Counsel
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Judge
|
Professional |
8
Strong
|
3 | |
|
person
Juror 50
|
Client |
7
|
3 | |
|
person
Ms. Maxwell
|
Professional |
7
|
3 | |
|
person
Ms. Maxwell
|
Client |
7
|
2 | |
|
person
GHISLAINE MAXWELL
|
Client |
6
|
2 | |
|
person
defendant
|
Professional |
6
|
2 | |
|
person
Judge (implied speaker)
|
Professional |
6
|
1 | |
|
organization
The Court
|
Legal representative |
6
|
2 | |
|
person
Judge
|
Legal representative |
6
|
2 | |
|
person
the defendant
|
Professional |
5
|
1 | |
|
person
The jury
|
Professional |
5
|
1 | |
|
person
Unnamed Speaker (presumably the judge)
|
Professional |
5
|
1 | |
|
person
defendant
|
Legal representative |
5
|
1 | |
|
organization
GOVERNMENT
|
Legal representative |
5
|
1 | |
|
person
Unnamed Speaker (Judge)
|
Professional |
5
|
1 | |
|
person
the defendant
|
Client |
5
|
1 | |
|
person
Designating Party
|
Legal representative |
5
|
1 | |
|
person
Ms. Maxwell
|
Legal representative |
5
|
1 | |
|
person
The President
|
Adversarial |
5
|
1 | |
|
person
Attorney General
|
Administrative |
5
|
1 | |
|
person
Juror No. 50
|
Client |
5
|
1 | |
|
person
MDC warden
|
Adversarial professional |
5
|
1 | |
|
organization
Peters and Peters
|
Professional |
5
|
1 | |
|
person
Juror 50
|
Professional |
5
|
1 | |
|
organization
The Court
|
Professional |
5
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Legal visits characterized by uncomfortable conditions, lack of privacy, and surveillance | MDC Legal Visiting Rooms | View |
| N/A | N/A | Meeting between Court and Counsel at 8:45 AM. | Courtroom | View |
| N/A | N/A | Trial sessions planned for Monday, Tuesday, Wednesday before Christmas and New Year's. | Courtroom | View |
| N/A | N/A | 10-minute break (Recess) | Courtroom | View |
| N/A | N/A | 9 a.m. conference regarding the jury charge. | Courtroom | View |
| N/A | N/A | Charging Conference (Trial Tr. at 2758–61) | Court | View |
| N/A | N/A | Jury Charge / Instructions phase of the trial. | Courtroom | View |
| N/A | N/A | Scheduled oral argument in both cases. | Court | View |
| N/A | N/A | Side bar conferences | Courtroom | View |
| N/A | N/A | Government Exhibit 10 is admitted into evidence. | Courtroom | View |
| N/A | N/A | Potential firing of the Special Counsel or Attorney General by the President. | Washington D.C. (Implied) | View |
| N/A | N/A | Jury Deliberation Scheduling Discussion | Courtroom | View |
| N/A | N/A | Reading of Jury Note regarding Count Four | Courtroom | View |
| N/A | N/A | Jury Deliberation/Recess | Courtroom | View |
| N/A | Legal proceeding | The Hearing | N/A | View |
| N/A | N/A | Protracted discussion regarding a jury note | Courtroom | View |
| N/A | N/A | Potential Evidentiary Hearing | Court | View |
| N/A | N/A | Guards setting up a tripod/camera focused on Maxwell during legal conferences. | MDC | View |
| N/A | N/A | Closing arguments in United States v. Ghislaine Maxwell | Courtroom | View |
| N/A | N/A | Counsel Meeting | Courtroom | View |
| N/A | N/A | Legal conferences where Maxwell is separated by a cloudy plastic shield, cannot handle documents,... | MDC Visiting Room | View |
| N/A | Trial | A trial in which the jury is being instructed on how to evaluate witness testimony. | N/A | View |
| N/A | Legal proceeding | The Court and the Defendant's counsel discussed a note received from the deliberating jury. | Court | View |
| N/A | Meeting | A daily meeting scheduled for 8:30 a.m. beginning 'tomorrow' to prepare for voir dire. | courtroom, 518 | View |
| N/A | Court proceeding | The court is in session to discuss a note from the jury regarding their deliberation schedule aro... | Courtroom | View |
EFTA00031439.pdf
This document is an email dated April 14, 2021, from an Assistant United States Attorney in the Southern District of New York to defense counsel regarding the case US v. Maxwell. The email serves as a transmittal for discovery materials, specifically an additional photograph and a cover letter, which are being prepared on a drive for the client (Ghislaine Maxwell) to review at the Metropolitan Detention Center (MDC).
