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-00008361.jpg
A letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The Government informs the court that, after conferring with the defense, they will not agree to a stipulation regarding the testimony of Robert Glassman. The Government argues that a specific statement in an email is inadmissible and requires context to be understood by the jury.
DOJ-OGR-00008359.jpg
This document is the signature page (page 3 of 3) of a legal filing (Document 539) from the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330), filed on December 12, 2021. It is submitted by Damian Williams, U.S. Attorney for the Southern District of New York, and signed by Assistant U.S. Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach. The document indicates a copy was sent to Defense Counsel via ECF.
DOJ-OGR-00008356.jpg
This document is the second page of a legal filing (Document 538) in case 1:20-cr-00330-PAE, filed on December 11, 2021. It serves as the signature page for a submission by United States Attorney Damian Williams and Assistant U.S. Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach from the Southern District of New York. The document also indicates that a copy was sent to the Defense Counsel via e-mail.
DOJ-OGR-00008313.jpg
This document is page 3 of a court transcript from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 10, 2021. Prosecutor Ms. Comey addresses the Court to request a briefing schedule to preclude defense counsel from cross-examining government witnesses on specific topics, citing concerns about witness anonymization, embarrassment, and irrelevant criminal convictions. The Court instructs the parties to engage in further discussion to narrow their disputes before submitting a briefing.
DOJ-OGR-00008302.jpg
This document is the signature page (page 2 of 2) of a court filing in case 1:20-cr-00330-PAE, filed on December 9, 2021. It was submitted by the office of Damian Williams, the United States Attorney for the Southern District of New York, and signed by Assistant U.S. Attorney Maurene Comey. The document also lists Alison Moe, Lara Pomerantz, and Andrew Rohrbach as Assistant U.S. Attorneys and indicates that Defense Counsel was served a copy via the court's electronic filing system.
DOJ-OGR-00008280.jpg
This is the signature page (page 8 of 8) of Document 533, a legal filing in case 1:20-cr-00330-PAE, submitted on December 9, 2021. The document is filed by United States Attorney Damian Williams and signed by Assistant U.S. Attorney Maurene Comey on behalf of herself and three other AUSAs from the Southern District of New York. A copy was also sent to the Defense Counsel by e-mail.
DOJ-OGR-00008276.jpg
This legal document, filed on December 9, 2021, addresses the authentication and admissibility of Government Exhibit 52, described as a 'book' or 'household manual' belonging to Epstein and Maxwell. It discusses the defendant's challenge to Alessi's knowledge regarding the exhibit's origins and highlights the manual's contents, which detail practices and relationships between the defendant, Epstein, and other individuals. The document asserts that authentication does not require direct knowledge of creation or seizure, and chain of custody issues pertain to weight rather than admissibility.
DOJ-OGR-00008258.jpg
This document is page 14 of a court transcript from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on December 8, 2021. Prosecutor Ms. Comey addresses the Court regarding stipulations on evidence, noting a disagreement with the defense regarding the authentication of certain birth certificates and a prior sworn statement. She also indicates the government intends to confer with the defense regarding limits on cross-examination of government witnesses.
DOJ-OGR-00008224.jpg
This legal document, filed on December 5, 2021, is a request from the U.S. Government to the Court in case 1:20-cr-00330-PAE. The Government proposes a specific limiting instruction for the jury to be read before a witness, identified as "Witness-3," testifies. The instruction aims to prevent prejudice by clarifying that any testimony about sexual conduct between Witness-3 and Mr. Epstein is not part of the charged crimes and cannot be used to judge the character or propensity of either Mr. Epstein or Ms. Maxwell.
DOJ-OGR-00008215.jpg
This page is from a legal filing (Case 1:20-cr-00330-PAE) dated December 4, 2021. It discusses legal standards for the relevance and admissibility of evidence, citing case law regarding remote evidence and continuity of conduct (specifically regarding sexual interest in minors). The discussion section argues that 'photographs in the 900 series' corroborate statements made by a witness identified as 'Jane.'
