S.D.N.Y.
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
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Documents | Actions |
|---|---|---|---|---|
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person
Epstein's lawyers
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Legal representative |
1
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1 |
010.pdf
Declaration by Jeffrey S. Pagliuca, attorney for Ghislaine Maxwell, filed on June 30, 2016, in the Southern District of Florida. The document lists 18 exhibits (A-R) supporting Maxwell's opposition to Bradley J. Edwards' motion to quash a subpoena. Several exhibits are filed under seal, while others include procedural documents from related cases (Cassell v. Dershowitz, Epstein v. Rothstein, Jane Doe v. US) and communications regarding discovery and subpoenas.
007.pdf
This document is a 'Notice of Filing' submitted to the U.S. District Court for the Southern District of Florida on June 29, 2016. It serves to notify the court and opposing counsel that Defendant Ghislaine Maxwell has filed Exhibits A, G, H, I, and N under seal. These exhibits are attached to a declaration by her attorney, Jeffrey S. Pagliuca, in support of her opposition to Bradley J. Edwards' motion to quash a subpoena.
EFTA00030792.pdf
This document contains an email chain from July 29, 2020, discussing a new court filing in the civil case against Ghislaine Maxwell (1:15-cv-07433-LAP). Sigrid McCawley of Boies Schiller Flexner LLP alerts recipients to a letter filed by Maxwell's attorney, Ty Gee, regarding a reconsideration of a court ruling. The subsequent internal emails react strongly to the filing, with one sender calling the defense 'fucking idiots' and another stating the filing was 'ridiculous' and caused by a failure to communicate effectively.
EFTA00027729.pdf
This document is an email thread from July 29, 2020, originating from an automated PacerPro notification regarding the case '[Redacted] v. Maxwell' (Case No. 1:15-cv-07433-LAP in S.D.N.Y.). A partner at Boies Schiller Flexner LLP forwards the notification to alert recipients that Maxwell's counsel, Ty Gee, has filed a letter addressed to Judge Loretta A. Preska requesting reconsideration of a July 23 ruling.
EFTA00027113.pdf
This document is an email chain from the U.S. Attorney's Office for the Southern District of New York (SDNY) dated August 12-14, 2019, initiating a formal litigation hold following Jeffrey Epstein's death. The correspondence directs staff to preserve all records related to Epstein, his suicide, his conditions of confinement at the MCC, and an earlier reported incident involving physical injuries. The emails reference a potential 'wrongful death case' indicated by Epstein's lawyers and provide specific instructions regarding the preservation of emails, hard-copy notes, and text messages.
EFTA00024829.pdf
An email chain from November 29, 2021, between employees of the U.S. Attorney's Office for the Southern District of New York (USANYS). The correspondence concerns updating the 'Ghislaine Maxwell victim page' on the DOJ website with new information regarding trial attendance, specifically noting that the trial (jury selection) began that day. The update outlines strict COVID-19 protocols for the courthouse and clarifies that victim access is coordinated by specific Victim-Witness Coordinators.
EFTA00024004.pdf
This document is an internal email chain from the U.S. Attorney's Office for the Southern District of New York (SDNY) dated August 12-15, 2019. It issues a formal litigation hold following Jeffrey Epstein's death at the Metropolitan Correctional Center (MCC), citing a preservation request from Epstein's lawyers regarding a potential wrongful death case. Staff are instructed to preserve all records, including emails, hard-copy notes, and text messages, related to Epstein's suicide, conditions of confinement, and a prior injury incident.
EFTA00015654.pdf
This document is an email chain from November 29, 2021, between court executives at the Southern District of New York regarding the start of the Ghislaine Maxwell trial. Edward Friedland requests an urgent update to the court's website to remove outdated phone access information, noting that the trial is in-person only with no broadcast or dial-in. The correspondence includes draft text for the website detailing victim attendance coordination, public access via overflow rooms, and strict COVID-19 entry protocols.
EFTA00010943.pdf
This document is an email chain from November 29, 2021, between Edward Friedland (District Court Executive) and Joseph Pecorino regarding public information for the *United States v. Ghislaine Maxwell* trial. The correspondence focuses on correcting outdated website information that suggested phone access to the trial was available, clarifying that access is in-person only due to court orders. They draft and approve a public notice detailing victim attendance coordination, the lack of broadcast/dial-in options, and strict COVID-19 entry protocols for the courthouse.
EFTA00010941.pdf
This document contains an email chain from November 29, 2021, between SDNY District Court Executive Edward Friedland, Joseph Pecorino, and others regarding public information for the Ghislaine Maxwell trial. The emails discuss correcting outdated website information that incorrectly suggested telephonic access to the trial and approving the text for a notice about victim attendance and COVID-19 protocols. The text confirms that the trial began on that date with jury selection and outlines strict in-person attendance rules.
DOJ-OGR-00000151.tif
This document excerpt discusses discovery procedures in a criminal case involving Maxwell, noting the complexity due to decades-old allegations and multiple locations. It highlights the Government's proposed disclosure schedule, providing Maxwell six weeks to review witness statements and mentioning a production of over 20,000 pages of materials on April 13, 2021. The document also addresses Maxwell's request for early disclosure of Rule 404(b) evidence, outlining the prosecutor's obligation to provide notice of intent to use such evidence at least 45 days in advance of trial.
DOJ-OGR-00000141.tif
This legal document discusses perjury charges against Maxwell, concluding that they are legally tenable but should be severed and tried separately from Mann Act counts to avoid undue prejudice. It references legal precedents and argues that Maxwell's statements in a civil case about sex trafficking and sexual abuse allegations could have led to the discovery of other evidence or influenced the factfinder, thus supporting the perjury charges.
