dell servers, Sony laptops, various hard drives with NYC serial numbers) and concludes with USANYS seeking funding to hire a private vendor (BRG) to expedite the processing because they have lost confidence in the FBI's ability to deliver in a timely manner. While flight records are mentioned as a type of document contained within the evidence (specifically regarding the inability to link attachments to emails), no actual flight logs are present in this document.

Email chain / legal correspondence
2025-12-25
Analysis Source

EFTA00018888.pdf

This document is an email dated November 6, 2021, concerning the transmission of legal discovery material ('3500 material') in the case U.S. v. Ghislaine Maxwell. The sender confirms that files have been uploaded to USAfx for the defense team and that a physical drive will be prepared and sent via FedEx. The email includes several attachments referencing indices, non-testifying witness material, and cover letters.

Email
2025-12-25
Analysis Source

DOJ-OGR-00021991.jpg

This is the final page (page 15) of a court transcript filed on December 19, 2019, for Case 1:19-cr-00830-AT. The judge rules to exclude time under the Speedy Trial Act until April 20, 2020, to allow for discovery production and motion preparation. The hearing is adjourned, and the defendants' bail status remains unchanged.

Court transcript / legal filing
2025-11-20
Analysis Source

DOJ-OGR-00016480.jpg

This document is a page from a court transcript (Case 1:20-cr-00330-PAE, USA v. Ghislaine Maxwell) filed on August 10, 2022. A government prosecutor addresses the Court regarding the potential calling of a rebuttal expert and the logistics of closing arguments, specifically how to present sealed exhibits to the jury without making them public. The speaker emphasizes coordination with the defense to ensure the process runs smoothly.

Court transcript
2025-11-20
Analysis Source

DOJ-OGR-00005596.jpg

This document is the Table of Contents for a legal filing (Document 384) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The filing outlines the Defense's arguments that the Government failed to identify co-conspirator statements and overwhelmed the defense with document dumps, violating court orders. The Defense argues this hinders cross-examination and requests the preclusion of these purported statements as a remedy.

Court filing (table of contents)
2025-11-20
Analysis Source

DOJ-OGR-00005248.jpg

This document is page 3 of a Government filing (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) dated October 15, 2021. The Government argues that the defense's proposed deadline of November 15, 2021, for filing Rule 412 motions (regarding the admissibility of victims' sexual behavior) is impractical as it conflicts with jury selection and the Thanksgiving holiday. The Government requests an earlier deadline to allow sufficient time for investigation and *in camera* hearings.

Legal filing / government motion (case 1:20-cr-00330-ajn)
2025-11-20
Analysis Source

DOJ-OGR-00005215.jpg

This legal document, filed on October 13, 2021, argues for the necessity of individual, sequestered voir dire (jury questioning) for a high-publicity case involving a well-known defendant. The filing contends that the sensitive and inflammatory nature of the charges, specifically sexual abuse of minors, makes it unlikely for jurors to be candid in a group setting, thus hindering the ability of both the defense and prosecution to identify biases and ensure a fair trial.

Legal document
2025-11-20
Analysis Source
Total Received
$40,332,000,000.00
1 transactions
Total Paid
$0.00
0 transactions
Net Flow
$40,332,000,000.00
1 total transactions
Date Type From To Amount Description Actions
1789-01-01 Received PRC / US Government defense $40,332,000,000.00 Defense Spending ($40,332 MM) View
As Sender
73
As Recipient
33
Total
106

Def. Mot. 11

From: defense
To: Court

Defense motion arguing that evidence of rape is irrelevant and inflammatory.

Legal motion
N/A
Communication Source

Def. Mem. at 35-36

From: defense
To: Court

Argument that Juror 50 repeatedly lied.

Legal memorandum
N/A
Communication Source

Def. Mot. at 11

From: defense
To: Court

Defense motion arguing that the plea agreement should be universally binding.

Legal motion
N/A
Communication Source

3500 material

From: Government officials
To: defense

Reference to disclosure material (Jencks Act material) regarding the witness Matt.

Legal discovery
N/A
Communication Source

Mr. Flatley's 3500 information

From: Government officials
To: defense

Defense has received '3500 information' (Jencks Act material) and examples of prior testimony regarding witness Flatley.

Legal disclosure
N/A
Communication Source

Def. Mot. at 13

From: defense
To: Court

Argument that the jury improperly based conviction on New Mexico abuse.

Legal motion
N/A
Communication Source

Justification for pseudonym

From: defense
To: Court

A letter from the Defense, cited as 'Def. Letter at 5', arguing for the use of a pseudonym for a law enforcement witness.

Letter
N/A
Communication Source

Def. Mem. at 44

From: defense
To: Court

Argument regarding probing Juror 50.

Legal memorandum
N/A
Communication Source

Protective Order Arguments

From: defense
To: Court

Acknowledging baseline prohibitions on disclosing victim identities.

Legal filing
2025-11-29
Communication Source

Request for inspection

From: defense
To: Government officials

Defense asked for an inspection the week before the conference.

Request
2025-11-01
Communication Source

Followup to jury's last note

From: defense
To: THE COURT

A letter from the defense, filed in the 'wee hours' of 08/10/22, taking a different approach to a recent jury note.

Letter
2022-08-10
Communication Source

Followup to jury's last note

From: defense
To: THE COURT

A letter from the defense, filed in the 'wee hours' of 08/10/22, taking a different approach to a recent jury note.

Letter
2022-08-10
Communication Source

Witness Declaration

From: defense
To: Government officials

Declaration disclosed orally and in written form.

Oral disclosure/written form
2022-08-10
Communication Source

Defense memorandum in support of PSR objections

From: defense
To: THE COURT

Submission reviewed by the court

Memorandum
2022-06-15
Communication Source

Sentencing Submission

From: defense
To: THE COURT

Includes Exhibits A-J (letters from friends/family and forensic psychiatric evaluation).

Legal submission
2022-06-15
Communication Source

Defense reply

From: defense
To: THE COURT

Scheduled filing

Legal filing
2022-02-09
Communication Source

Defense motion for new trial

From: defense
To: THE COURT

Scheduled filing

Legal filing
2022-01-19
Communication Source

Opposition to Juror 50 Motion

From: defense
To: THE COURT

Referenced as 'Defense Ltr., Jan. 13, 2022'

Letter
2022-01-13
Communication Source

Witness List/Arguments

From: defense
To: Court

Def. Dec. 14, 2021 Letter to Court referenced regarding a defense witness.

Letter
2021-12-14
Communication Source

Supplemental briefing on defendant's fourth motion in limine

From: defense
To: Court

Briefing status discussion.

Legal briefing
2021-12-08
Communication Source

Witness for authentication

From: defense
To: Government/CBP

Request for a witness from Customs and Border Protection to authenticate border crossing records.

Touhy request
2021-12-08
Communication Source

Response to Government's letter motion and further letter

From: defense
To: THE COURT

The Court ordered the Defense to file a response letter by 7:00 p.m. on December 5, 2021.

Response letter
2021-12-05
Communication Source

Rule 412 Motion

From: defense
To: Government and Victims

Anticipated filing date under the defense's proposed schedule.

Legal filing (proposed)
2021-11-15
Communication Source

Opposition Brief

From: defense
To: Court/Government

Defense stated need to investigate Minor Victim-6 as a potential witness (Referenced as 'Def. Opp. at 20').

Legal brief
2021-10-29
Communication Source

Response to Objection

From: defense
To: Government/Court (Impl...

Incorporating previous response regarding media related questions.

Court filing annotation
2021-10-22
Communication Source

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