EFTA00031434.pdf
This document is an email dated April 14, 2021, from a Paralegal Specialist at the U.S. Attorney's Office (SDNY) to defense counsel regarding 'Discovery Production 7' in the case U.S. v. Thomas (No. 19 Cr 830). The email confirms the upload of discovery materials to USAfx and notes the attachment of a specific document marked 'attorney's eyes only'.
EFTA00030991.pdf
This document is an email dated August 21, 2020, from an Assistant United States Attorney in the Southern District of New York to opposing counsel. The email serves as a transmittal for discovery materials in the case US v. Maxwell, referencing an attached cover letter and a redacted password for accessing the materials.
EFTA00030225.pdf
This document is a digital calendar entry for a 'counsel call' scheduled for July 9, 2019, from 14:00 to 14:30 UTC. The organizer's identity and the specific counsel's name are redacted. The entry is classified as 'X-PERSONAL' and was created on July 8, 2019.
EFTA00027655.pdf
This document is an email dated November 10, 2021, from an Assistant United States Attorney in the Southern District of New York to defense counsel regarding the case US v. Maxwell. The email serves as a transmittal for a supplemental production of testifying witness material (3500 material) and exhibits for a hearing scheduled for the following day (likely a Daubert hearing). The sender's name and recipient email addresses are redacted.
EFTA00026450.pdf
This document is an email dated June 5, 2020, from attorney Jason Foy of Foy & Seplowitz LLC to opposing counsel regarding the case 'US v. Tova Noel'. The email attaches a supplemental discovery demand and asks for an anticipated timeline for a response.
EFTA00023108.pdf
This document is an email from the chambers of Judge Alison J. Nathan dated December 28, 2020, addressed to counsel involved in United States v. Ghislaine Maxwell. It serves to distribute an Opinion & Order regarding Maxwell's renewed motion for bail, noting that the document is temporarily sealed to allow parties to propose redactions by December 30, 2020.
EFTA00021688.pdf
An email dated February 27, 2021, from an Assistant United States Attorney in the Southern District of New York to defense counsel regarding 'US v. Maxwell'. The email transmits discovery production files and a cover letter, with the password for the files redacted.
EFTA00019458.pdf
An email dated November 24, 2021, from an Assistant United States Attorney (SDNY) to opposing counsel regarding a deadline for a protective order related to Rule 17(c) subpoena materials. The email includes an attachment with 'GM' in the filename, strongly suggesting the context is the Ghislaine Maxwell trial proceedings.
EFTA00019082.pdf
A letter from U.S. Attorney Audrey Strauss (SDNY) to defense counsel in the Ghislaine Maxwell case, dated March 29, 2021. The letter concerns the identification of 'Minor Victim-4' referenced in the superseding indictment (S2) and provides a list of relevant discovery materials (Bates ranges), though the specific list and victim's birth date are redacted.
EFTA00019081.pdf
An email from an Assistant United States Attorney in the Southern District of New York to Ghislaine Maxwell's legal counsel dated March 29, 2021. The email serves to notify the defense of a superseding indictment (S2) returned by a grand jury that day and proposes times for a meeting the following day to discuss discovery issues and potential supplemental briefings regarding pretrial motions.
EFTA00016031.pdf
An email dated December 18, 2020, from an Assistant US Attorney (SDNY) to Ghislaine Maxwell's defense counsel. The email provides replacement discovery materials to correct documents that were inadvertently labeled with incorrect Bates numbers in a previous production. It notes that a physical copy on disc is being sent to the MDC for Maxwell.
EFTA00010287.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense counsel dated October 2, 2020, detailing a production of discovery materials. The production includes financial records from Deutsche Bank, JPMorgan Chase, Citibank, and UBS related to Maxwell, Epstein, and various associated entities like the Terramar Project and Max Foundation. It also provides technical instructions for viewing specific file types (.dat, .vol, video files) included in the production.
