Defense counsel
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Legal representative |
14
Very Strong
|
10 | |
|
organization
GOVERNMENT
|
Legal representative |
12
Very Strong
|
14 | |
|
person
defendant
|
Legal representative |
11
Very Strong
|
21 | |
|
person
GHISLAINE MAXWELL
|
Client |
11
Very Strong
|
7 | |
|
organization
The government
|
Legal representative |
11
Very Strong
|
7 | |
|
person
Potential Defense Witnesses
|
Legal representative |
11
Very Strong
|
9 | |
|
person
the defendant
|
Legal representative |
11
Very Strong
|
10 | |
|
organization
GOVERNMENT
|
Professional |
10
Very Strong
|
6 | |
|
person
the defendant
|
Client |
10
Very Strong
|
8 | |
|
person
defendant
|
Professional |
10
Very Strong
|
11 | |
|
person
defendant
|
Client |
10
Very Strong
|
10 | |
|
person
Ms. Maxwell
|
Professional |
9
Strong
|
5 | |
|
person
the defendant
|
Professional |
9
Strong
|
5 | |
|
organization
U.S. Attorney's Office
|
Legal representative |
8
Strong
|
8 | |
|
person
Potential Defense Witnesses
|
Professional |
8
Strong
|
3 | |
|
organization
The government
|
Professional |
8
Strong
|
4 | |
|
organization
The government
|
Adversarial |
7
|
3 | |
|
organization
Defense team
|
Professional |
7
|
2 | |
|
person
Defense Staff
|
Professional |
7
|
3 | |
|
organization
The government
|
Opposing counsel |
7
|
3 | |
|
person
MR. ROHRBACH
|
Professional |
7
|
3 | |
|
person
Jeffrey Epstein
|
Client |
7
|
3 | |
|
person
Defense Experts/Advisors
|
Professional |
7
|
3 | |
|
person
ALISON J. NATHAN
|
Judicial |
6
|
2 | |
|
organization
The Court
|
Professional |
6
|
2 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Appeals of Office's decisions to Washington. | Washington | View |
| N/A | N/A | Defense counsel's tactics in negotiating with AUSAs, including challenging resolutions collaterally. | N/A | View |
| N/A | N/A | Defense counsel arguing against victim notification letters | N/A | View |
| N/A | Investigation | Federal investigation of Epstein | N/A | View |
| N/A | N/A | In camera conference | Court | View |
| N/A | N/A | Jury Selection (Voir Dire) | Courtroom | View |
| N/A | N/A | Defense counsel review of nude images | FBI | View |
| N/A | N/A | Discussion and disagreement between Villafaña and Lourie regarding an immigration waiver in the p... | N/A | View |
| N/A | N/A | Villafaña informed defense counsel that Lourie rejected the proposed immigration language. | N/A | View |
| N/A | N/A | Presentation of the document to defense counsel, with two terms dropped from Villafaña's draft: o... | N/A | View |
| N/A | N/A | Negotiations with Main Justice and Southern District | Unknown | View |
| N/A | N/A | Joint Defense Agreement Discussion | Unknown | View |
| N/A | Legal agreement | Signing of the Non-Prosecution Agreement (NPA) | N/A | View |
| N/A | N/A | Meeting between the prosecution team and Epstein's defense counsel where the U.S. Attorney reaffi... | Unspecified (likely U.S. At... | View |
| N/A | N/A | Attorney Visits | MDC Attorney Visiting Room | View |
| N/A | N/A | Expected testimony of law enforcement agents | Court | View |
| N/A | N/A | Witness 'Carolyn' throws binder of evidence in distress during cross-examination. | Courtroom | View |
| N/A | N/A | Cross-examination testimony regarding grooming tactics. | Courtroom | View |
| N/A | N/A | Juror 50 Hearing | Court | View |
| N/A | N/A | Discussions with SDNY | New York | View |
| N/A | N/A | Civil litigation service attempt | Southern District (NY) | View |
| N/A | N/A | Seating of the Jury | Courtroom | View |
| N/A | N/A | Criminal trial where witnesses testified and were cross-examined. | Court | View |
| N/A | N/A | Breakfast meeting between Acosta and Defense Counsel. | Unknown | View |
| N/A | N/A | In-person legal visit where guards read legal notebooks, denied water, and monitored conversation... | MDC Conference Room | View |
DOJ-OGR-00000591.jpg
This document is a page from a court order filed on July 25, 2019, in case 1:19-cr-00490-RMB. It defines 'Highly Confidential Information' as including images of nude or partially-nude individuals and sets forth strict rules for its handling by the defense. The order explicitly states that this information cannot be copied or disseminated and that the Defendant is only permitted to review it under the direct supervision of their defense counsel.
