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 |
EFTA00019231.pdf
An email chain from January 2020 discussing the scheduling of a presentation by defense counsel for 'full brass' (likely senior leadership). The participants negotiate times between Thursday, January 23rd, and Friday, January 24th, eventually settling on Friday the 24th at 3:30 PM. One email mentions a redacted individual having meetings lined up with 'all of the Judges'.
EFTA00018966.pdf
This document is an email chain from August 10, 2019, detailing the immediate government reaction to Jeffrey Epstein's death. It captures the timeline from the initial report of a suicide attempt and ambulance transport to the confirmation of his death. The correspondence highlights significant frustration within the U.S. Attorney's Office regarding the Bureau of Prisons (BOP) releasing information to the press before informing the prosecutors, making it difficult for them to update Epstein's defense counsel and family.
EFTA00018964.pdf
This document is a chain of internal emails from August 10, 2019, documenting the timeline of the U.S. Attorney's Office learning about Jeffrey Epstein's death. The correspondence reveals significant confusion and frustration among officials, as the Bureau of Prisons (BOP) issued press releases and spoke to the media before providing official confirmation or details to the prosecutors, who were simultaneously fielding frantic calls from Epstein's defense counsel. The chain begins with a notification of an 'apparent suicide attempt' at 7:52 AM and progresses to confirmation that he 'passed away' by 8:18 AM.
EFTA00017832.pdf
This document is a letter from the U.S. Department of Justice to Judge Alison Nathan opposing Ghislaine Maxwell's requests for early disclosure of witness names and court intervention in her confinement conditions. The Government argues the requests are premature given the trial is 11 months away and discovery has just begun, noting they have already produced over 165,000 pages of evidence. The letter also defends the Bureau of Prisons' protocols for Maxwell, stating her monitoring is appropriate for a high-profile inmate facing significant prison time and confirming she has been granted extensive daily access to review discovery materials.
EFTA00016734.pdf
An email exchange dated January 13, 2020, discussing scheduling a meeting. One party requests the availability of 'full brass' (leadership) for a presentation by defense counsel regarding a redacted individual on January 24, 2020. The respondent states they are out sick and cannot access calendars immediately.
EFTA00016247.pdf
This document is a Protective Order filed on July 30, 2020, in the case of United States v. Ghislaine Maxwell. It establishes strict protocols for the handling of discovery materials, distinguishing between standard, 'Confidential', and 'Highly Confidential' information (which includes sexualized imagery), and limiting access to the Defendant, Defense Counsel, and specific authorized persons. The order specifically mandates that highly confidential materials containing sexualized images must not be copied or possessed by the defendant outside the presence of counsel.
EFTA00015913.pdf
An email from Ghislaine Maxwell's defense team (likely to prosecutors/USANYS) dated December 30, 2020, complaining about conditions at the MDC. The email disputes MDC Legal's claim that Maxwell is not being directed to stand in specific spots, alleging guards enforced strict positioning rules under threat of sanction on December 29. The email also raises issues about Maxwell not receiving menu-designated food and technical failures with discovery discs on the MDC computer.
EFTA00015902.pdf
This document is an email chain between US Attorneys regarding a judicial inquiry into why Ghislaine Maxwell (at MDC) received significantly better legal access than Justin Rivera (at MCC). Judge Engelmayer called the disparity 'terrible' optics. The BOP's explanation was that Maxwell's protective custody status (isolation) allowed her exclusive use of equipment, whereas Rivera was in the general population sharing limited resources with ~80 other inmates. The emails track the drafting of a declaration to explain this to the court by the December 31, 2020 deadline.
EFTA00014348.pdf
This document is an email chain from August 10, 2019, between the U.S. Marshals Service (USMS) and the U.S. Attorney's Office (USAO) concerning the death of Jeffrey Epstein. The chain tracks the timeline from the initial report of an 'apparent suicide attempt' and ambulance transport to the confirmation that Epstein had 'passed away.' The emails highlight significant friction and frustration from the USAO regarding the Bureau of Prisons (BOP) issuing press releases before providing basic facts to federal prosecutors, hindering their ability to inform Epstein's defense counsel and family.
EFTA00013267.pdf
An email chain from January 2021 between the US Attorney's Office (SDNY) and redacted recipients regarding discovery materials for Ghislaine Maxwell. The prosecution explains that Maxwell could not view materials provided on CD, so a new drive was prepared. Due to logistical constraints, the AUSA asks for permission to allow defense counsel to hand-deliver the drive to the Metropolitan Detention Center (MDC) so Maxwell can review it over the weekend.
EFTA00013176.pdf
This document is a chain of internal emails between the U.S. Attorney's Office, the U.S. Marshals Service (USMS), and the Metropolitan Correctional Center (MCC) on August 10, 2019, the day Jeffrey Epstein died. The emails chronologically track the initial report of his transport to the hospital for an 'apparent suicide attempt,' the subsequent confirmation that he 'passed away,' and the significant frustration expressed by the U.S. Attorney's Office that the Bureau of Prisons issued a press release before providing official details to government attorneys or Epstein's family. Later emails discuss a suspicious phone call received by Epstein's defense team regarding the retrieval of his body, which officials suspected might be a hoax.
DOJ-OGR-00023180.tif
This document, an excerpt from a report, discusses OPR's investigation into whether Epstein's status, wealth, or associations improperly influenced the outcome of his case. It concludes that OPR found no evidence of such influence, despite news reports in 2006 identifying Epstein as wealthy and connected to prominent figures like William Clinton, Donald Trump, and Kevin Spacey. The report notes that FBI personnel initially unfamiliar with Epstein later became aware of his connections, including those who had been on his plane, and that his legal team's mention of Clinton in pre-NPA letters was contextual.
