the government
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Adversarial |
6
|
1 |
| 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-00018349.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. The judge is ruling to exclude photographic evidence of a stuffed tiger and dog found in Epstein's New York apartment in 2019, deeming them irrelevant and prejudicial because they do not match the specific 'artwork of animals' described by the witness 'Jane' from years prior. However, the judge notes anticipation that 'schoolgirl outfits' found in the same apartment in 2019 will likely be introduced.
DOJ-OGR-00018339.jpg
This document is a page from a court transcript filed on August 10, 2022, related to Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). The Judge is addressing a government request regarding the testimony of a witness using the pseudonym 'Kate.' The Judge notes that while Kate alleges sexual conduct with Jeffrey Epstein, she was over the age of consent at the time and is not a victim of the specific crimes charged in this indictment. However, her testimony is deemed relevant to Mann Act counts and 404(b) evidence. The Judge rules that her testimony regarding sexual details will be limited to avoid prejudice and that the jury will be instructed that the Court prohibited asking for those specific details.
DOJ-OGR-00018311.jpg
This document is a transcript page from the cross-examination of Mr. Parkinson by attorney Mr. Everdell in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The questioning focuses on a specific photograph of an unidentified woman found during a search of Jeffrey Epstein's house conducted by Parkinson. Everdell establishes that Parkinson did not recall finding, nor did the government present, any other photographs or video evidence of this specific woman from the search.
DOJ-OGR-00017679.jpg
This document is a page from the cross-examination of a witness named 'Jane' in the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The defense attorney questions Jane about prior statements she made to the government, confirming that she previously stated Maxwell was not present or did not witness specific sexual acts (oral sex, intercourse) between Jane and Jeffrey Epstein. The witness confirms several of these prior statements while stating she does not recall others.
DOJ-OGR-00015111.jpg
This document is page 3 of a legal filing (Case 1:20-cr-00330) addressed to Judge Paul Engelmayer, dated August 6, 2025. It argues for strict protocols and heightened caution regarding the unsealing of grand jury materials to protect the privacy and safety of Epstein and Maxwell's victims, citing the Crime Victims' Rights Act (CVRA) and Rule 6(e). A significant footnote highlights that several victims have already died by suicide or overdose and argues that a potential pardon would cause irreparable harm.
DOJ-OGR-00008656.jpg
This document is a page from the jury instructions (Instruction No. 28) filed on December 18, 2021, in the trial of Ghislaine Maxwell. It details the 'Third Element' of Count Six: Sex Trafficking of an Individual Under the Age of 18. The instruction clarifies that the Government must prove Maxwell knew the victim, identified as 'Carolyn,' would be caused to engage in commercial sex acts, and explicitly states that the victim's consent is not a defense if she was under 18.
DOJ-OGR-00008588.jpg
This document is page 50 (internal paging 49) of a court filing (Document 563) from the Ghislaine Maxwell trial, filed on December 18, 2021. It contains jury instructions explaining the legal standards for establishing 'guilty knowledge' and participation in a conspiracy. The text clarifies that Maxwell does not need to know every detail or member of the conspiracy to be found guilty, and that a single act can establish membership, making her liable for the conspiracy's activities.
DOJ-OGR-00008568.jpg
This document contains Jury Instruction No. 20 from the trial of Ghislaine Maxwell, filed on December 18, 2021. It defines the first element of Count Four: Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity. The text outlines that the Government must prove Maxwell knowingly transported 'Jane' in interstate commerce, noting that personal transportation is not required if she made arrangements (like purchasing tickets), and that the victim's consent is irrelevant to the charge.
DOJ-OGR-00008567.jpg
This document is a page from the jury instructions (Instruction No. 19) filed on December 18, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It outlines the three legal elements required to prove 'Count Four: Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity,' specifically relating to a victim identified as 'Jane' between 1994 and 1997. The text includes markup showing specific legal language adjustments, such as defining the age requirement and limiting the scope to interstate commerce.
DOJ-OGR-00008558.jpg
This document is page 20 of 167 from a court filing (Document 563) dated December 18, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains Jury Instruction No. 11 regarding 'Multiple Counts,' instructing the jury to consider each of the six counts separately. The text shows specific edits replacing the generic term 'Defendant' with 'Ms. Maxwell' and outlines the burden of proof required by the Government.
