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-00001694.jpg
This document is Page 5 of a Protective Order filed on July 30, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It outlines strict protocols prohibiting the Defense team and potential witnesses from publicly disclosing the identities of victims or witnesses found in discovery materials, mandating that such references in court filings be made under seal.
DOJ-OGR-00001693.jpg
This document is page 4 of a court-filed Protective Order from case 1:20-cr-00330-AJN, dated July 30, 2020. It establishes strict rules for handling sensitive 'Discovery' materials, requiring Defense Counsel to encrypt information shared through non-email channels. The order explicitly prohibits all parties, including the Government, the Defendant, and their entire legal teams, from posting any Discovery information on the Internet or social media.
DOJ-OGR-00001692.jpg
This document is page 3 of a court filing (Document 36) from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 30, 2020. It outlines the protocols for a Protective Order regarding the handling of Discovery materials, defining categories of authorized recipients such as 'Defense Experts/Advisors' and 'Potential Defense Witnesses.' It explicitly mandates that anyone receiving these materials must sign an agreement to be bound by the terms of the Order and prohibits the further distribution of discovery materials.
DOJ-OGR-00001691.jpg
This document is page 2 of a court order filed on July 30, 2020, in a criminal case. The order establishes strict rules for how discovery materials, provided by the Government, are to be handled by the Defendant and their Defense Counsel. It limits the use of these materials strictly to the defense of the current criminal action and restricts their distribution to specific 'Designated Persons' such as paralegal and investigative staff.
DOJ-OGR-00001680.jpg
This document is a page from a court order filed on July 28, 2020, detailing the strict rules and procedures for the handling of confidential and highly confidential information by the defendant and their legal team. It prohibits the public filing of discovery materials unless explicitly authorized by the Government or by a court order, and specifies that materials must be reviewed under controlled conditions. The order aims to protect sensitive information, including victim and witness identities, during legal proceedings.
DOJ-OGR-00001679.jpg
This document is page 9 of a court filing (Document 33-1) from Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on July 28, 2020. It outlines the protocols for handling 'Highly Confidential Information,' specifically defining it as materials containing sexualized images of individuals. It establishes that such information is to be used solely for the criminal defense and not for any civil proceedings.
DOJ-OGR-00001677.jpg
This page from a legal document, filed on July 28, 2020, outlines the rules for handling confidential information in a criminal case (Case 1:20-cr-00330-AJN). It stipulates that such information must be used solely for the defense, kept secure, and details specific protocols for how the defendant can access it in both hard copy and electronic formats, the latter involving the Bureau of Prisons. The Government's confidentiality designations are binding unless overturned by the Court.
DOJ-OGR-00001676.jpg
This legal document, filed on July 28, 2020, as part of case 1:20-cr-00330-AJN, defines what constitutes "Confidential Information" provided by the Government during discovery. It specifies that materials containing personal information of victims and witnesses are to be marked confidential, but also establishes a procedure for Defense Counsel to challenge this designation if they disagree, potentially leading to a motion to de-designate the materials.
DOJ-OGR-00001675.jpg
This document is page 5 of a court order (Document 33-1) from case 1:20-cr-00330-AJN, filed on July 28, 2020. The order restricts the defense team and other authorized persons from publicly disclosing or filing the identities of victims and witnesses found in discovery materials. Such information must be filed under seal unless specific written authorization is granted by the Government or the Court.
DOJ-OGR-00001674.jpg
This document is page 4 of a court-filed Protective Order from July 28, 2020, in a criminal case. It outlines the rules for handling discovery materials, stating that all members of the defense team are bound by the order even without individual signatures. The order mandates that Defense Counsel must encrypt discovery shared through non-electronic means and strictly prohibits all parties from posting any discovery information on the internet or social media.
DOJ-OGR-00001673.jpg
This document is page 3 of a legal order filed on July 28, 2020, for case 1:20-cr-00330-AJN. It specifies the categories of individuals, such as defense staff, experts, and potential witnesses, who are authorized to receive discovery materials from the defendant's counsel. The order mandates that any person receiving these materials must first sign a copy of the order, explicitly agreeing to be bound by its terms to ensure confidentiality.
DOJ-OGR-00001668.jpg
This document is page 5 of a Government filing from July 28, 2020, in the case against Ghislaine Maxwell. The Government argues against a defense proposal that would allow them to publicly name victims and witnesses, stating that such a request is broad, unjustified, and contrary to the Crime Victims' Rights Act. The text highlights the distinction between the previous Epstein protective order and the current case, emphasizing that victims should not fear reprisal or shaming by having their identities broadcast by the defense.
DOJ-OGR-00001666.jpg
This is page 3 of a government filing dated July 28, 2020, addressed to Judge Alison J. Nathan in the case against Ghislaine Maxwell. The government argues against the defense's request to publicly name victims/witnesses, calling the defense's argument 'absurd' and 'offensive' particularly regarding the suggestion that victims derive a 'benefit' from public identification. The document outlines the proposed protective order which would allow defense counsel to discuss identities privately but prohibits public dissemination to prevent harassment and intimidation.