DOJ-OGR-00001890.jpg
This document is a page from a court transcript dated December 10, 2020, from Case 1:20-cr-00330-AJN. A representative for the government informs the judge that they are prepared for discovery and have collaborated with defense counsel on a proposed schedule for the trial. The government representative emphasizes their commitment to a thorough review of materials, including an ongoing privilege review of electronic data, and mentions the bulk of materials will be produced by the end of summer. The judge then begins to question the representative about issues with complete disclosure seen in other cases.
DOJ-OGR-00001823.jpg
This legal document, dated November 6, 2020, details a negotiation between defense counsel and the Government regarding an extension in case 1:20-cr-00330-AJN. The defense proposed four conditions for an extension, including extending motion deadlines and providing discovery materials and victim names. The Government agreed to only two of the conditions, resulting in an inability to reach an agreement on the requested two-week extension for production. The document is certified by Assistant United States Attorney Maurene Comey.
DOJ-OGR-00001779.jpg
This is a letter from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan regarding 'United States v. Ghislaine Maxwell'. The Government requests permission to delay the disclosure of sensitive photographs and documents related to victims of Jeffrey Epstein to the defense until eight weeks before trial, citing risks to an ongoing investigation and victim privacy. The defense counsel has objected to this request.
DOJ-OGR-00001767.jpg
This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) dated August 24, 2020, addressed to Judge Alison J. Nathan. It argues that Protective Orders can be modified as circumstances change and asserts that Ms. Maxwell did not waive her right to seek modification. The text claims the government circumvented Second Circuit processes regarding civil materials for grand jury use and cites various case laws supporting the court's power to modify protective orders.
DOJ-OGR-00001744.jpg
This document is page 2 of a court order filed on August 25, 2020, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court addresses the Defendant's request regarding pretrial disclosure schedules (denied without prejudice) and conditions of confinement. Specifically, the Court denies Maxwell's request for a court order mandating her release to the general population and specific discovery access, noting that the Bureau of Prisons (BOP) has already modified conditions to allow her 13 hours of access to discovery materials daily.
DOJ-OGR-00001734.jpg
This document is page 3 of a government filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), dated August 21, 2020. The government argues against modifying a protective order, asserting that the defendant should not be allowed to use discovery materials from this criminal case in her parallel civil cases. The filing highlights that the grand jury investigation into Epstein's co-conspirators is active and ongoing, and that disseminating these materials could compromise witness privacy and the investigation.
DOJ-OGR-00001722.jpg
This document is page 4 of a Government filing (Document 41) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330), dated August 13, 2020. The Government argues against disclosing witness identities prematurely before the July 2021 trial to protect victim privacy. Additionally, the Government rejects the defendant's complaints regarding her confinement conditions at the MDC, asserting that monitoring protocols are appropriate for safety and security, and clarifying that attorney-client calls are visually observed but not audited.
DOJ-OGR-00001703.jpg
This document is page 2 of a court filing (Case 1:20-cr-00330-AJN) dated July 30, 2020. The Court rules in favor of the Government regarding a protective order, restricting Ghislaine Maxwell and her defense team from publicly disclosing the identities of alleged victims and witnesses, even those who may have previously made public statements about Maxwell or Jeffrey Epstein. The judge argues that participating in a criminal investigation warrants privacy protection distinct from previous voluntary public statements.
DOJ-OGR-00001701.jpg
This document is the final signature page (page 12 of 12) of a court filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It is an order signed by United States District Judge Alison J. Nathan on July 30, 2020, in New York, stating that Defense Counsel may apply to the Court for modifications. The page bears a Department of Justice Bates stamp (DOJ-OGR-00001701).
DOJ-OGR-00001700.jpg
This legal document, part of case 1:20-cr-00330-AJN filed on July 30, 2020, outlines the procedures for handling discovery materials post-trial. It mandates that the Defense Counsel must return or destroy all discovery, including confidential information, within 30 days of the case's final resolution. The document also requires the Government and Defense Counsel to meet before any hearings or trial to agree on the presentation of evidence.
DOJ-OGR-00001699.jpg
This document is page 10 of a court order filed on July 30, 2020, in case 1:20-cr-00330-AJN. It details strict regulations for the handling of confidential discovery materials by the Defendant and their legal team, prohibiting dissemination, copying, and public filing unless authorized in writing by the Government or by a specific Order of the Court. The order also specifies that information identifying victims or witnesses is an exception and should not be disclosed.
