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-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.
DOJ-OGR-00001166.jpg
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.
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.
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.
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.
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.
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.
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.
DOJ-OGR-00000646.jpg
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.
DOJ-OGR-00000620.jpg
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.
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.
DOJ-OGR-00021071.jpg
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.
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.
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.
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.
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.
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.
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.
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.
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'.
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.
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.
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.
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.
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.
| 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 CV
Production of Dr. Rocchio's curriculum vitae bearing Bates number 3502-006.
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.
Disclosure Order
The Court issued a disclosure order which the government sought to reconsider.
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.
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 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.
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.
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.
Discovery Production
Production of witness list, Giglio material, Jencks Act material, and Rule 404(b) notice.
Court-ordered disclosures
Hard drive sent via FedEx.
Evidence Admissibility
Evidence contained in this letter is being argued as admissible under Rule 404(b) or as direct evidence.
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