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-00003012.jpg
This page is from a government legal filing (Case 1:20-cr-00330-PAE) opposing Ghislaine Maxwell's motion to dismiss. The Government argues that Maxwell's claims of prejudice due to pre-indictment delay and media publicity since 2011 are speculative and insufficient to warrant dismissal. A footnote details a discovery dispute where the defense is requesting names, birth dates of minor victims, and specific details of overt acts.
DOJ-OGR-00004724.jpg
This document is page 17 of a Government filing (Document 295) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on May 25, 2021. The text argues that the Defendant's motion to dismiss the S2 Indictment based on improper pre-trial delay should be denied, citing that the Court has already rejected similar arguments and that the defendant failed to prove actual prejudice or intentional delay by the Government. It references case law standards for due process violations regarding pre-indictment delays.
DOJ-OGR-00014619.jpg
This document is page 219 of a court transcript (Document 767, Case 1:20-cr-00330-PAE) filed on August 10, 2022. It contains the judge's charge to the jury regarding the legal standards for conspiracy as applied to the defendant, Ms. Maxwell. The text explains that the government must prove knowledge and intent, but clarifies that Maxwell did not need to know every detail or member of the conspiracy, nor did she need to be involved from the beginning to be held responsible for the conspiracy's activities.
DOJ-OGR-00014598.jpg
This document is page 198 of a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It contains the Judge's charge to the jury regarding Ghislaine Maxwell, specifically defining legal concepts such as 'acting knowingly,' 'interstate commerce,' and 'intent' in the context of Count Two: Enticement to engage in illegal sexual activity. The text outlines the government's burden of proof regarding Maxwell's intent for individuals to engage in criminal sexual activity under New York law.
DOJ-OGR-00002765.jpg
This document is page 4 of a court order filed on March 18, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Government's broad requests to redact pages 1–128 and seal Exhibits 8 and 9, citing a lack of non-conclusory basis for how disclosure would imperil the investigation. The Court sets a deadline of March 22, 2021, for the Government to submit a letter justifying more tailored redactions and agrees with the Defendant regarding objections to redactions on pages 187–188.
DOJ-OGR-00020114.jpg
This document is page 7 of a legal filing filed on December 23, 2020, arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell and her spouse have pledged all their assets and that her spouse has liquidated investments to support the bond, countering the government's argument that she is a flight risk or 'adept at hiding.' The text also disputes government claims regarding the verification of the spouse's financial information.
DOJ-OGR-00020094.jpg
This document is a page from a Government court filing (Case 1:20-cr-00330-AJN, likely USA v. Maxwell) dated December 18, 2020. It addresses defense complaints regarding discovery access, noting that one hard drive malfunctioned because the defendant dropped it, and details her special confinement conditions at the MDC, which include 13 hours out of cell, private shower, computers, phone, and TV. A footnote highlights a contradiction in the defense's arguments regarding the value of discovery versus the prejudice caused by delays.
DOJ-OGR-00020050.jpg
This is page 30 of a defense filing (likely a bail application) dated December 14, 2020, in the case against Ghislaine Maxwell. The defense argues that despite the government's initial claims of 'strong' evidence backed by flight logs and diaries, the 1.2 million pages of discovery produced so far contain no meaningful corroboration of the charges. The defense emphasizes that the produced documents largely date from the 2000s and 2010s, rather than the 1994-1997 period charged in the indictment.
DOJ-OGR-00020045.jpg
This document is page 25 of a defense filing arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell was not evading arrest but rather avoiding the press, evidenced by the government's ability to easily track her phone. It further argues she is not a flight risk to the UK or France, noting she waived extradition rights and remained in the US following Jeffrey Epstein's arrest and death.
DOJ-OGR-00020037.jpg
This document is page 17 of a legal filing (Defense Bail Submission) dated December 8, 2020, arguing for Ghislaine Maxwell's release on bail. It cites a 'Macalvins report' to refute government claims that Maxwell's finances are opaque, stating that she and her spouse have disclosed all assets, which total approximately $22.5 million—the exact amount proposed for the bond. A footnote contains redactions regarding the name of a specific bank involved in her finances.
DOJ-OGR-00005651.jpg
This document is a legal filing from the Government (prosecution) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), providing notice of expert testimony by Dr. Rocchio. The filing outlines that Dr. Rocchio will testify generally about the psychology of trauma, sexual abuse, grooming tactics, and delayed disclosure by victims, explicitly stating she has not evaluated any specific victims in this case. Additionally, the Government requests reciprocal discovery regarding any expert witnesses the defense intends to call.
DOJ-OGR-00005615.jpg
This document is a page from a defense filing in the Ghislaine Maxwell case, dated October 29, 2021. It argues that the Government's disclosure of Rule 404(b) evidence was insufficient and late, citing a letter served on October 11, 2021. The filing highlights discrepancies between the 404(b) letter and the trial exhibits provided the same day, specifically noting post-conspiracy evidence such as flight logs (2005-13), Amazon shipments (2013), and financial statements (2007) that were not justified in the letter.
DOJ-OGR-00005613.jpg
This document is page 4 of a legal filing (Motion in Limine) in the case of United States v. Ghislaine Maxwell, filed on October 29, 2021. The defense argues that the Government should be precluded from introducing certain evidence under Federal Rule of Evidence 404(b) because the prosecution failed to provide particularized notice and reasoning as required by the December 2020 amendments to the rule. The text outlines the specific requirements of the amended rule regarding notice in criminal cases.