DOJ-OGR-00001658.jpg
This document is page 12 of 13 from a filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 27, 2020. It outlines legal stipulations regarding the handling of confidential information, specifically setting timelines relative to appeals and dismissals (referencing 28 U.S.C. § 2255). Paragraphs 19 and 20 detail that the provisions remain in effect until mutual written agreement or court order, and mandate that the Government and Defense Counsel meet to discuss evidence presentation prior to hearings or trial.
DOJ-OGR-00001657.jpg
This document is a page from a court order (Case 1:20-cr-00330-AJN) filed on July 27, 2020, detailing the strict protocols for handling confidential discovery materials. It specifies that the Defendant and their legal team are restricted in how they can review, possess, copy, and file this information, requiring authorization from the Government or the Court for public disclosure. The order also mandates that all discovery materials be returned or destroyed at the end of the case.
DOJ-OGR-00001656.jpg
This document is page 10 of a court filing in case 1:20-cr-00330-AJN, filed on July 27, 2020. It defines 'Highly Confidential Information' as potentially including nude or sexualized images and establishes strict rules for its use by the Defense Counsel, limiting it solely to the defense of the current criminal action. The document also provides a legal mechanism for the Defense Counsel to challenge the Government's 'Highly Confidential' designation of materials before the Court.
DOJ-OGR-00001655.jpg
This document is page 9 of a court filing (Document 29-1) from July 27, 2020, in Case 1:20-cr-00330-AJN (US v. Ghislaine Maxwell). It outlines strict protocols for the handling of discovery materials, specifically those designated as 'Highly Confidential Information.' It details that the Defendant may only review materials in the presence of counsel or BOP officials, and sets rules for showing materials to potential defense witnesses via read-only means without providing physical copies.
DOJ-OGR-00001653.jpg
This document is page 7 of a court filing (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) dated July 27, 2020. It outlines protocols for handling 'Confidential Information' during the discovery process, specifically defining what constitutes confidential material and how personal identification of victims and witnesses must be protected. It also notes that victims or witnesses who have publicly identified themselves are not subject to these specific confidentiality restrictions.
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.
DOJ-OGR-00001650.jpg
This legal document, part of case 1:20-cr-00330-AJN filed on July 27, 2020, is a court order outlining the protocol for handling discovery materials. It specifies that the Defendant and Defense Counsel can share materials with authorized third parties—such as experts, advisors, and potential witnesses—provided these individuals formally agree in writing to be bound by the order's confidentiality terms.
DOJ-OGR-00001541.jpg
This document is page 2 of a court order filed on July 7, 2020, in the case of USA v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It outlines strict COVID-19 entry protocols for the courthouse, instructions for defense counsel regarding the 'Waiver of Right to be Present' form, and mandates that the Government ensure crime victims are notified of proceedings and their rights under 18 U.S.C. § 3771.
DOJ-OGR-00001540.jpg
This document is a court order filed on July 7, 2020, by District Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell (20-CR-330). It schedules an arraignment, initial conference, and bail hearing for July 14, 2020, to be conducted via remote video due to COVID-19 protocols. The order outlines specific restrictions on video participation to essential parties only, while noting that public viewing will be available at the Daniel Patrick Moynihan Courthouse due to the high public interest in the case.
DOJ-OGR-00001532.jpg
A court order filed on July 6, 2020, by District Judge Alison J. Nathan in the case against Ghislaine Maxwell. The order addresses the scheduling of an arraignment and bail hearing, proposing remote proceedings due to COVID-19 safety concerns. It outlines specific time slots available for video appearances from the Metropolitan Detention Center (July 9 or July 14) and orders counsel to confer and file a joint letter by 9:00 p.m. that night.
DOJ-OGR-00001428.jpg
In this court order from May 14, 2021, Judge Alison J. Nathan denies Ghislaine Maxwell's request to override the Bureau of Prisons' security protocols regarding frequent safety checks and the prohibition of eye masks at the MDC. The Judge rules the request unsubstantiated but urges the MDC to consider reducing sleep disruption and ensures Maxwell is only subjected to necessary security protocols consistent with similarly situated detainees. The order is part of Case 1:20-cr-00330.
DOJ-OGR-00001362.jpg
This legal document, page 4 of a court filing, describes the search and wellness check procedures applied to a defendant at the MDC facility. It details daily pat-down searches, cell searches, and frequent nightly flashlight checks for safety. The document also responds to a specific complaint from the defendant's counsel on February 16, 2021, stating that an internal investigation found the search in question was appropriate and video-recorded, and that a subsequent directive for the defendant to clean her cell was due to hygiene issues, not retaliation.
| 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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