DOJ-OGR-00023204.tif
This document, an excerpt from a report, analyzes the non-prosecution provision within Jeffrey Epstein's Non-Prosecution Agreement (NPA), specifically examining whether key individuals (Villafaña, Lourie, Acosta) acted to improperly protect Epstein's associates. It details the evolution of the provision's language, from a narrow defense request to a broad clause covering 'potential co-conspirators of Epstein,' and notes the limited internal discussion within the USAO regarding its implications. The report concludes that emails and records do not establish improper favoritism but highlight a lack of substantive debate on the provision's broad scope.
DOJ-OGR-00018123.jpg
This document is a page from a court transcript dated August 10, 2022, from a case involving Jeffrey Epstein. An unidentified speaker, likely from the defense, argues against admitting costumes as evidence, claiming they are irrelevant and would prejudice the jury. In response, Ms. Moe, for the prosecution, argues the evidence is highly relevant to counter the defense's repeated claims that Epstein had no interest in underage girls, citing his possession of "schoolgirl outfits" near his massage room.
DOJ-OGR-00017925.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) filed on August 10, 2022. It details a sidebar conference during the direct examination of a witness named Rocchio. The Judge admonishes Ms. Pomerantz (prosecution) for approaching a line of questioning regarding 'grooming by proxy' or 'third-party involvement' in a 'pimp-prostitute context,' which the Judge states was precluded or limited during a previous Daubert hearing.
DOJ-OGR-00017890.jpg
This court transcript from August 10, 2022, captures a legal argument regarding the admissibility of a document. An attorney, Mr. Rohrbach, argues against an objection from defense counsel, stating that the document qualifies as an 'adoptive business record' of a school because it was integrated into their files and relied upon, despite a witness's testimony questioning its reliability. The judge ultimately overrules the objection, allowing the document into evidence.
DOJ-OGR-00017641.jpg
This document is a page from a court transcript dated August 10, 2022, detailing the cross-examination of a witness named Jane. The questioning focuses on her past entertainment career in 1994, including her participation in a touring production of 'Joseph and the Amazing Technicolor Dreamcoat' in Florida, and confronts her with a prior statement she made: "Nothing has been very difficult for me." The transcript also records a brief pause where an attorney, Ms. Moe, confers with defense counsel.
DOJ-OGR-00008611.jpg
This document is page 73 of a legal filing (Document 563) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 18, 2021. It contains Jury Instruction No. 51, which advises the jury that the Government is not legally required to use specific investigative techniques to prove its case.
DOJ-OGR-00008526.jpg
This document is page 70 of 82 from a court filing (Document 562) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. It contains Jury Instruction No. 51, which clarifies that the Government is not legally required to use specific investigative techniques to prove its case. The instruction directs the jury to focus solely on whether the evidence presented proves the defendant's guilt beyond a reasonable doubt.
DOJ-OGR-00008521.jpg
This document is page 65 of a court filing (Document 562) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. It contains Jury Instruction No. 46, which directs the jury on how to weigh testimony provided by law enforcement officials and government employees, specifically noting that such testimony should not automatically receive greater weight than that of ordinary witnesses.
DOJ-OGR-00008456.jpg
This is the final page of a legal filing from the U.S. Attorney's office for the Southern District of New York, dated December 19, 2021. The letter, submitted by U.S. Attorney Damian Williams and his assistants, informs the Court of the submission of exhibits GX 603-A and GX 604-A under a temporary seal. It also states that copies of other referenced exhibits will be provided the following morning.
DOJ-OGR-00008443.jpg
This document is the signature page (page 5 of 5) of a legal filing, Document 558, in case 1:20-cr-00330-PAE, filed on December 19, 2021. The document was submitted by the office of DAMIAN WILLIAMS, United States Attorney for the Southern District of New York, and signed by Assistant U.S. Attorney Maurene Comey, with Alison Moe, Lara Pomerantz, and Andrew Rohrbach also listed as Assistant U.S. Attorneys on the case.
DOJ-OGR-00008394.jpg
This legal document is the second page of a filing by the U.S. Attorney for the Southern District of New York in case 1:20-cr-00330-PAE, filed on December 17, 2021. The prosecution cites several legal precedents to counter the defense's anticipated arguments regarding the government's motives and the thoroughness of the investigation. The document concludes by stating that the government is not seeking any specific relief at this time.
DOJ-OGR-00008384.jpg
This document is the second page of a legal filing (Document 546) from case 1:20-cr-00330-PAE, filed on December 15, 2021. It contains the signature block for the U.S. Attorney's Office for the Southern District of New York, submitted by U.S. Attorney Damian Williams and signed by Assistant U.S. Attorney Maurene Comey, with three other Assistant U.S. Attorneys also listed. The document indicates that a copy was sent to the Defense Counsel via the court's electronic filing system.
DOJ-OGR-00008382.jpg
This document is the signature page (page 9 of 9) of a legal filing, Document 545, in case 1:20-cr-00330-PAE, filed on December 15, 2021. The submission was made by Damian Williams, the United States Attorney for the Southern District of New York, and signed by Assistant U.S. Attorney Maurene Comey, with three other Assistant U.S. Attorneys also listed. The document indicates that a copy was sent to the Defense Counsel by e-mail.
| 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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