DOJ-OGR-00015067.jpg
This document is page 6 of a legal filing dated July 29, 2025, in which the Government argues for the unsealing of grand jury transcripts related to the Epstein and Maxwell cases. Citing the 'magnitude and abhorrence of Epstein's crimes' and a July 6, 2025 Memorandum, the Government asserts that public interest warrants disclosure, subject to redactions protecting victims. The document details that the Epstein grand jury met in June/July 2019, and the Maxwell grand jury met in June/July 2020 and March 2021.
DOJ-OGR-00015056.jpg
This legal document is a court order denying defendant Maxwell's request for full access to the grand jury transcripts from her case. The court finds she has not demonstrated a particularized need for the materials, as required by law. However, the court has ordered the government to produce the transcripts for a private (in camera) review by July 28, 2025, after which the court may provide excerpts to Maxwell's counsel if deemed necessary.
DOJ-OGR-00008401.jpg
This document is a page from a legal filing, likely a court transcript or motion, dated December 17, 2021. The speaker argues against a defense strategy that challenges the thoroughness of a government investigation, citing multiple legal precedents (e.g., Watson, Gray v. Ercole, United States v. Birbal) to support the principle that the government's choice of investigative techniques is generally irrelevant to the defendant's guilt. The argument distinguishes these cases from another, Bowen v. Maynard, where evidence of an alternative suspect was deemed material.
DOJ-OGR-00008309.jpg
This document is page 7 of a legal filing from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 9, 2021. It discusses the legal admissibility of a telephone directory (Exhibit GX 606) found at the Palm Beach residence, arguing it is not hearsay because it is offered to prove a link between Maxwell and the listed contacts rather than the truth of the contact details. The text cites witness Mr. Alessi's testimony confirming Maxwell regularly used this directory.
DOJ-OGR-00001820.jpg
This is page 3 of a legal filing (Case 1:20-cr-00330-AJN, likely US v. Ghislaine Maxwell) dated November 6, 2020. The Government argues against the immediate production of witness lists (Giglio/Jencks material), stating it is premature seven months before trial. The document details an upcoming 'sixth discovery production' due November 9, 2020, which includes thousands of images/videos from Jeffrey Epstein's electronic devices, portions of his iPads and iPhone, and FBI Florida files.
DOJ-OGR-00001802.jpg
This page from a legal filing argues against the defense's position that a co-conspirator committing similar crimes without the defendant constitutes exculpatory evidence under Brady. The Government cites multiple Second Circuit precedents to establish that evidence of a defendant's non-participation in other criminal events or lawful conduct on other occasions is irrelevant to disproving specific charged crimes.
DOJ-OGR-00001768.jpg
This legal document is a letter dated August 24, 2020, from Jeffrey S. Pagliuca to Judge Alison J. Nathan. Pagliuca argues on behalf of his client, Ms. Maxwell, for a limited request to present sealed materials to other judicial officers, asserting that the materials are judicial documents and that disclosure would not compromise grand jury secrecy. The letter contends that the government has failed to provide a sufficient reason to prevent this limited disclosure.
DOJ-OGR-00001735.jpg
The Government argues against a criminal defendant's request to use criminal discovery materials in civil cases, citing a lack of precedent and the need to maintain grand jury secrecy. The document references several cases to support the separation of criminal and civil proceedings and refutes the defendant's claims of impropriety regarding how the Government obtained materials.
DOJ-OGR-00001645.jpg
This legal document, dated July 27, 2020, is a filing to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The filing argues in favor of Maxwell's proposed protective order, which would allow her defense team to publicly reference alleged victims or witnesses who have already spoken on the public record regarding Maxwell or Jeffrey Epstein. It contrasts this with the government's more restrictive proposal, arguing the government's position is 'broader than necessary' and would hinder the defense's ability to prepare for trial.
DOJ-OGR-00001627.jpg
This document is page 17 of a court filing (Document 22) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 13, 2020. The text argues against granting bail, citing an 'extraordinary risk of flight' and rejecting the defendant's claim that detention at the MDC prevents adequate preparation for defense. The filing cites numerous precedents (Tolentino, Adamu, Brito, etc.) where bail was denied despite access-to-counsel restrictions, distinguishing the current case from *United States v. Stephens*.
DOJ-OGR-00001605.jpg
This document is page 25 of a bail application filed on July 10, 2020, for Ghislaine Maxwell. The defense argues that Maxwell is concealing the identities of potential bond co-signers to protect their safety and privacy. The filing cites legal precedents involving high-profile defendants like Bernie Madoff and Marc Dreier to argue that Maxwell should be granted release subject to conditions, including the potential use of private security guards.
DOJ-OGR-00001584.jpg
This document is page 4 (labeled 'iii') of a legal filing, specifically a Table of Authorities listing case law citations. It was filed on July 10, 2020, in Case 1:20-cr-00330-AJN (the criminal case against Ghislaine Maxwell). The page lists various legal precedents cited in the brief, including 'United States v. Epstein' (2019) and 'United States v. Kashoggi', referencing rulings from the S.D.N.Y., 2nd Circuit, and other jurisdictions regarding bail or detention issues (inferred from the statute 18 U.S.C. § 3142).
DOJ-OGR-00001583.jpg
This document is a Table of Authorities from a legal filing in case 1:20-cr-00330-AJN, filed on July 10, 2020. It lists numerous U.S. court cases that are cited as legal precedent within the main document, providing the case names, citations, and the page numbers where they are referenced. The cases listed involve the United States as a party against various individuals and span from 1978 to 2020.
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