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-00003148.jpg
This legal document is a filing by the Government in response to a defense motion. The Government argues that it is not required to produce pages from a personal diary belonging to a third-party victim because the diary is not in its custody or control. Furthermore, the Government asserts that it has already inquired with the victim, who confirmed that no diary entries exist for the relevant time period in the spring of 1996 when she met the defendant while visiting Epstein.
DOJ-OGR-00003147.jpg
This is a page from a Government legal filing (Case 1:20-cr-00330-PAE) responding to defense motions regarding discovery. The Government argues that witness statements (Jencks Act material) need not be disclosed immediately, and that a request for an unredacted FBI report is moot because it was already provided in November 2020. A key revelation in the footnotes is that a redacted version of an FBI report submitted by the defense was actually recovered directly from one of Jeffrey Epstein's personal devices during a search warrant execution.
DOJ-OGR-00002728.jpg
This legal document, filed by the U.S. Attorney for the Southern District of New York, details the security and search procedures for a specific defendant at the Metropolitan Detention Center (MDC). It outlines daily pat-down and cell searches, weekly body scans, and frequent nightly wellness checks, justifying them as necessary for the safety of the institution and the defendant. The document also notes a recent change to reduce searches by relocating the defendant's video conferences with her counsel to within her unit.
DOJ-OGR-00020093.jpg
This legal document, filed by the Government, refutes the defense's claim that the defendant cannot adequately prepare for trial while detained at the MDC. The Government outlines the measures taken to ensure access to discovery materials and legal counsel, including providing hard drives, a dedicated laptop, and arranging for daily video calls with her lawyer. The document argues that these provisions, despite pandemic-related restrictions, are sufficient for trial preparation.
DOJ-OGR-00020085.jpg
This legal document argues for the defendant's detention by highlighting her evasive behavior and lack of trustworthiness. It cites an instance where she fled from FBI agents and suggests her actions, like wrapping a phone in tin foil, were meant to evade law enforcement. Furthermore, it claims the defendant was deceptive about her wealth, reporting only $3.8 million to Pretrial Services when evidence suggests she has access to far more, indicating a willingness to deceive the Court.
DOJ-OGR-00020084.jpg
This document is page 24 of a court filing (Case 1:20-cr-00330-AJN) arguing against a renewed bail application for the defendant (Ghislaine Maxwell). It details her evasion of law enforcement, noting that despite communications between her counsel and the government from July 2019 to March 2020, her location was never disclosed. It further highlights that upon arrest, she ignored FBI directives and fled from agents who were clearly identified, countering defense claims that she was simply following security protocols.
DOJ-OGR-00020043.jpg
This legal document is a filing from Ms. Maxwell's defense team arguing that she was not trying to avoid arrest or hide from law enforcement. The defense claims they would have arranged a self-surrender if requested and that her actions during the arrest, such as moving to an interior room and wrapping a phone in foil, were pre-arranged security measures to protect herself from the press, not to evade officers. A new statement from the head of her security company is presented as evidence to support this claim.
DOJ-OGR-00005615.jpg
This document is a page from a defense filing in the Ghislaine Maxwell case, dated October 29, 2021. It argues that the Government's disclosure of Rule 404(b) evidence was insufficient and late, citing a letter served on October 11, 2021. The filing highlights discrepancies between the 404(b) letter and the trial exhibits provided the same day, specifically noting post-conspiracy evidence such as flight logs (2005-13), Amazon shipments (2013), and financial statements (2007) that were not justified in the letter.
DOJ-OGR-00005571.jpg
This legal document, filed on October 29, 2021, is part of a court case where the Government is arguing for the protection of 'Minor Victims' by allowing them to testify under pseudonyms. The Government asserts that this protection is necessary to prevent their identities from being exposed by news outlets, which would cause significant harm, and that the Defendant's need for witness information does not outweigh this need for protection. The document cites the Second Circuit's definition of a defendant's interests in witness disclosure.
DOJ-OGR-00005519.jpg
This document is page 64 of a legal filing (Document 382) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. The defense argues against government motions to exclude evidence regarding Maxwell's 'charitable works' and 'family history,' suggesting these may become relevant if the government opens those topics. Section X argues strongly against the government's request to preview the defense's evidence, using the metaphor of having 'hands tied behind their back and their mouths duct-taped,' while noting that accusers are testifying under anonymity.