DOJ-OGR-00000590.jpg
This legal document, part of case 1:19-cr-00490-RMB filed on July 25, 2019, establishes the rules for handling "Confidential Information." It dictates that the defendant's counsel is responsible for the secure maintenance of this information and outlines strict limitations on how the defendant can access it and to whom it can be disclosed, such as Designated Persons and Potential Witnesses.
DOJ-OGR-00000588.jpg
This document is page 3 of a protective order filed on July 25, 2019, in the case of United States v. Jeffrey Epstein (Case 1:19-cr-00490). It outlines strict protocols for handling discovery materials, including requirements for encryption when sharing with staff and a specific prohibition against the Defendant, Government, or Counsel posting any discovery information on the Internet or social media. It also specifies that potential witnesses may view materials for trial preparation but cannot retain copies.
DOJ-OGR-00000580.jpg
This is a page from a court transcript dated July 24, 2019, detailing a discussion between a judge and several lawyers. The conversation covers an agreement between the U.S. Attorney and defense counsel regarding whether trustees or guards will be armed. Attorney Mr. Boies, representing a victim, interrupts to clarify that payments of $250,000 and $100,000 were made by the defendant at a time when a legal proceeding was pending, contradicting a prior statement by the defense.
DOJ-OGR-00000572.jpg
This document is page 62 of a court transcript from July 24, 2019, appearing to be a bail hearing for Jeffrey Epstein (Case 1:19-cr-00490-RMB). A prosecutor argues against the defendant's request for home detention, describing it as a 'gilded cage' and 'private jail' that necessitates actual detention. The prosecutor also clarifies that the SDNY case was independently investigated by the FBI, CBP, and NYPD, explicitly stating there was no coordination with the Southern District of Florida regarding the initiation of this specific case.
DOJ-OGR-00000561.jpg
This document is page 51 of a court transcript from Case 1:19-cr-00490 (USA v. Jeffrey Epstein), filed on July 24, 2019. A member of the defense counsel is addressing the Judge regarding bail conditions, stating the defendant is willing to accept any monetary conditions, home detention, and monitoring to guarantee his appearance. The speaker also addresses the issue of sealing financial information, conceding that if monetary bail conditions are set, the associated financial information becomes a judicial document to which the public is entitled.
DOJ-OGR-00000537.jpg
Page 27 of a court transcript from Case 1:19-cr-00490 (USA v. Epstein) filed on July 24, 2019. Defense counsel argues for the defendant's release, citing his compliance with past registration (since 2010), jail time, and probation, while asserting that the Southern District of New York was not 'detached' from the Florida non-prosecution agreement. The Judge (The Court) responds by discussing the 'rebuttable presumption' for detention in cases involving children or young people.
DOJ-OGR-00000500.jpg
This document is page 29 of a court order filed on July 18, 2019, in the case against Jeffrey Epstein (Case 1:19-cr-00490-RMB). The Court rules Epstein's proposed bail package inadequate, primarily because the defense failed to provide audited financial statements or an affidavit from Epstein, submitting only a 'cursory' summary claiming assets of $559,120,954. The judge criticizes the defense's claim that they could not produce accurate financials quickly, calling the excuse 'disingenuous' for someone of Epstein's wealth and financial experience.
DOJ-OGR-00000497.jpg
This document is a page from a government filing (July 18, 2019) arguing against bail for Jeffrey Epstein. It details his immense wealth, listing specific property values totaling hundreds of millions of dollars, and notes the discovery of over $70,000 in cash and loose diamonds in his safe, which the government argues indicates a flight risk. The document also asserts that Epstein previously used employees to facilitate the exploitation of minors in New York and Florida.
DOJ-OGR-00000482.jpg
This legal document, part of a court filing from July 18, 2019, argues against granting bail to Jeffrey Epstein. It details testimony from alleged victim Courtney Wild, who described being abused by Epstein from age 14 and expressed fear for other girls' safety. The filing counters the defense's argument that Epstein is disciplined, asserting instead that his alleged sexual conduct is an uncontrollable, addictive behavior that poses a continued threat to young girls.
DOJ-OGR-00000441.jpg
This court filing from July 2019 addresses supplemental evidence for Jeffrey Epstein's detention hearing, specifically regarding flight risk. The Government notes the discovery of a foreign passport with Epstein's photo but a different name found in his Manhattan safe, alongside a US passport. The document also references a female co-conspirator (protected by the earlier NPA) and other employees who facilitated the trafficking of minors.