DOJ-OGR-00008524.jpg
This document is page 68 of 82 from a court filing (Document 562) dated December 17, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It contains Jury Instruction No. 49, which explicitly instructs the jury that Ms. Maxwell exercised her Constitutional right not to testify, that the burden of proof rests solely with the Government, and that no adverse inference can be drawn against her for not taking the witness stand.
DOJ-OGR-00008514.jpg
This document is page 58 of 82 from a court filing (Document 562) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 17, 2021. It contains 'Instruction No. 41: Time of Offense,' which instructs the jury that the Government is not required to prove the exact dates of the alleged conduct, provided it occurred 'on or about' the alleged times.
DOJ-OGR-00008487.jpg
This document is page 31 of 82 from a court filing (Document 562) in Case 1:20-cr-00330-PAE, filed on December 17, 2021. It contains Jury Instruction No. 23 regarding Counts Two and Four, clarifying that for the charges of enticement and transportation, the Government need only prove the Defendant had the requisite intent, and it is immaterial whether the intended sexual activity actually occurred.
DOJ-OGR-00008361.jpg
A letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The Government informs the court that, after conferring with the defense, they will not agree to a stipulation regarding the testimony of Robert Glassman. The Government argues that a specific statement in an email is inadmissible and requires context to be understood by the jury.
DOJ-OGR-00008341.jpg
This is a page from a court transcript (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) filed on December 10, 2021. The Judge ('The Court') is discussing jury instructions regarding a specific witness involved in sexual conduct in New Mexico. The Judge notes that while the witness was above the age of consent in New Mexico, the government is using the evidence to prove enticement for illegal acts in New York, and the jury instructions must accurately reflect this legal distinction without favoring the government's arguments.
DOJ-OGR-00001895.jpg
This document is a page from a court transcript (filed Dec 10, 2020) detailing the government's efforts to notify victims regarding the case against Ghislaine Maxwell. It outlines specific dates in July 2020 when notifications were sent regarding her arrest, presentment, and bail hearing. It explicitly mentions notifications sent to individuals identifying as victims of both Ghislaine Maxwell and Jeffrey Epstein, even those not named in the indictment.
DOJ-OGR-00001813.jpg
This document is Page 2 of a Government filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on October 30, 2020. It addresses delays in electronic discovery production due to vendor volume and refutes defense accusations regarding the definition of the 'Prosecution Team' and the withholding of exculpatory material. A significant footnote (Footnote 2) argues that the 'genesis' of Jeffrey Epstein's Non-Prosecution Agreement with the Southern District of Florida is irrelevant because the current defendant (Maxwell) was not a party to it, was not named in it, and the agreement covered a different time period.
DOJ-OGR-00001788.jpg
This document is Page 2 of a court filing (likely from United States v. Maxwell based on the case number) dated October 7, 2020, addressed to Judge Alison J. Nathan. The Government updates the court on discovery progress, committing to a November 9, 2020 deadline for electronic discovery and outlining schedules for producing witness statements (Brady/Giglio materials) 4 to 8 weeks before trial. The document also argues the legal scope of the prosecution's obligations, citing case law (Avellino, Quinn) to assert that the prosecution is not responsible for knowledge held by other government agencies (like the FBI) not directly involved in the investigation.
DOJ-OGR-00001744.jpg
This document is page 2 of a court order filed on August 25, 2020, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court addresses the Defendant's request regarding pretrial disclosure schedules (denied without prejudice) and conditions of confinement. Specifically, the Court denies Maxwell's request for a court order mandating her release to the general population and specific discovery access, noting that the Bureau of Prisons (BOP) has already modified conditions to allow her 13 hours of access to discovery materials daily.
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-00001587.jpg
This document is a page from a legal filing (Case 1:20-cr-00330-AJN) arguing for Ghislaine Maxwell's release on bail. The defense argues that she is not a danger to the community, cites the health risks of COVID-19 in prison, and claims she is not a flight risk due to her strong ties to the U.S. (citizenship, 30-year residency, family in NY) and her history of cooperation through counsel since Epstein's arrest.