DOJ-OGR-00005382.jpg
This document is the signature page (Page 3 of 3) of a legal filing submitted on October 26, 2021, in the case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It is signed by Damian Williams (United States Attorney) and Assistant US Attorneys Alison Moe, Lara Pomerantz, and Andrew Rohrbach on behalf of the Southern District of New York. The document indicates a copy was sent to Defense Counsel via ECF.
DOJ-OGR-00005235.jpg
This document is Page 2 of a Government filing (Case 1:20-cr-00330-PAE, filed 10/15/21) addressing defense complaints regarding legal mail delays at the MDC. The Government argues that a request for 1-day mail turnaround is burdensome given the facility houses 1,700 inmates. It details the timeline of a specific hard drive delivery: sent Oct 11, received Oct 12, delayed Oct 13 due to an 'institutional emergency,' and personally delivered to the defendant by MDC legal counsel on Oct 14, 2021.
DOJ-OGR-00002903.jpg
This document is page 3 of a court filing (Case 1:20-cr-00330-PAE) dated April 6, 2021, detailing the detention conditions of a female defendant (Ghislaine Maxwell) at the MDC. It confirms the defendant is fully vaccinated against COVID-19 and communicates with counsel via VTC and email, as counsel has declined in-person visits. The text also describes security protocols, including daily pat-down searches during movement between the isolation cell and day room, as well as weekly body scans.
DOJ-OGR-00002902.jpg
This document is page 2 of a legal filing from April 6, 2021, regarding Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It details the conditions of the defendant's confinement at the MDC, specifically highlighting that she is separated from her isolation cell from 7am to 8pm daily with access to electronics and showers. The text extensively describes the protocols for attorney-client communications, noting she receives 25 hours of private VTC calls per week, and clarifies that surveillance cameras monitor the door but do not record the audio or visual content of these legal meetings.
DOJ-OGR-00002901.jpg
This document is a letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan updating the court on Ghislaine Maxwell's confinement conditions at the MDC. It states that Maxwell receives 13 hours of discovery review time daily (more than any other inmate) with access to both a laptop and desktop. A footnote addresses complaints about missing emails, clarifying that an MDC investigation found Maxwell deleted them herself or archived them, rather than staff deleting them.
DOJ-OGR-00014466.jpg
This document is a page from a court transcript (summation) filed on August 10, 2022, in the case USA v. Maxwell. Prosecutor Ms. Moe argues that the case centers on manipulation, money, and memory, highlighting how Maxwell groomed victims for Epstein. The text contrasts the small payments made to victim Carolyn (approx. $100) against the $30 million Maxwell received from Epstein.
DOJ-OGR-00014465.jpg
This document is page 65 of a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022, featuring the summation by prosecutor Ms. Moe. She argues that the government has met its burden of proof regarding the six crimes charged against Ghislaine Maxwell. Ms. Moe specifically refutes the defense's narrative that Maxwell is being blamed for a man's actions, asserting instead that Maxwell made her own choices and committed crimes 'hand-in-hand' with Jeffrey Epstein.
DOJ-OGR-00014432.jpg
This document is a page from the closing summations of the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), delivered by prosecutor Ms. Moe. She argues that the testimony of a victim identified as 'Jane' is credible despite her being a 'kid' at the time of the abuse. The text highlights that Jane recalled specific first names of individuals present during 'group sexualized encounters': Emmy, Kelly, Sophie, Eva, and Michelle.
DOJ-OGR-00014428.jpg
This document is a page from a court transcript of a summation delivered by Ms. Moe (prosecution) in the Ghislaine Maxwell trial. The speaker details two specific flights in May 1997 and April 1998 where a minor victim, 'Jane,' traveled with Epstein and Maxwell to New Mexico and New York. The speaker also rebuts the defense's argument that the 'Jane' listed in the flight logs was actually an adult personal assistant with the same first name, citing pilot and DMV testimony as proof.
DOJ-OGR-00005254.jpg
This is the final signature page (page 5) of a legal filing from the United States Attorney's Office for the Southern District of New York, filed on October 18, 2021 (Case 1:20-cr-00330-PAE, Document 355). The text concludes an argument regarding jury selection (voir dire), stating that group discussion is safe and efficient. It is signed by U.S. Attorney Damian Williams and Assistant U.S. Attorneys Alison Moe, Lara Pomerantz, and Andrew Rohrbach.
