the government

Person
Mentions
286
Relationships
1
Events
2
Documents
143
Also known as:
Ghislaine Maxwell (Defendant), The Government Ghislaine Maxwell (Defendant), The Government, Warden Heriberto Tellez

Relationship Network

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1 total relationships
Connected Entity Relationship Type
Strength (mentions)
Documents Actions
person Jeffrey Epstein
Adversarial
6
1
View
Date Event Type Description Location Actions
N/A N/A An alleged promise was made by the government to victims ('the girls') that they would receive mo... N/A View
N/A N/A Negotiation of Epstein's Non-Prosecution Agreement Southern District of Florida View

DOJ-OGR-00001321.jpg

This document is page 4 of a legal filing from April 12, 2021, detailing the government's allegations against Ghislaine Maxwell. It outlines how Maxwell normalized Epstein's abuse, participated in sexual acts with minors as young as 14, facilitated financial dependence, and conspired to transport victims across state lines. It also references perjury charges stemming from false statements Maxwell made during a civil deposition regarding her interactions with minors.

Legal filing / court document (government brief/memorandum)
2025-11-20

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This document is a page from a Government filing (likely opposing bail) in the case against Ghislaine Maxwell (Case 1:20-cr-00330). It argues that the defendant is a flight risk, noting that she actively hid from law enforcement and the media, and that her lawyers refused to disclose her location to the Government despite ongoing communications in 2019 and 2020. The text details the circumstances of her arrest, stating that she ignored FBI directives and ran away from clearly identified agents to hide in an inner room.

Court filing / legal memorandum (government opposition to bail)
2025-11-20

DOJ-OGR-00001073.jpg

A page from a court transcript dated April 1, 2021, featuring arguments by Ghislaine Maxwell's defense attorney. The attorney argues that the government's citations of 'dangerousness cases' are irrelevant to Maxwell's situation and emphasizes the impossibility of preparing for trial while Maxwell is detained during the COVID-19 crisis, citing lack of in-person access to the client due to BOP restrictions. The Judge attempts to interject at the bottom of the page.

Court transcript
2025-11-20

DOJ-OGR-00001064.jpg

This document is a page from a court transcript (Case 21-770) dated April 1, 2021, concerning a bail application. The defense attorney argues against a deep investigation into the detained client's finances, specifically addressing a 2016 real estate transaction of $15 million (likely Ghislaine Maxwell's townhouse sale). The defense disputes the government's claim that the client retains $14 million in liquid assets, citing liabilities and litigation expenses, while referencing legal precedents (Khashoggi, Dreier) regarding bail amounts.

Court transcript (bail proceeding)
2025-11-20

DOJ-OGR-00001062.jpg

This page is a transcript from a court hearing dated April 1, 2021 (Case 21-770), likely related to Ghislaine Maxwell's appeal regarding detention. The defense attorney argues that the defendant is not a flight risk ('opposite of hiding') and contends that the perjury charge—stemming from a denial of guilt during a deposition—should not heavily weigh the 3142 analysis against release. The attorney notes the government has been investigating the case for ten years.

Court transcript
2025-11-20

DOJ-OGR-00001061.jpg

This document is a page from a court transcript dated April 1, 2021, regarding Case 21-770. Defense counsel is arguing before a judge regarding Ghislaine Maxwell's 'risk of flight' status. The defense contends that Maxwell's use of tinfoil or Faraday bags was to prevent phone hacking, not to destroy evidence, and describes a security sweep where agents confirmed with a security guard that Maxwell lives at the house and relies on the guard for groceries.

Court transcript (southern district reporters)
2025-11-20

DOJ-OGR-00000988.jpg

This page is from a government filing (Case 1:20-cr-00330-AJN, U.S. v. Ghislaine Maxwell) dated July 2, 2020, arguing for the defendant's detention pending trial. The government argues that despite COVID-19 concerns, the defendant should remain at the Metropolitan Detention Center (MDC) like other inmates, citing her significant assets, foreign ties, and history of evading detection as flight risks. The document also introduces an argument based on the Crime Victims' Rights Act (CVRA), noting that victims and their counsel have been contacted and seek her detention.

Court filing / government memorandum regarding detention
2025-11-20

DOJ-OGR-00000964.jpg

This document is page 4 of a legal filing (bail application) for Ghislaine Maxwell, dated July 10, 2020. The defense argues that the government's concerns about flight risk due to her citizenship and finances are unfounded and notes the alleged crimes are 25 years old. The defense proposes a $5 million bond co-signed by six people, secured by UK property, along with home confinement, GPS monitoring, and strict travel restrictions within New York.

