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-00019544.jpg
This legal document, filed on July 30, 2020, details the post-case responsibilities of the Defense Counsel. It mandates that all discovery materials provided by the Government must be returned or securely destroyed within 30 days after the case's final conclusion and all appeal periods have passed. The document also stipulates that the Government and Defense Counsel must meet before any hearings or trials to agree on how evidence will be presented.
DOJ-OGR-00019543.jpg
This document is page 10 of a legal order, likely a protective order, filed on July 30, 2020. It details strict rules for the Defendant and their legal team regarding the handling of confidential discovery materials, prohibiting dissemination, copying, and public filing without explicit authorization from the Government or the Court. The order specifies that materials must be reviewed in the presence of counsel and may be inspected under the protection of law enforcement.
DOJ-OGR-00019542.jpg
This document is a page from a legal filing (Case 1:20-gp-00330-AJN) dated July 30, 2020, that establishes rules for handling "Highly Confidential Information." It defines this information as including nude or sexualized depictions, outlines the process for the Government to designate it, and details the procedure for Defense Counsel to challenge such designations with the Court. The document strictly limits the use of this information to the defense of the current criminal action.
DOJ-OGR-00019541.jpg
This document is page 8 of a Protective Order filed on August 20, 2020, in Case 1:20-cr-00330-AJN (U.S. v. Ghislaine Maxwell). It outlines strict protocols for the Defendant's review of discovery materials, mandating supervision by Defense Counsel or BOP officials, and establishes rules for handling 'Highly Confidential Information' produced by the Government.
DOJ-OGR-00019540.jpg
This is page 7 of a court order (Document 30, filed July 2, 2020) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The text outlines strict protocols for handling 'Confidential Information,' specifically prohibiting the use of such materials for civil proceedings and restricting the Defendant from possessing hard copies unless in the presence of Defense Counsel. It also establishes that the Bureau of Prisons (BOP) will facilitate electronic access to discovery materials for the defendant.
DOJ-OGR-00019539.jpg
This page documents a protective order regarding discovery procedures in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). It defines 'Confidential Information' as materials containing personal details of victims and witnesses, while explicitly excluding those who have publicly identified themselves on the record. It also establishes a mechanism for Defense Counsel to challenge the Government's confidentiality designations.
DOJ-OGR-00019538.jpg
This document is page 5 of a court order filed on July 30, 2020, for case 1:20-gp-00330-AJN. The order prohibits the defense team (including the Defendant, Counsel, Staff, Experts, and Witnesses) from publicly disclosing or filing the identities of victims or witnesses referenced in the Discovery process. An exception is made for individuals who have already spoken on the public record, or if the disclosure is authorized in writing by the Government or by an order from the Court, in which case the filing must be made under seal.
DOJ-OGR-00019536.jpg
This page is part of a legal order filed on July 30, 2020, that governs the handling of discovery materials in a court case. It specifies which third parties—such as defense staff, experts, and potential witnesses—are permitted to receive these materials from the defendant's counsel for trial preparation. The document mandates that any such 'Designated Person' must first sign a copy of the order, formally agreeing to its terms, before being granted access to the materials.
DOJ-OGR-00019535.jpg
This document is page 2 of a court order filed on July 30, 2020, related to a criminal case. The order establishes strict rules for how the defendant and their legal team ('Defense Counsel') can handle discovery materials provided by the Government. It specifies that the materials must be used solely for the defense in this criminal action, restricts copying and distribution, and lists the specific types of personnel ('Designated Persons') who are authorized to view the information.
DOJ-OGR-00019533.jpg
This document is the signature page (page 12 of 12 in the original filing, stamped as page 76 of a larger compilation) of a court order from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It allows Defense Counsel to apply for modifications and is prepared for the signature of the Honorable Alison J. Nathan, United States District Judge, in New York in 2020.
DOJ-OGR-00019532.jpg
This document is page 11 of a court order (likely a Protective Order) from the case United States v. Ghislaine Maxwell (1:20-cr-00330). It outlines the strict protocols for the Defense Counsel regarding the handling, return, or destruction of 'Discovery' and 'Confidential Information' provided by the Government. It stipulates that materials must be destroyed or returned within 30 days of the finalization of the case (including appeals) and mandates that both parties meet to discuss evidence presentation before trials.
DOJ-OGR-00019529.jpg
This document is page 8 of a legal filing (Protective Order) from Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on July 28, 2020. It outlines strict protocols for the handling of 'Highly Confidential Information' during the discovery process, specifically dictating that the Defendant may only review materials in the presence of counsel or via BOP officials, and establishing rules for showing materials to potential defense witnesses without providing them copies.