DOJ-OGR-00000203.tif
This document, likely a legal brief or argument, discusses the importance of the government upholding its promises in plea agreements. It argues that the NACDL urges the Court to ensure the government honors its commitments to defendants, especially given the significant rights defendants waive when entering such agreements. The text emphasizes that courts should enforce these promises to maintain fairness and trust in the legal system.
DOJ-OGR-00017663.jpg
This document is an excerpt from a court transcript dated August 10, 2022, detailing a procedural discussion during a cross-examination. Attorneys Ms. Moe and Ms. Menninger debate with the Court about the proper handling of a witness's (Jane Cross's) lack of recollection, specifically concerning whether Epstein directed her seating. The core issue revolves around refreshing a witness's memory versus allowing the jury to consider the witness's current inability to recall as relevant evidence.
DOJ-OGR-00017645.jpg
This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Jane. The questioning focuses on her activities in 1996, including performances and applications to programs like a School of the Arts and Interlochen. The central point of this excerpt is to establish that on three of her applications from that time, there was no mention of Jeffrey Epstein.
DOJ-OGR-00008623.jpg
This document is page 2 (Bates DOJ-OGR-00008623) of a Table of Contents for Jury Instructions filed on December 18, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It outlines instructions for the jury regarding their role, the burden of proof, and specific charges including 'Enticement to Engage in Illegal Sexual Activity' (Count Two) and 'Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity' (Count Four). The document details the structure of the legal charge, breaking down specific crimes into their constituent elements for jury consideration.
DOJ-OGR-00008621.jpg
This document is a page of jury instructions from a legal case, filed on December 18, 2021. A judge is instructing the jury on the procedures for reaching and reporting a verdict, emphasizing that it must be unanimous and that deliberations must be kept confidential. The judge also reminds the jurors to be courteous to one another and announces a brief sidebar conference with counsel before the case is formally submitted to the jury.
DOJ-OGR-00008549.jpg
This document is a legal instruction (Instruction No. 4) from a court case, filed on December 18, 2021. The judge directs the jury that they must decide the case based solely on their own recollection of the evidence, not on the arguments, objections, or statements made by the attorneys for the Government or the Defendant. The instruction explicitly states that statements from counsel and the court are not evidence and that the jury's memory of the facts is the ultimate authority.
DOJ-OGR-00008536.jpg
This document page contains the final jury instructions from the trial of Ghislaine Maxwell (Case 1:20-cr-00330), filed on December 17, 2021. The judge instructs the jury that their verdict must be unanimous, explains the role of the foreperson in filling out the verdict form and notifying the marshal, and urges courtesy during deliberations. The transcript concludes with the judge pausing proceedings for a brief sidebar conference with counsel and the court reporter before officially submitting the case to the jury.
DOJ-OGR-00008459.jpg
This document is the table of contents for jury instructions in the legal case 1:20-cr-00330-PAE, filed on December 17, 2021. It outlines the structure of the instructions, covering the roles of the court and jury, general legal principles like the presumption of innocence, and specific charges including conspiracy, enticement, and transportation of a minor for illegal sexual activity.
DOJ-OGR-00008441.jpg
This legal document, part of a court filing, outlines a joint proposal from the prosecution and defense regarding the presentation of closing arguments. The parties argue that alternatives like toggling monitors or using printed binders for the jury are unworkable due to potential interruptions, logistical difficulties, and the risk of inadvertently exposing sealed material, which would violate the privacy of victims and third parties. They propose instead to provide redacted copies of their presentation slides to the public on the following day.
DOJ-OGR-00008252.jpg
This document is a page from a court transcript dated December 8, 2021, from case 1:20-cr-00330-PAE. A judge is outlining the specific procedures for the jury selection process, known as voir dire, to the legal counsel. The judge explains how jurors' privacy will be protected, the protocol for striking a juror for cause, and how counsel can raise objections or request follow-up questions at sidebar.
DOJ-OGR-00001745.jpg
This is page 3 of a court order (Case 1:20-cr-00330-AJN) filed on August 25, 2020, concerning Ghislaine Maxwell. The Court denies Maxwell's request for an order against the BOP regarding her surveillance and confinement conditions, citing security concerns and deference to prison administrators. However, the Court orders the Government to provide written status updates every 90 days regarding any changes to her conditions to ensure she can participate in her defense.
