Defense counsel
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
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person
Jane
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Adversarial |
6
|
2 | |
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organization
United States Attorney's Office
|
Professional adversarial |
6
|
1 | |
|
person
Judge Nathan
|
Professional |
6
|
2 | |
|
person
Jeffrey Epstein
|
Legal representative |
6
|
2 | |
|
person
defense team (attorneys, experts, consultants, etc.)
|
Legal representative |
6
|
1 | |
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person
potential witnesses
|
Legal representative |
6
|
2 | |
|
person
Ms. Moe
|
Opposing counsel |
6
|
2 | |
|
person
ALISON J. NATHAN
|
Judicial |
6
|
2 | |
|
person
CAROLYN
|
Legal representative |
6
|
1 | |
|
person
Designated Persons
|
Professional |
6
|
1 | |
|
person
Ms. Moe
|
Professional |
6
|
2 | |
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person
Brune
|
Legal representative |
6
|
2 | |
|
person
prosecutors
|
Professional |
6
|
2 | |
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person
Ms. Comey
|
Professional |
5
|
1 | |
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person
Menchel
|
Business associate |
5
|
1 | |
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person
Ms. Comey
|
Professional adversarial |
5
|
1 | |
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person
Juror No. 50
|
Legal representative |
5
|
1 | |
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person
ALISON J. NATHAN
|
Professional |
5
|
1 | |
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person
Former Principal Deputy Chief of CEOS
|
Professional consultative |
5
|
1 | |
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person
Brune
|
Professional |
5
|
1 | |
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person
JUROR
|
Business associate |
5
|
1 | |
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person
defense team (attorneys, experts, consultants, etc.)
|
Professional |
5
|
1 | |
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organization
GOVERNMENT
|
Professional adversarial |
5
|
1 | |
|
person
unnamed defendant
|
Professional |
5
|
1 | |
|
person
MDC
|
Adversarial professional |
5
|
1 |
| 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-00002001.jpg
This legal document, filed on behalf of Ms. Maxwell, argues that she did not attempt to avoid arrest. The defense counters the government's claims by stating they would have arranged for a self-surrender if asked and that her actions during the arrest, such as moving to an interior room and having a phone wrapped in tin foil, were pre-arranged security measures to protect her from the press, not to evade law enforcement. This claim is supported by a newly obtained statement from the head of her security company.
DOJ-OGR-00001993.jpg
This document is a page from a legal filing (Motion for Bail) arguing that Ghislaine Maxwell has now provided a thorough review of her finances for the years 2015-2020, addressing previous court concerns. Defense counsel retained UK accounting firm Macalvins to analyze bank statements, tax returns, and FBAR filings for Maxwell and her spouse. This report was further validated by a redacted former IRS Special Agent with 40 years of experience in financial fraud.
DOJ-OGR-00001949.jpg
This document is page 72 of a court transcript from the case U.S. v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on December 10, 2020. The prosecution argues to the Judge that the defendant is a serious flight risk, justifying why they did not offer her the chance to surrender voluntarily. The prosecutor also notes the defendant's lack of candor regarding finances and references separate civil litigation where defense counsel refused to accept service on the defendant's behalf.
DOJ-OGR-00001946.jpg
This is page 69 of a court transcript from Case 1:20-cr-00330-AJN, filed on December 10, 2020. Ghislaine Maxwell's defense attorney is arguing before the judge regarding her continued detention, stating that the government's cited case law regarding COVID-19 risks involves dangerous felons and is not relevant to Maxwell's situation. The attorney emphasizes the impossibility of preparing for trial with only four months of discovery while unable to meet the client in person due to BOP restrictions.
DOJ-OGR-00001889.jpg
This document is page 12 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. Prosecutor Ms. Moe addresses the court regarding the status of discovery, noting that materials will include search warrant returns, electronic data, and prior investigative files from the Southern District of Florida (referencing the earlier Epstein investigation). The government is waiting for a protective order to be finalized with defense counsel before producing the first batch of discovery.