DOJ-OGR-00001698.jpg
Page 9 of a court order (Protective Order) from case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The document defines 'Highly Confidential Information' as materials containing sexualized images of individuals and outlines the strict limitations on its use, specifically prohibiting use in civil proceedings. It also establishes the protocol for the Defense Counsel to challenge the Government's classification of such materials.
DOJ-OGR-00001697.jpg
Page 8 of a Protective Order filed on July 30, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The document outlines strict protocols for the Defendant's review of discovery materials, mandating supervision by Defense Counsel or BOP officials, and defines the handling of 'Highly Confidential Information,' prohibiting the dissemination of copies to potential witnesses.
DOJ-OGR-00001696.jpg
Page 7 of a court filing (Case 1:20-cr-00330-AJN, filed July 30, 2020) detailing a protective order regarding 'Confidential Information.' The text stipulates that the Defendant (identified as female) may only use such information for this specific criminal defense (not civil proceedings), may only review hard copies in the presence of Defense Counsel, and may only access electronic copies via the Bureau of Prisons (BOP).
DOJ-OGR-00001695.jpg
This is page 6 of a court filing (Document 36) from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 30, 2020. The document outlines protocols for handling 'Confidential Information' during discovery, specifically regarding the protection of PII for victims and witnesses, while noting that victims who have publicly identified themselves on the record are exempt from this confidentiality. It also establishes the procedure for Defense Counsel to challenge confidentiality designations made by the Government.
| 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 |
Court Filing Service
Cc: Defense Counsel (by email)
Maxwell Reply
Cited as 'Maxwell Reply, Feb. 9, 2022, at 8 n.4' regarding the legal standard for hearings.
Service
cc: counsel for all parties (via email)
Case 1:20-cr-00330-PAE Document 568
Submission of legal document (content on previous pages), copied to defense counsel via ECF.
Grounds for a new trial
Defense Counsel sent a letter (ECF #569) to Judge Nathan claiming 'incontrovertible grounds for a new trial' based on Juror 50's interviews and information filed under seal.
Juror's statements
Inquiry regarding the defense's position on the juror issue; no response received at time of filing.
Document 550 Service
Service of filed document via email
Case 1:20-cr-00330-PAE Document 545
A copy of the filed document was sent to the Defense Counsel via e-mail, as indicated by 'Cc: Defense Counsel (by e-mail)'.
Request for remote testimony
Requesting permission for Mr. Hamilton to testify via WebEx due to COVID infection.
Mr. Hamilton's COVID status
Notification that Mr. Hamilton tested positive for COVID.
Case 1:20-cr-00330-PAE Document 533
A copy of the filed legal document was sent to the Defense Counsel via e-mail.
Case 1:20-cr-00330-AJN Document 526
Submission of legal document (signature page only shown).
Response regarding Motions in Limine and Defense Strategy
Legal argument regarding burden of proof and admissibility of past civil litigation outcomes.
Response to Government Motion regarding admissibility of ...
Defense argues that government attempts to preclude evidence on charitable works/family history are premature and that the request to preview defense evidence should be denied.
Production of Testimony List
List of Dr. Rocchio's previous testimony bearing Bates number 3502-002.
Production of CV
Production of Dr. Rocchio's curriculum vitae bearing Bates number 3502-006.
Case 1:20-cr-00330-PAE Filing
Submission of Document 372
Request for expedited legal mail delivery
The defense counsel sent a letter requesting that the MDC be ordered to provide the defendant with all legal mail within one day of receipt.
Document 350 Filing
Cc: Defense Counsel (By ECF)
Regarding delivery of defendant's legal mail
Complaint about delayed mail delivery (Dkt. No. 346).
Service of filing
Cc: Defense Counsel (by email)
Jencks Act and Giglio material
Government produced hard drives containing thousands of pages of disclosures.
Maxwell Rule 404(b) letter
Notice of evidence regarding Rule 404(b) and potential witnesses.
Maxwell Rule 404(b) letter
Notice of evidence including emails and a witness.
Pretrial Conference
Defense counsel explained it is impossible to prepare for trial under current lockdown conditions.
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