DOJ-OGR-00000403.jpg
This document is a page from a court transcript filed on July 16, 2019. In it, a judge grants a joint request from the prosecution and defense to adjourn proceedings and exclude the time until Monday, July 15th, from speedy trial calculations. The judge justifies the decision as necessary to prevent a miscarriage of justice and to allow both sides adequate time to prepare, specifically mentioning a 'written bail submission'.
DOJ-OGR-00021051.jpg
This document is a table of contents from a legal filing dated February 28, 2023, related to Case 22-1426. It outlines the arguments for an appeal on behalf of 'Maxwell', alleging multiple errors by the District Court, including the handling of 'Juror 50' in a post-trial hearing, constructively amending the indictment, and applying an incorrect sentencing guideline. The filing seeks to have the sentence vacated and the case remanded for resentencing.
DOJ-OGR-00020954.jpg
This document is page 11 of a court order filed on April 1, 2022, in the case of United States v. Ghislaine Maxwell. It details the Court's assessment of 'Juror 50,' who failed to disclose a history of sexual abuse during voir dire; the juror testified that this history did not affect his impartiality. The document also notes the denial of a defense request to stay the ruling pending the release of a documentary featuring said juror.
DOJ-OGR-00018886.jpg
This court transcript from August 10, 2022, captures a procedural discussion between the judge and counsel (Mr. Rohrbach and Ms. Comey) about Exhibit 52. After confirming no further witnesses will testify about the exhibit, Mr. Rohrbach informs the court of his plan to submit a letter that evening arguing for its admission. The judge instructs him to confer with defense counsel on the matter before the court takes a recess.
DOJ-OGR-00018854.jpg
This is a page from a court transcript (Case 1:20-cr-00330, US v. Maxwell) filed on August 10, 2022. Prosecutor Ms. Moe informs the court that the government anticipates resting its case 'this week.' The Judge grants a request to keep a document under seal to protect the identities of witnesses testifying under pseudonyms and discusses scheduling a charging conference, noting a conflict on the 13th, 14th, and 15th.
DOJ-OGR-00016119.jpg
This page is a transcript from the United States v. Ghislaine Maxwell trial (Case 1:20-cr-00330-AJN). Prosecutor Ms. Moe argues against the defense's use of screens to highlight documents because the government cannot see the witness's screen without it being mirrored to the public gallery, which poses security/privacy risks. The Court rules that highlighting text on a screen for a witness is permissible provided the action is fully described for the record, similar to reading from paper.
DOJ-OGR-00002273(1).jpg
A formal letter from the Federal Bureau of Prisons (MDC Brooklyn) to Judge Alison Nathan requesting the vacating of a court order regarding Ghislaine Maxwell. The MDC argues that Maxwell already has significant access to discovery materials (via a dedicated laptop provided in Nov 2020) and extensive communication with her legal counsel, exceeding that of other inmates. The letter refutes defense claims that her confinement conditions are limiting her ability to prepare for trial.
DOJ-OGR-00002252.jpg
This document is page 20 of a court order filed on December 30, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Defendant's request for release, reaffirming that she presents a flight risk and determining that her conditions of confinement at the MDC (including COVID-19 lockdowns) do not violate her constitutional rights or justify release. The text notes that the Defendant has received more time than other inmates to review discovery and communicate with counsel.
DOJ-OGR-00002252(1).jpg
This is page 20 of a court order filed on December 30, 2020, in the case of United States v. Ghislaine Maxwell (identified by case number 1:20-cr-00330-AJN). The Court denies the defendant's request for release, reaffirming that she presents a flight risk and rejecting arguments that her conditions of confinement at the MDC (specifically relating to COVID-19 lockdowns and attorney access) violate her constitutional rights. The document notes that she has received significant time to review discovery compared to other inmates.
DOJ-OGR-00002194.jpg
This legal document, filed on December 18, 2020, is a response from the Government arguing that the defendant, housed at the MDC, has adequate resources to prepare for trial. It refutes the defense's claim to the contrary by detailing provisions such as daily VTC calls with counsel, access to discovery on hard drives, and the provision of a dedicated laptop. The document also explains how access to this equipment is managed within the MDC, including during a recent period of quarantine.
DOJ-OGR-00002193(1).jpg
This document is page 29 (filed 12/18/20) of a Government opposition to a renewed bail application in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Government argues against release, citing the defendant's multiple foreign citizenships (including a non-extradition country), substantial wealth, and demonstrated sophistication in hiding assets as indicators of extreme flight risk. The document also defends the conditions of confinement at the MDC, noting the defendant has 13 hours a day to review discovery and access to attorney communications.