DOJ-OGR-00005244.jpg
This legal document, filed by the Government, responds to a request from defense counsel for expedited delivery of legal mail to a defendant held at the MDC. The Government argues against the request, citing the burden on the MDC's legal department, and details a timeline of events where a hard drive delivery was delayed by one day due to an 'institutional emergency' at the facility on October 13, 2021.
DOJ-OGR-00005240.jpg
This is the final page (page 4) of a legal filing by the United States Attorney for the Southern District of New York in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues against the defense's schedule regarding 'sensitive issues' and requests the Court maintain the October 18, 2021, deadline for Rule 412 motions (regarding admissibility of victim sexual history), or set a final deadline of October 25, 2021. The document is signed by Assistant US Attorneys Moe, Pomerantz, and Rohrbach under US Attorney Damian Williams.
DOJ-OGR-00002870.jpg
This page is from a Government court filing (Case 1:20-cr-00330-PAE, US v. Ghislaine Maxwell) dated March 29, 2021. It details the discovery schedule, specifically noting the provision of evidence related to 'Minor Victim-4' and the intent to produce statements from over 250 non-testifying witnesses related to the Epstein investigation by April 12, 2021. It also confirms the trial is scheduled to proceed on July 12, 2021, and discusses potential motions regarding the 'S2 Indictment.'
DOJ-OGR-00008813.jpg
This legal document, filed on January 10, 2022, in the Southern District of New York, is a submission by the U.S. Attorney's office. It formally states that the defense agrees with the government to postpone or defer any court proceedings concerning perjury counts. This deferral is to last until after the post-trial motions have been fully resolved.
DOJ-OGR-00008800.jpg
This document is the signature page (page 3 of 3) of a legal filing submitted on January 5, 2022, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It is respectfully submitted by United States Attorney Damian Williams and signed by Assistant United States Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach of the Southern District of New York. The document notes that Defense Counsel was copied via the Electronic Case Files (ECF) system.
| 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 |
No Subject
Publicly released communications between prosecutors and defense counsel regarding the NPA.
Legal Visits
Weekly in-person legal visits cancelled due to quarantine period.
Redactions and sealing
Government consents to sealing cosigner names and confidential discovery materials but opposes in camera conference.
Unknown
That is fine. I'm sorry I didn't get your e-mail sooner... Tomorrow I am available early in the morning...
NPA Negotiations
Mentioned former President Clinton.
Invoking the Fifth
Counsel for a witness indicated the witness intends to invoke the Fifth Amendment.
Jury Instructions
Requesting instruction on 'purpose of travel' and arguing lack of evidence for return flight arrangement.
Modifications for presentation of evidence
Agreement to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence.
Preservation Letter
Request to preserve video tapes (Ref Dkt. No. 248, Ex. C).
Video call schedule
Outlining the 4-hour Friday session schedule.
Maxwell Post-Hearing Br. / Maxwell Br.
Arguments regarding Juror 50's bias.
Plea negotiations
Defense challenged the prosecution and terms presented; Prosecution reaffirmed position of two years jail time.
Maxwell Post-Hearing Br.
Arguments that Juror 50's trauma affected his ability to serve.
Conferral regarding filing
Government sought to confer with defense counsel but received no response.
Rule 404(b) Letter
Repeated opinion that newly-disclosed materials qualify as direct evidence of conspiracy.
Conditions of confinement
Discussions regarding defendant's status
Legal Consultation
5 hours per weekday (25 hours/week) of attorney calls.
Non-concurrence in designation
Notification that Defense Counsel does not concur in the designation of documents as Highly Confidential.
Order de-designating documents
Motion to remove Highly Confidential status from materials.
Maxwell Reply at 23
Argues that Rule 606 violates Maxwell's constitutional rights.
Objection to Confidential Designation
Notification that Defense Counsel does not concur in the designation of documents or other materials as Confidential.
Legal Defense Preparation
Argument that confinement impairs ability to communicate effectively with counsel.
Rebuttal report (Ex. A)
Explains French extradition provisions and constitution.
Addendum opinion (Ex. B)
Reiterates that waiver is a relevant factor and bail in UK is unlikely.
Objection to Confidential Designation
Notification that Defense Counsel does not concur with the designation of specific materials as Confidential Information.
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