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

Conditions of confinement

From: the government
To: Judge Nathan (implied)

Referenced letter claiming Maxwell's detention is superior to others.

Letter
2021-04-06

MDC protocols / Eye mask usage

From: the government
To: Judge Nathan

Conveyed MDC's imprecise language stating Maxwell wore an eye mask at night (later corrected to 'non-contraband items').

Letter
2021-04-06

MDC's imprecise language regarding Maxwell's eye covering

From: the government
To: Judge Nathan

The Government sent a letter to Judge Nathan on April 6, 2021, conveying the MDC's imprecise language about Maxwell wearing an eye mask, an inaccuracy the Government later acknowledged.

Letter
2021-04-06

Defendant's Meals

From: Legal Counsel
To: the government

Informed that meals arrive in microwavable/oven safe containers and are heated in a thermal oven.

Information relay
2021-04-06

Conditions of confinement

From: the government
To: Judge Nathan (implied)

Referenced letter that Sternheim is responding to.

Letter
2021-04-06

Notification process

From: the government
To: victims

Informed victims about an opt-in process for receiving future notifications.

Letter
2021-04-01

Defendant's flight risk and extradition difficulties

From: the government
To: ["Your Honor"]

The government's representative is arguing to a judge that the defendant is a flight risk due to her citizenships, international ties, and wealth, combined with the legal difficulties of extraditing her from France or the United Kingdom.

Oral argument
2021-04-01

The Government's Memorandum in Support to the Defendant's...

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

A legal memorandum filed by the government in support of a motion for release filed by the defendant in case 21-58.

Legal memorandum
2021-04-01

Production of Giglio material

From: the government
To: Defense/Court

Agreement to produce Giglio material six weeks in advance of trial.

Letter
2021-04-01

Reply Memorandum

From: the government
To: THE COURT

Contains one victim's views regarding the bail proceeding.

Memorandum
2021-04-01

Victim Statement

From: victim
To: the government

Written statement submitted to be read aloud by the government during proceedings.

Statement
2021-04-01

Bates ranges relevant to Minor Victim-4

From: the government
To: the defense

Provision of list of Bates ranges within discovery materials relevant to Minor Victim-4.

Discovery production
2021-03-29

Additional redaction request

From: the defense
To: the government

Defense requested an additional redaction to the bottom of page 134 earlier that day.

Request
2021-03-22

Justification for specific redaction and sealing requests

From: the government
To: THE COURT

The Court ordered the Government to file a letter by this date if they wish to seek more tailored redactions.

Letter
2021-03-22

Order regarding redactions

From: Judge Alison J. Nathan
To: the government

Previous order referenced in the text.

Court order (referenced)
2021-03-18

Government’s Omnibus Memorandum in Opposition to Defendan...

From: the government
To: THE COURT

A legal memorandum filed by the government in response to Ms. Maxwell's pre-trial motions. The document cites this memorandum as evidence of the government's weakening case.

Legal filing
2021-02-26

MDC conditions (Dkt.158)

From: the government
To: Court

Government's defense of MDC's request regarding laptop usage.

Letter
2021-02-16

Production date for Jencks Act material

From: the defense
To: the government

Defense proposed March 12, 2021 for production of materials; Government denied the request.

Conferral
2021-02-04

Request for 404(b) evidence deadline

From: Defense counsel
To: the government

Defense requested evidence be provided by March 12, 2021; Government denied the request.

Meeting/conferral
2021-01-25

Lifting restriction on laptop access

From: the government
To: MDC officials

Government requested MDC to lift restrictions on Maxwell's laptop access without success.

Contact/request
2021-01-14

Discussion related to the case

From: Shawn (witness)
To: the government

The witness scheduled a phone or video meeting with the government on January 13th, 2021.

Phone meeting or video meeting
2021-01-13

Related to the case

From: Shawn (witness)
To: the government

The witness scheduled a phone or video meeting with the government on January 13th, 2021.

Phone meeting or video meeting
2021-01-13

Unknown

From: the government
To: JANE

The witness ('Jane') is asked if she recalls speaking to the government in October of 2021.

Interview
2021-01-01

Lifting laptop restriction

From: the government
To: MDC officials

Government requested MDC lift restrictions on laptop access at defense counsel's request.

Contact
2021-01-01

Lifting laptop restrictions

From: the government
To: MDC officials

Government requested MDC lift restrictions on laptop access without success.

Contact
2021-01-01

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