Legal filing / court document (bail application)
2025-11-20

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This document is page 8 of a court transcript filed on September 3, 2019. It discusses the legal concept of 'abatement' following the death of a defendant, citing the Second Circuit case *U.S. v. Wright*. The text explains that upon a defendant's death during a pending appeal, the conviction, indictment, restitution, and forfeiture orders are typically vacated.

Court transcript / legal filing
2025-11-20

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This is page 9 of a court transcript from Case 1:19-cr-00490-RMB (United States v. Jeffrey Epstein), filed on August 6, 2019. The Judge (The Court) rules to exclude time from the Speedy Trial Act calculations to allow for extensive pretrial preparation and tentatively schedules a trial for June 8, 2020. Defense attorney Mr. Weinberg requests oral arguments for motions, which the court schedules for October 28, 2019.

Court transcript
2025-11-20

DOJ-OGR-00000597.jpg

This document is Page 3 of a Protective Order filed on July 25, 2019, in the case USA v. Jeffrey Epstein (Case 1:19-cr-00490-RMB). It outlines strict protocols for handling 'Discovery' materials, including requirements for encryption and password protection when sharing with defense staff or experts. It explicitly prohibits the Government, the Defendant, or Counsel from posting any discovery information on the Internet or social media.

Court filing / protective order (page 3 of 9)
2025-11-20

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This document is page 24 of an appellate brief (Case 22-1426, dated Feb 28, 2023) arguing two main points: first, that the statute of limitations had expired for the offenses charged because the 2003 amendment to §3283 cannot be applied retroactively to offenses committed before its enactment. Second, it argues for a new trial based on juror misconduct, specifically that a juror lied on a questionnaire to conceal his own history as a victim of child sexual abuse, which the defense argues established bias.

Legal brief / appellate court filing
2025-11-20

DOJ-OGR-00021013.jpg

This page from a legal filing (Case 1:20-cr-00330-AJN, likely the Ghislaine Maxwell trial) discusses a dispute over a jury note regarding 'Count Four.' The argument centers on whether the jury could convict based solely on conduct in New Mexico versus the required New York law violation. The text details a debate over the placement of a comma in the jury's note and the Court's subsequent instruction to the jury to focus on New York law.

Court filing / legal brief (appeal/post-trial motion)
2025-11-20

DOJ-OGR-00021010.jpg

This document is a legal filing (likely an appellate brief response) from April 2022 summarizing testimony from a victim identified as 'Jane' regarding the criminal conduct of Ghislaine Maxwell ('the Defendant') and Jeffrey Epstein. It details how Jane met the pair at a summer camp, was groomed, and transported via private and commercial flights to properties in Florida, New York, and New Mexico for sexual activity starting when she was 14. The text highlights Maxwell's role in arranging travel and participating in the scheme to transport underage girls across state lines for illegal sexual acts.

Court filing / legal brief (appellate or post-trial response)
2025-11-20

DOJ-OGR-00020954.jpg

This document is page 11 of a court order filed on April 1, 2022, in the case of United States v. Ghislaine Maxwell. It details the Court's assessment of 'Juror 50,' who failed to disclose a history of sexual abuse during voir dire; the juror testified that this history did not affect his impartiality. The document also notes the denial of a defense request to stay the ruling pending the release of a documentary featuring said juror.

Legal court order / opinion
2025-11-20

DOJ-OGR-00020831.jpg

This document is a page from the jury instructions (Charge) in the trial of Ghislaine Maxwell. It details Instruction No. 21 regarding Count Four, which charges Maxwell with transporting an individual under 17 ('Jane') across state lines for illegal sexual activity in violation of New York Penal Law Section 130.55. The judge instructs the jury that the government must prove Maxwell's intent and knowledge beyond a reasonable doubt, though the illegal activity need not be the sole purpose of the transportation.

Court transcript / jury instructions
2025-11-20

DOJ-OGR-00020826.jpg

This document is a page from court transcripts (Jury Instruction No. 20) regarding the trial of Ghislaine Maxwell. It details the legal elements for 'Count Four,' specifically the charge of transporting an individual ('Jane') under the age of 17 in interstate commerce for illegal sexual activity between 1994 and 1997. The instruction clarifies that Maxwell did not need to physically transport the victim herself, but that making arrangements, such as purchasing tickets, satisfies the legal requirement.