DOJ-OGR-00001819.jpg
This legal document, filed on November 6, 2020, is a motion from the Government detailing a delay in producing discovery evidence from 62 electronic devices seized from Epstein. The Government explains that its outside vendor will not meet the November 9 deadline and will likely complete the work by November 19. The document outlines the subsequent unsuccessful negotiations with the defense for an extension, detailing the defense's four conditions and the Government's agreement to some (extending motion deadlines, providing a laptop) but rejection of others (providing names of minor victims and Jencks Act material).
DOJ-OGR-00001780.jpg
This document is page 2 of a court filing (Document 60) in the case of USA v. Ghislaine Maxwell (1:20-cr-00330-AJN), filed on October 6, 2020. It details the specific charges against Maxwell (enticement, conspiracy, transport of minors, perjury) focused on the 1994-1997 timeframe, while discussing the production of discovery materials related to a broader investigation of Epstein's abuse post-1997. The Government argues for the delayed disclosure of specific 'Materials' (approx. 40 photos and 40 pages of documents) to protect the identities of non-testifying victims and to avoid interfering with ongoing investigations.
DOJ-OGR-00001682.jpg
This document is the final page of a court order from Case 1:20-cr-00330-AJN, filed on July 28, 2020. The order, signed by United States District Judge Alison J. Nathan in New York, concludes by stating that the Defense Counsel may apply to the Court for modifications.
DOJ-OGR-00022123.jpg
This legal document, filed on May 21, 2021, is a submission from the United States Attorney's office to the Court, signed by Assistant United States Attorneys Jessica Lonergan and Nicolas Roos. It addresses the scheduling of a court proceeding, stating that if the proposed date is inconvenient or if an in-person proceeding is desired, the parties can propose alternative dates. Copies were sent to Defense Counsel and Pretrial Services.
DOJ-OGR-00022010.jpg
A transcript page from Case 1:19-cr-00830-AT (United States v. Noel et al.) filed on February 10, 2020. Government prosecutor Ms. Lonergan argues against a six-month adjournment, stating the trial focuses on a specific '14-hour period' at the MCC and is not complex. She notes that witness statements (3500 material) were provided unusually early to the defense.
DOJ-OGR-00022000.jpg
This legal document, filed on January 28, 2020, in the Southern District of New York, is a letter from the U.S. Attorney's Office regarding an upcoming trial. The prosecution states it is ready to proceed as scheduled but would not object to a brief adjournment to allow the defense more preparation time. However, it argues that the reasons cited by the defendants do not justify the six-month delay they requested.
DOJ-OGR-00021989.jpg
This document is a transcript from a court hearing dated December 19, 2019 (Case 1:19-cr-00830-AT). Ms. Donaleski, representing the government, states no objection to expanding the defendant's travel to the Middle District of Pennsylvania but strongly opposes the defendant possessing a firearm due to safety concerns for Pretrial Services officers who conduct unscheduled home visits. The Court agrees with the government and Judge Netburn's previous ruling, denying the application to keep the firearm as a 'commonsense safety measure.'
DOJ-OGR-00021967.jpg
This is page 9 of a court transcript from Case 1:19-cr-00830-AT, filed on December 16, 2019. The Judge is addressing counsel regarding the release conditions for a defendant named Ms. Noel. The Judge clarifies that while the defense and government have reached an agreement, the Court has final authority, and discusses a specific pretrial service policy regarding firearms, noting that the case involves allegations about documents, not violence.
DOJ-OGR-00021844.jpg
This document is page 15 (labeled 20 of 51 in the header) of a legal appellate brief filed on November 1, 2024. It argues that the Non-Prosecution Agreement (NPA) covering the 2001-2007 period should have prevented the USAO-SDNY from charging the Appellant (contextually Ghislaine Maxwell) for conduct between 2001-2004. The text cites legal precedents (*Annabi*, *Alessi*, *Papa*) regarding whether plea agreements bind other US Attorney Offices and argues the Appellant was improperly denied an evidentiary hearing.
DOJ-OGR-00021711.jpg
This document is a page from a legal filing (Case 22-1426) discussing the jury selection process (voir dire), specifically addressing how potential jurors with past experiences of sexual abuse were handled. It notes that defense counsel did not strike jurors who disclosed such history but affirmed their impartiality, citing specific examples of disclosures. The text transitions to a specific discussion regarding 'Juror 50' and their questionnaire responses to Judge Nathan.