DOJ-OGR-00019528.jpg
This page from a legal document, filed on July 28, 2020, details the strict protocols for handling Confidential Information in a criminal case. It stipulates that such information can only be used for the defense of the current action, must be kept secure, and outlines specific rules for how the defendant can access it in hard copy (only with counsel present) and electronically (facilitated by the Bureau of Prisons). The Government's designation of information as confidential is binding unless overridden by a court order.
DOJ-OGR-00019527.jpg
This is a page from a legal document, likely a protective order from case 20-cr-00330-AJN, filed on July 28, 2020. It defines how materials produced by the Government during discovery are to be designated and handled as "Confidential Information," particularly to protect the identities of victims and witnesses. The document also outlines the process for Defense Counsel to challenge these confidentiality designations.
DOJ-OGR-00019526.jpg
This is page 5 of a Court Order (Protective Order) filed on July 28, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The text outlines strict protocols for handling Discovery materials, specifically prohibiting the Defense team and Potential Defense Witnesses from publicly disclosing the identities of victims or witnesses who have not already spoken publicly. It mandates that any court filings containing such identities must be filed under seal unless authorized by the Government or the Court.
DOJ-OGR-00019525.jpg
This document is page 4 of a Protective Order from a legal case (1:20-cr-00330-AJN), filed on July 28, 2020. It establishes strict rules for the handling of discovery materials by the defendant, her counsel, and the entire defense team. The order mandates encryption for disseminated discovery and explicitly prohibits all parties, including the Government, from posting any discovery information on the internet, social media, or any other public medium.
DOJ-OGR-00019524.jpg
This document is a page from a legal order filed on July 28, 2020, detailing who is permitted to access discovery materials in a criminal case. It specifies that defense staff, experts, court-authorized individuals, and potential witnesses can receive these materials under strict conditions. The order requires any designated person receiving the materials to first sign a copy, agreeing to be bound by its terms, to ensure confidentiality during trial preparation.
DOJ-OGR-00019523.jpg
Page 2 of a Protective Order filed on July 28, 2020, in Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell). The document outlines strict protocols for handling discovery materials, mandating they be used solely for criminal defense purposes and prohibiting the defendant from copying or distributing them to anyone other than counsel. It defines 'Designated Persons' (support staff) who are permitted to view the materials.
DOJ-OGR-00019519.jpg
This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) dated July 28, 2020, addressed to Judge Alison J. Nathan. The Government argues against the defense counsel's request to publicly name victims who have self-identified in the media or public fora, contrasting this with the narrower 'Epstein protective order.' The Government asserts that victims of Ghislaine Maxwell and Jeffrey Epstein should be protected from having their identities broadcast by the defense, citing the Crime Victims' Rights Act and privacy concerns.
DOJ-OGR-00019513.jpg
This page of a legal document, filed on July 27, 2020, outlines the conditions under which its provisions remain in effect. It states that changes require either a mutual written agreement between the Government and Defense Counsel or a modifying order from the Court. It also mandates that both parties must meet and confer before any hearings or trials to agree on modifications for presenting evidence.
DOJ-OGR-00019512.jpg
This document is page 11 of a court order (Document 292) filed on July 27, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). It outlines strict protocols for handling confidential discovery materials, mandating that the Defendant may only review certain materials in the presence of counsel and cannot possess copies. It also prohibits public filing of confidential information without authorization and mandates the return or destruction of discovery materials at the conclusion of the case.
DOJ-OGR-00019511.jpg
This page is from a legal document filed on July 27, 2020, outlining the rules for handling "Highly Confidential Information" in a criminal case (Case 1:20-cr-00330-AJN). It specifies that such information may include sexualized images and details the legal process for Defense Counsel to challenge this designation with the Government and the Court. The document also strictly limits the use of this information to the defense of the criminal action and prohibits its further dissemination.
DOJ-OGR-00019510.jpg
This document is page 9 of a protective order filed on July 27, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It establishes strict protocols for the handling of discovery materials, stating that the Defendant may only review them in the presence of counsel or via BOP officials. It further defines 'Highly Confidential Information' and restricts Potential Defense Witnesses to viewing materials via read-only platforms without receiving physical copies.
DOJ-OGR-00019509.jpg
This document is page 7 (filed as page 8 of 13) of a protective order in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It stipulates strict handling procedures for 'Confidential Information,' limiting its use solely to the criminal defense and prohibiting use in civil proceedings. It specifically mandates that the defendant may only review hard copies in the presence of counsel and that electronic access within the Bureau of Prisons must be facilitated by BOP officials.
DOJ-OGR-00019508.jpg
This document is page 7 (labeled page 6 internally) of a court filing from July 2, 2020, in case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It outlines the protocols for handling 'Confidential Information' during discovery, specifically defining what constitutes confidential material and establishing protections for the personal identification of victims and witnesses. It also sets the procedure for Defense Counsel to challenge confidential designations.
| 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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