Court transcript / jury instructions
2025-11-20

DOJ-OGR-00020787.jpg

This document is page 28 of a court order filed on April 16, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The court denies Maxwell's motion to dismiss multiplicitous counts without prejudice and addresses discovery disputes, specifically accepting the Government's representation that it has already disclosed all required Brady and Giglio material. The court orders the parties to negotiate a schedule for any remaining pretrial disclosures.

Court filing (memorandum & order)
2025-11-20

DOJ-OGR-00020781.jpg

This document is page 22 of a court ruling (Document 207) filed on April 16, 2021, in the case United States v. Maxwell. The court is denying Maxwell's motion to dismiss perjury counts, arguing that the ambiguity of questions and the materiality of her statements are issues of fact for a jury to decide, not grounds for pretrial dismissal. The text cites legal precedents regarding perjury, materiality in civil depositions, and the role of the jury.

Court order / legal opinion (page from a ruling on a motion to dismiss)
2025-11-20

DOJ-OGR-00020780.jpg

This page is from a court order (Case 1:20-cr-00330-AJN) dated April 16, 2021, addressing Ghislaine Maxwell's motion to dismiss perjury charges. The Court denied the motion, stating that the charges are legally tenable and that arguments regarding the ambiguity of questions asked during her civil deposition are matters for a jury to decide. The document cites several legal precedents (Lighte, Wolfson) regarding perjury and 'knowing falsity'.

Court order / legal filing
2025-11-20

DOJ-OGR-00016358.jpg

This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) dated August 10, 2022. It features the cross-examination of witness A. Farmer regarding a pair of boots purchased for her by Jeffrey Epstein. The questioning focuses on the wear and tear of the boots, specifically that the witness wore them 'two-stepping' (dancing) after 2006, and whether she had disclosed this usage to the government prosecutors.

Court transcript (cross-examination)
2025-11-20

DOJ-OGR-00015148.jpg

This document is page 16 of a court order (Case 1:20-cr-00330-PAE) rejecting the Government's claim that unsealing Ghislaine Maxwell's grand jury materials would reveal significant new information. The Court asserts that the grand juries were not used for investigative purposes and heard no testimony from victims, eyewitnesses, or suspects, meeting only for the routine purpose of returning an indictment. The document indicates the filing date as August 11, 2025.

Court order / legal opinion (page 16 of 31)
2025-11-20

DOJ-OGR-00015146.jpg

This document is page 14 of a court filing (Document 809) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It discusses the legal standards for unsealing grand jury materials, citing Rule 6(e) and case law emphasizing that disclosure requires 'exceptional circumstances.' The text argues that the Government's proposal to disclose testimony and exhibits from the grand juries that indicted Maxwell does not meet the required exceptions for law enforcement or national security.

Court filing / legal brief
2025-11-20

DOJ-OGR-00002362(1).jpg

This document is page 15 of a legal filing (Document 134) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on February 4, 2021. The text argues that the government colluded with a redacted third party (likely civil plaintiffs) starting in 2016 to engineer perjury charges against Maxwell. It contrasts two judicial rulings: one granting a government ex parte request and another rejecting an identical request in a different civil case, characterizing the government's actions as an attempt to deprive Maxwell of due process.

Legal filing / court motion (criminal case)
2025-11-20

DOJ-OGR-00002314(1).jpg

This document is a page from a legal motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell. The defense argues that the Superseding Indictment is vague, failing to identify specific accusers or dates beyond the range of 1994-1997. The filing requests that the Court dismiss Counts One through Four or force the Government to provide a Bill of Particulars, citing Federal Rule of Criminal Procedure 7(c)(1) and Constitutional precedents regarding due process.

Legal filing (motion to dismiss / request for bill of particulars)
2025-11-20
Total Received
$0.00
1 transactions
Total Paid
$0.00
1 transactions
Net Flow
$0.00
2 total transactions
Date Type From To Amount Description Actions
N/A Paid the government Kate $0.00 Public assistance/benefits sought by the witnes... View
2022-07-22 Received Ms. Maxwell the government $0.00 Judge intends to impose a fine; amount not spec... View
As Sender
321
As Recipient
183
Total
504

Defendant's access to legal materials and counsel

From: the government
To: Warden of the Metropol...

A direct conversation that took place in the morning to confirm the defendant's access to her legal documents and ability to confer with counsel.