DOJ-OGR-00001651.jpg
This document is a page from a Protective Order in criminal case 1:20-cr-00330-AJN, filed on July 27, 2020. It establishes strict rules for handling 'Discovery' materials, limiting their use by both government and defense witnesses and counsel solely for preparation for the criminal trial. The order explicitly prohibits using the information for civil proceedings and forbids any party, including the Defendant and defense team, from posting the Discovery or its contents on the Internet.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Received | Plaintiffs | Counsel | $0.00 | Obligation to pay counsel a reasonable fee for ... | View |
| 0001-07-01 | Received | Attorney General ... | Counsel | $0.00 | Hypothetical refusal of the Special Counsel's b... | View |
Privilege Waiver
Discussion on whether privilege was waived and confirming it belongs to the client.
Testimony
Jane testified she did not know cooperation would benefit civil litigation.
Adjournment and Health Safety
The court adjourns proceedings, mentions upcoming masking rules, offers supplies, and wishes happy holidays.
Re: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN)
Asking to confirm as soon as possible that a copy of the response was served on counsel for the moving parties.
Re: U.S. v. Maxwell...
Requesting confirmation that a copy of the response was served on counsel for the moving parties.
Juror Lists
Deadline for lists for questionnaires completed on Nov 12.
Juror Lists
Deadline for lists for questionnaires completed on Nov 4 and 5.
Draft preliminary remarks for prospective jurors (Dkt. 366)
Order inviting response to proposed address to prospective jury.
Conference
Reference to 'yesterday's conference' where reasons for the order were stated on the record.
Exhibit List
Counsel hand-delivered and deposited exhibit list in the MDC legal mailbox.
Failure to provide hard drive to Ms. Maxwell
On the morning of the filing (October 14), counsel emailed MDC Legal again regarding the failure to provide Ms. Maxwell with the hard drive.
Re: US v. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juro...
The Court requests that counsel provide Word doc versions of the proposed juror questionnaire and voir dire.
Failure to provide hard drive to Ms. Maxwell
On the morning of the filing (October 14), counsel emailed MDC Legal again regarding the failure to provide Ms. Maxwell with the hard drive.
Non-receipt of hard drive by Ms. Maxwell
On October 13, counsel emailed MDC Legal because Ms. Maxwell had not yet received the hard drive of evidence.
Non-receipt of hard drive by Ms. Maxwell
On October 13, counsel emailed MDC Legal because Ms. Maxwell had not yet received the hard drive of evidence.
N/A (Quoted text)
Request for logistics planning, attendee numbers, and phone numbers for Oct 21 teleconference and Nov 1 pretrial conference.
Re: US v. Maxwell, 20 Cr. 330 (AJN) - Joint Proposed Juro...
Clarifying rules on sealing documents on ECF and requesting a copy of Jencks Act materials.
Return of legal mail
Unit Manager contacted counsel regarding irregularity and personally returned legal mail.
US v. Maxwell, 20 Cr. 330 (AJN) - discovery letter
Please see the attached letter.
U. S. v. Thomas, No. 19 Cr 830 - Discovery Production 7
Notification regarding Government's discovery production (Production 7), including a zip file uploaded to USAfx and an 'attorney's eyes only' document.
Request to vacate Jan 15, 2021 order
A letter from MDC legal counsel asking the Court to vacate its January 15, 2021 order that directed the MDC to permit the defendant to use a laptop on weekends and holidays.
Defendant's discovery access
A letter mentioned in the main document where MDC legal counsel asks the Court to vacate its January 15, 2021 order that permitted the defendant to use a laptop on weekends and holidays.
Re: In Re: Grand Jury Subpoena_19-mc-00179
Notification of an attached Order filed under seal in 19-mc-179.
Restrictive conditions of confinement
A letter detailing the most serious and extraordinarily restrictive conditions of Ms. Maxwell's confinement.
Request for an expert opinion on UK-US extradition arrang...
A set of five questions instructing a legal counsel to prepare an expert opinion on the extradition process between the UK and the US, specifically focusing on bail, consent, bars to extradition, and human rights arguments as they might apply to Ms Maxwell.
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