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-00001384.jpg
This document is page 12 of a legal filing (Case 21-770) dated April 19, 2021, in which Ghislaine Maxwell's defense team argues against the Government's narrative regarding her confinement. The defense claims that unsanitary conditions are caused by others, accuses the Government of a double standard and HIPAA violations for releasing Maxwell's vaccination status while keeping accusers anonymous, and asserts that her vaccination does not resolve issues regarding her ability to prepare for trial using 'ancient' technology.
DOJ-OGR-00001375.jpg
This document is page 3 of a legal reply brief filed on April 19, 2021, in Case 21-770 (associated with Ghislaine Maxwell). The defense argues that the lower court did not conduct a 'lengthy bail hearing' and that the Government presented no actual evidence, relying solely on the text of the Indictment to argue the strength of the case and flight risk. The filing contends the court erred by accepting the Indictment itself as proof of the strength of evidence.
| 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 |
Compliance of Noel and Thomas
Informed the Government that Noel and Thomas complied with the terms of the agreement.
Witness order
The Government conferred with the defense on Saturday (December 11, 2021, 'yesterday' from the filing date) about the witness order and was told more information would be forthcoming.
Unknown (referenced in text)
Government seeking to relitigate an issue regarding photo evidence.
Request for admission of photographs
The government filed a letter with the Court on December 4th, 2021, requesting the admission of a subset of photographs of Jeffrey Epstein's apartment.
Reply to Defendant's response re GX 52
Order to file a reply addressing argument that Employee-1 cannot authenticate GX 52 due to actions of a former employee.
Opposition to the defense motion to exclude evidence of M...
The Government submitted a supplemental letter regarding its opposition to a defense motion, which was temporarily sealed.
Mann Act conspiracies
With respect to the Mann Act conspiracies, the particular criminal sexual activity relates to a particular statute in New York.
Production of Testimony List
List of Dr. Rocchio's previous testimony bearing Bates number 3502-002.
Request for Reciprocal Discovery
Request for notice regarding any expert witness the defendant intends to rely upon.
Motion to Resolve Litigation Related to Prior Consistent ...
This document is a filing by the Government arguing for the admission of prior consistent statements of its witnesses under certain conditions at trial.
Production of CV
Production of Dr. Rocchio's curriculum vitae bearing Bates number 3502-006.
Disclosure Order
The Court issued a disclosure order which the government sought to reconsider.
Jury selection procedures
The Government argues against providing juror identities weeks in advance of selection, citing legal precedent that the purpose of voir dire is to find disqualifications, not to allow for in-depth analysis. It requests that peremptory challenges be exercised at the conclusion of voir dire and asks the Court to clarify when juror names will be provided.
Jury selection procedures
The Government argues against providing juror identities weeks in advance of selection, citing legal precedent that the purpose of voir dire is to find disqualifications, not to allow for in-depth analysis. It requests that peremptory challenges be exercised at the conclusion of voir dire and asks the Court to clarify when juror names will be provided.
Proposed Jury Charge
Government provided the defense with its proposed jury charge.
Proposed Jury Charge
Government provided the defense with its proposed jury charge.
Response Deadline
Order to respond to Defendant's letter by 5:00 p.m. on Oct 15, 2021.
Response to Dkt. No. 345
Ordered response due by 5:00 p.m.
Response to defendant's letter on legal mail delivery
The Court issued an order (Dkt. No. 348) directing the Government to respond to a letter from the defendant regarding the delivery of her legal mail.
Dkt. No. 347
Ordering the Government to respond to the defendant's letter.
Institutional Emergency
Informed Govt of emergency impacting safety/security preventing mail delivery.
Institutional emergency at the MDC
Legal counsel at the MDC informed the Government about an institutional emergency on October 13, 2021, which delayed mail delivery.
Identification of exhibits
Letter identifying exhibits necessary to identify parties to emails.
Maxwell Rule 404(b) letter
Notice of evidence regarding Rule 404(b) and potential witnesses.
Evidence Admissibility
Evidence contained in this letter is being argued as admissible under Rule 404(b) or as direct evidence.
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