Conversation
2022-06-26

Order to docket a motion

From: The Court (Alison J. N...
To: the government

This document is an order compelling the Government to docket a motion referenced by the Defendant by midnight on June 26, 2022.

Court order
2022-06-26

Order directing Government to respond to application

From: THE COURT
To: the government

Order directing response to application by Ransome and Stein.

Order
2022-06-25

Victim Notification

From: the government
To: THE COURT

Confirmation that victims have been notified of rights described in the CVRA

Confirmation
2022-06-22

Investigation of purported threat

From: MDC
To: the government

Confirmed remark was made but determined no actual payment or credible threat existed.

Internal investigation/report
2022-06-22

Argument on McDonough prong

From: the government
To: THE COURT

Argues that a deliberate falsehood is required.

Legal brief/filing
2022-04-01

Proposed questioning for Juror 50 regarding answers to qu...

From: the government
To: THE COURT

The Government submits a legal document to the Court proposing specific questions to ask Juror 50 about their questionnaire answers and how past experiences might affect their impartiality as a juror.

Court filing
2022-03-01

Proposed questioning for Juror 50 regarding answers to qu...

From: the government
To: THE COURT

The Government submits a legal document to the Court proposing specific questions to ask Juror 50 about their questionnaire answers and how past experiences might affect their impartiality as a juror.

Court filing
2022-03-01

Juror 50's public statements

From: the government
To: THE COURT

Brought Juror 50's public statements to the Court's attention and sought an inquiry.

Letter
2022-02-24

Memorandum in Opposition to the Defendant’s Motion for a ...

From: the government
To: Court

Argument against a new trial (omitted from this specific appendix)

Memorandum
2022-02-24

Opposition to Defendant's Proposed Redactions

From: the government
To: The defendant

The Government argues against the defendant's requests to redact legal arguments about the jury pool, investigative steps, views of underlying facts, and requested discovery.

Legal filing
2022-02-16

Opposition to motion for a new trial

From: the government
To: THE COURT

A brief filed by the Government opposing the Defendant's motion for a new trial.

Legal brief
2022-02-02

Order Dkt. No. 585

From: THE COURT
To: the government

Scheduling order regarding the NYT motion

Court order
2022-01-26

Scheduling considerations

From: the government
To: THE COURT

Referenced as setting forth scheduling considerations affecting post-trial motions (Dkt. No. 574).

Letter
2022-01-10

Scheduling considerations

From: the government
To: THE COURT

A letter from January 10, 2022 (Dkt. No. 574) is referenced, which set forth scheduling considerations affected by pending motions.

Letter
2022-01-10

Juror's post-verdict interviews

From: the government
To: THE COURT

On January 5, 2022, the Government informed the Court that a juror (Juror 50) had given at least three post-verdict interviews.

Legal notification
2022-01-05

Requesting a hearing

From: the government
To: U.S. District Court fo...

Requesting a hearing upon learning of interviews.

Letter
2022-01-05

Request for a hearing regarding a juror's statements

From: the government
To: The Court (presumably)

The letter mentions a "government’s letter of this morning requesting a hearing to consider a Juror’s statements".

Letter
2022-01-05

Juror's post-verdict interviews

From: the government
To: THE COURT

The Government informed the Court that a juror (believed to be Juror 50) had given interviews, disclosed being a victim of sexual abuse which was contrary to his questionnaire, and requested a hearing on the matter.

Letter
2022-01-05

Requesting a hearing

From: the government
To: U.S. District Court fo...

Request for hearing upon learning of interviews.

Letter
2022-01-05

Juror's statements

From: the government
To: Defense counsel

Inquiry regarding the defense's position on the juror issue; no response received at time of filing.

Communication
2022-01-04

Handling and admission of trial exhibits

From: the government
To: ["The Court"]

The Government informs the Court about the status of various exhibits, noting some can be released publicly and others require redactions or sealing after conferring with the defense. The Government requests the Court to admit exhibits GX 603-A and GX 604-A into evidence.

Letter
2021-12-19

Discovery Material

From: the government
To: the defense

A large volume of electronically-stored information.

Discovery production
2021-12-17

Exclusion of Dr. Loftus's expert testimony

From: the government
To: THE COURT

The court mentions receiving a letter dated December 15th in which the government seeks to exclude two aspects of Dr. Loftus's anticipated expert testimony.

Letter
2021-12-15

Mr. Hamilton's COVID status

From: Defense counsel
To: the government

Notification that Mr. Hamilton tested positive for COVID.

Notification
2021-12-15

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