DOJ-OGR-00005603.jpg
This document is page 9 of a legal filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The text presents a legal argument citing precedents (Katz, Campagnuolo, Wicker) regarding discovery violations, willful misconduct, and the suppression of evidence as a sanction. The filing argues that the government failed to comply with a disclosure order issued months prior and criticizes the government's bad faith in seeking reconsideration rather than compliance.
DOJ-OGR-00005596.jpg
This document is the Table of Contents for a legal filing (Document 384) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The filing outlines the Defense's arguments that the Government failed to identify co-conspirator statements and overwhelmed the defense with document dumps, violating court orders. The Defense argues this hinders cross-examination and requests the preclusion of these purported statements as a remedy.
DOJ-OGR-00005567.jpg
This is page 13 of a legal filing (Document 383) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The visible text discusses 'Minor Victim-4,' arguing that the defense's attempts to attack her credibility based on statements made to the USAO-SDFL are irrelevant to her privacy interests regarding her upcoming testimony. Large portions of the page are redacted.
DOJ-OGR-00005566.jpg
This document is page 12 (internal page 11) of a court filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The main body text is entirely redacted. A visible footnote discusses a protective order (Dkt. No. 37) previously entered by the Court to protect the privacy and identities of alleged victims and witnesses.
DOJ-OGR-00005520.jpg
This is page 65 of 69 from a court filing (Document 382) in the case of USA v. Ghislaine Maxwell, filed on October 29, 2021. The defense argues that the burden of proof lies solely with the government and criticizes the prosecution's concerns about jury confusion. Specifically, under Section XI, the defense asserts that Maxwell was the 'prevailing party' in a previous civil litigation based on the same facts, a point the government seemingly disputes.
DOJ-OGR-00005519.jpg
This document is page 64 of a legal filing (Document 382) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. The defense argues against government motions to exclude evidence regarding Maxwell's 'charitable works' and 'family history,' suggesting these may become relevant if the government opens those topics. Section X argues strongly against the government's request to preview the defense's evidence, using the metaphor of having 'hands tied behind their back and their mouths duct-taped,' while noting that accusers are testifying under anonymity.
DOJ-OGR-00002895.jpg
This document is page 6 of a legal filing (Document 195) from the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE), filed on April 5, 2021. The Government is arguing that the Court should require notice for all Rule 17(c) subpoenas rather than allowing them to be issued *ex parte* (without notice), citing various legal precedents (Wey, Earls, Skelos, St. Lawrence, Boyle) to support the position that *ex parte* proceedings should only be permitted with a compelling reason. Footnotes clarify the Government's concern regarding financial institutions responding to broad subpoenas for impeachment purposes and state that this request does not apply to subpoenas returnable at trial.
DOJ-OGR-00002893.jpg
This document is Page 4 of a legal filing (Document 195) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell) filed on April 5, 2021. The text argues that defense subpoenas asking for 'any and all' records are improper discovery requests and asserts that the Court should require the Defendant to notify the Government of any Rule 17(c) subpoena applications. It cites concerns regarding the harassment of witnesses and the protection of victim confidentiality.
DOJ-OGR-00020371.jpg
This document is page 13 of a legal filing (Case 21-58, Document 92) dated May 27, 2021. It outlines the 'Applicable Law' regarding pretrial detention, specifically citing 18 U.S.C. § 3142. The text argues that for offenses involving minor victims (18 U.S.C. §§ 2422 or 2423), there is a statutory presumption that no conditions will assure the defendant's appearance, placing a burden of production on the defendant to prove they are not a flight risk.
DOJ-OGR-00005847.jpg
This document is a page from a Government legal filing (dated Oct 29, 2021) in the case against Ghislaine Maxwell. The Government rebuts defense accusations regarding discovery violations, stating they provided co-conspirator statements 'unusually early' (seven weeks before trial). Additionally, the Government argues against suppressing the identification of the defendant by 'Minor Victim-4,' asserting that the victim knew the defendant personally for decades.
DOJ-OGR-00005840.jpg
This document is a page from a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It details procedural disputes regarding the timing of the Government's disclosure of co-conspirator statements to the defense. The Court ruled that the Government's commitment to produce these statements six weeks before trial (alongside Jencks Act and Giglio materials) was sufficient, denying the defense's request for earlier identification.
DOJ-OGR-00005837.jpg
This document is a page from a Government filing in the Ghislaine Maxwell trial (Case 1:20-cr-00330), filed on October 29, 2021. It argues for the admissibility of the terms 'minor' and 'sexual abuse' regarding Minor Victim-3, noting she was 17 when sexual contact with Epstein began. The prosecution asserts that the defendant knew of Epstein's preference for underage girls and rejects the defense's request for jury instructions regarding United Kingdom law.
| 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.
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.
Disclosure Order
The Court issued a disclosure order which the government sought to reconsider.
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.
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.
Maxwell Rule 404(b) letter
Notice of evidence regarding Rule 404(b) and potential witnesses.
Notice / Disclosures
Notice regarding evidence/testimony, deemed adequate by the Government.
Evidence Admissibility
Evidence contained in this letter is being argued as admissible under Rule 404(b) or as direct evidence.
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