DOJ-OGR-00021642.jpg
This document is a page from a court transcript of a sentencing hearing dated June 29, 2023. The judge orders the defendant, Ms. Maxwell, to serve five years of supervised release and pay a $750,000 fine, rejecting her claim of inability to pay by citing a $10 million bequest she received from Epstein. The judge also imposes a mandatory special assessment and notes that the government is not seeking restitution or forfeiture.
DOJ-OGR-00021639.jpg
This document is a page from a court transcript of Ghislaine Maxwell's sentencing hearing. The judge discusses the difficult conditions at the MDC during the pandemic, acknowledging they were harsh for all inmates, and notes Maxwell's specific security risks as a high-profile sex offender. However, the judge explicitly rejects the defense's argument that Maxwell was singled out for uniquely harsh treatment compared to other inmates.
DOJ-OGR-00021636.jpg
This document is a page from a court transcript (likely a sentencing hearing included in an appeal appendix) dated June 29, 2023. The text details the abuse of a victim named Carolyn, stating that Ghislaine Maxwell exploited Carolyn's prior trauma (abuse by a grandfather) to groom her. It explicitly states Maxwell personally touched Carolyn sexually at age 14 and paid her for massages. The speaker (likely the judge) notes that Maxwell and Epstein used this 'playbook' on multiple underage girls.
DOJ-OGR-00021253.jpg
This document outlines the specific terms of the Non-Prosecution Agreement (NPA) between the government and Jeffrey Epstein, requiring a guilty plea to state charges involving minors and a two-year prison sentence. It details the legal statutes violated (Florida statutes regarding lewd battery, solicitation, and sexual activity with minors) and stipulates that federal investigations would close upon his state sentencing. The document also includes a narrative section describing the contentious negotiation process between July and September 2007, noting the prosecution's frustration with defense tactics.
DOJ-OGR-00021161.jpg
This legal document is a letter from the U.S. Attorney's Office for the Southern District of New York to the Clerk of the U.S. Court of Appeals for the Second Circuit. The letter, dated March 13, 2023, concerns the case of United States v. Ghislaine Maxwell, advising the court that the government intends to file its appeal brief by May 30, 2023, and also requests permission to file a supplemental appendix.
DOJ-OGR-00019578.jpg
This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) addressed to Judge Alison J. Nathan on August 24, 2020. The text argues that Protective Orders may be modified as circumstances change and refutes the Government's suggestion that Ms. Maxwell waived her right to seek modification. It cites various legal precedents (Smith Kline Beecham Corp., United States v. Gurney, etc.) to support the court's power to modify orders and unseal records.
DOJ-OGR-00019559.jpg
This document is page 2 of a court order filed on August 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The court denies the Defendant's request to modify a protective order, reaffirming that discovery materials produced by the Government must be used solely for the defense of the criminal action and not for any civil proceedings. The text cites Federal Rule of Criminal Procedure 16(d)(1) and various legal precedents regarding 'good cause' for protective orders.
DOJ-OGR-00019551.jpg
This document is Page 3 of a letter from the Government to Judge Alison J. Nathan, dated August 21, 2020, arguing against modifying a protective order. The Government asserts that the defendant (implied Ghislaine Maxwell) should not be allowed to use materials from criminal discovery in her civil cases, citing witness privacy and an active, ongoing grand jury investigation into co-conspirators of Jeffrey Epstein. The text emphasizes that defense counsel represents the defendant in both criminal and civil matters and warns against 'cherry-picking' confidential materials to defend against abuse accusations.
DOJ-OGR-00019550.jpg
This document is a page from a government filing addressed to Judge Alison J. Nathan, arguing against a defense request to use criminal discovery materials in civil cases. The text details the background of grand jury subpoenas related to the Jeffrey Epstein investigation, the modification of protective orders to allow compliance, and asserts that using these materials for civil litigation violates the protective order in the current criminal case.
DOJ-OGR-00019545.jpg
This document is the signature page of a court order, case number 1:20-cr-00330-AJN, filed on July 30, 2020. The order, signed by United States District Judge Alison J. Nathan in New York, states that Defense Counsel may apply to the Court for modifications. The document includes appendix and DOJ tracking numbers in the footer.
| 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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