DOJ-OGR-00002186.jpg
This document is a page from a Government filing (Case 1:20-cr-00330-AJN) opposing bail for the defendant (Ghislaine Maxwell). It details her evasion of FBI agents during her arrest, including fleeing and wrapping a phone in tin foil, and argues she prioritized private security over law enforcement. Additionally, it asserts she was deceptive with Pretrial Services regarding her finances, possessing 'vast resources' far exceeding the $3.8 million she initially disclosed.
DOJ-OGR-00002186(1).jpg
This legal document argues for the defendant's detention by highlighting her deceptive behavior and flight risk. It cites her knowing disobedience of FBI directives when she fled, her attempts to evade law enforcement by wrapping a phone in tin foil, and her significant dishonesty regarding her financial assets, which are believed to be far greater than the $3.8 million she disclosed to Pretrial Services.
DOJ-OGR-00002185(1).jpg
This document is page 24 of a Government filing (Document 100) in the case US v. Maxwell (1:20-cr-00330), filed on December 18, 2020. It argues against bail by highlighting the defendant's evasion of law enforcement, noting that her counsel never disclosed her location despite being in contact with the Government. It details that during her arrest, Maxwell ignored FBI directives and ran away from agents who were clearly identified.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2020-12-01 | Received | GHISLAINE MAXWELL | Defense counsel | $0.00 | Expenditures for professional services in her d... | View |
| 2020-08-13 | Received | Government officials | Defense counsel | $0.00 | Production of discovery totaling more than 150,... | View |
| 2020-07-01 | Received | GHISLAINE MAXWELL | Defense counsel | $7,000,000.00 | Retainer paid to attorneys mentioned in governm... | View |
Service of process
Defense counsel declined to accept service on behalf of plaintiffs in civil litigation.
Non-concurrence in designation
Notification that Defense Counsel does not concur in the designation of documents as Highly Confidential.
Legal Consultation
5 hours per weekday (25 hours/week) of attorney calls.
Insufficiency of asset statement for bail package
The Court advised Defense counsel that the Defendant's asset statement was 'cursory' and insufficient to support a bail package because it was not verified and lacked details on expenses, indebtedness, or liabilities.
Maxwell Post-Hearing Br. / Maxwell Br.
Arguments regarding Juror 50's bias.
Preservation Letter
Request to preserve video tapes (Ref Dkt. No. 248, Ex. C).
Maxwell Reply at 23
Argues that Rule 606 violates Maxwell's constitutional rights.
Maxwell Reply at 23
Argument that Rule 606 violates Maxwell's constitutional rights to due process and confrontation.
Rebuttal report (Ex. A)
Explains French extradition provisions and constitution.
Defense's request for the disclosure of the identities of...
Defense counsel conferred with government prosecutors to request the identities of Victims 1-3. The government did not agree to the request, stating it would disclose the identities later through Rule 16 discovery or Jencks Act material production.
Conditions of confinement
Discussions regarding defendant's status
Maxwell Br.
Arguments for a new trial (referenced at pages 12-14, 28, 39-43).
Plea negotiations
Defense challenged the prosecution and terms presented; Prosecution reaffirmed position of two years jail time.
Encrypted Discovery materials
Defense Counsel must encrypt and/or password protect Discovery when disseminating it via means other than electronic mail.
Cross-examination topics
Government conferred with defense counsel and presented about a dozen topics believed to be improper for cross-examination.
Maxwell's status
Contact regarding Maxwell, though location was not disclosed.
Request to review grand jury transcripts
Todd Blanche stated he has no objection to the defense's application.
Sentencing Argument
Argument regarding mitigating factors for Ghislaine Maxwell's sentencing, specifically regarding her family trauma and relationship with Epstein.
Names of people present
Defense counsel asked Jane whether she remembered first names of people present for group sexualized encounters.
Witness Disclosures and Scheduling
Discussion regarding the timeline for the defense to produce witness lists and exhibits, noting the government is about to rest its case.
Defendant's conditions of confinement
A publicly filed letter from the defendant's counsel raised concerns about her conditions of confinement. This letter is referenced in a footnote (Dkt. No. 677).
Sentencing Memorandum
Arguments for a sentence below 240 months for Ghislaine Maxwell.
Case 1:20-cr-00330-PAE Document 660
Legal filing submission copy
Rule 29 Application
Request to enter a judgment of acquittal as to all counts.
Filing Service
Cc: Defense Counsel (by email)
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