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-00009058.jpg
This document is page 50 (PDF page 57) of a legal filing dated February 24, 2022, in the case of United States v. Ghislaine Maxwell. The defense requests a hearing to question Juror No. 50 regarding potential bias, alleging that at least two jurors gave false answers during voir dire which violated Maxwell's Sixth Amendment rights. The filing argues that Federal Rule of Evidence 606(b) does not prohibit this inquiry as it pertains to juror qualifications rather than the content of deliberations.
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This document is page 2 of a Government filing from February 16, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The Government argues against the defendant's requests to redact specific information from a briefing, including arguments about the jury pool composition (specifically regarding sexual abuse survivors), investigative steps taken by the defense, the defense's view of underlying facts, and discovery requests. The Government asserts these redactions are not authorized by the Court's previous orders or are not narrowly tailored.
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This is page 3 of a court order filed on Feb 11, 2022, in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330). The Court rules against the Defendant's request to completely seal motion papers related to an inquiry into 'Juror 50,' stating that wholesale sealing is not narrowly tailored to serve the interest of justice. The Judge notes that much of the information is already public and that the Court, as the fact-finder for the inquiry, is already privy to the information regardless of sealing.
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This document is page 7 of a defense motion filed on July 10, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a danger to the community (unlike Epstein), that COVID-19 poses a severe health risk in detention hindering her defense, and that she is not a flight risk due to her U.S. citizenship and lack of criminal record. It asserts she stayed in the U.S. and maintained contact with the government after Epstein's arrest rather than fleeing.
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This document is page 225 of a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022, containing jury instructions (Charge) for the trial of Ghislaine Maxwell. The text outlines legal standards for 'overt acts' regarding conspiracy charges, specifically Instruction No. 37. It explicitly instructs the jury that they cannot convict Maxwell on Counts One or Three solely based on the testimony of a witness named 'Kate'.
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This document is page 221 of a court transcript (filed August 10, 2022) containing jury instructions (Charge) for the trial of Ghislaine Maxwell. It details the legal standards for conspiracy, specifically addressing the presumption of continuity in a conspiracy, the requirements for withdrawal, and Instruction No. 36 regarding the 'Third Element' which requires the government to prove an 'overt act' was committed.
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This document is page 215 of a court transcript (Document 767) filed on August 10, 2022, containing Jury Instruction No. 34 regarding conspiracy charges against Ghislaine Maxwell. The text outlines the requirements for proving a conspiracy and details Count One, which charges Maxwell with conspiring between 1994 and 2004 to entice individuals under age 17 to travel for illegal sexual activity.
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This document is page 210 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 the legal standards for finding Ghislaine Maxwell guilty of 'aiding and abetting' in Counts Two, Four, and Six. The text defines the necessity of proving willful association with the crime while clarifying that mere presence or knowledge of the crime is insufficient for conviction.
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This document is a page from the cross-examination transcript of witness A. Farmer (Annie Farmer) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). The questioning focuses on Farmer confirming she spoke to the government in roughly May 2020 and subsequently submitted a 3,000-page claim to the Epstein Victims Compensation Program on June 26, 2020. Defense attorney Ms. Menninger then introduces exhibit AF-13 for the witness to review.
DOJ-OGR-00013482.jpg
This document is a page from the cross-examination of a witness named Rodgers (likely a pilot) in the case United States v. Ghislaine Maxwell (1:20-cr-00330). Rodgers admits that his previous statement to the government—that he first met 'Jane' around 2000—was based on memory without researching his logbooks and was 'a couple of years off.' The attorney points out that flight logs from 1996, 1997, and 1998 show a passenger with Jane's first name, establishing an earlier connection than Rodgers initially recalled.
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This document is page 2 of a government filing in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on June 24, 2022. The Government argues that victims have a right to be heard at sentencing and opposes the defendant's request to redact victim impact statements, citing that privacy interests belong to the victims, not the defendant. The filing cites legal precedents (Eberhard, Lugosch) regarding the Court's discretion to accept information and the standards for sealing documents.
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This document is a Government filing addressing Ghislaine Maxwell's complaints regarding her confinement conditions at the MDC. It refutes claims about discovery access, clarifying that she was provided a laptop and ample attorney visits. It also addresses email deletions (attributing them to BOP policy or Maxwell's own actions), legal mail delivery, and justifies nighttime flashlight checks as standard safety procedures for all inmates.
DOJ-OGR-00010368.jpg
This document is page 2 of a court order from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 29, 2022. The Court denies the Defendant's motions for acquittal (Rule 29) and to vacate convictions based on constructive amendment or prosecutorial delay (Rule 33), citing sufficient evidence and lack of prejudice. However, the Court rules in favor of the Defendant regarding 'multiplicitous' counts, concluding that Counts One, Three, and Five charge the same offense regarding a decade-long unlawful agreement.
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This document is page 10 of a legal filing from March 2022 in the US v. Maxwell case. The defense argues that a Jury Note regarding Count Four indicates the jury was considering convicting Maxwell based on intent for sexual activity occurring in New Mexico, which the defense claims raises a 'constructive amendment' issue. The text disputes the government's interpretation of the note, accusing the government of inserting a comma to alter the meaning and downplay the jury's focus on New Mexico.
DOJ-OGR-00009881.jpg
This page is from a legal filing (Document 644) dated March 11, 2022, in the case of Ghislaine Maxwell. The text argues that Maxwell does not need to prove prejudice or that an innocent person was convicted to warrant a new trial. It counters government arguments that discourage inquiries into juror misconduct, citing case law (Tanner v. United States, United States v. Ianniello) regarding the sanctity of jury deliberations and the right to an impartial jury.
DOJ-OGR-00009843.jpg
This document is a page from a Government filing in the case against Ghislaine Maxwell (Case 1:20-cr-00330), dated March 11, 2022. It discusses a dispute regarding 'Juror 50', who has requested access to his own voir dire transcript and juror questionnaire; the defense opposes this, arguing it would prejudice the investigation into the juror's conduct, while the government supports the juror's right to access a document he authored. The text also references a separate motion by The New York Times to unseal juror questionnaires.
DOJ-OGR-00009813.jpg
This is page 15 of a legal filing (Document 643) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on March 11, 2022. The Government argues that the defendant has failed to meet the 'McDonough test' requirements to secure a new trial based on juror misconduct, specifically stating that the defendant must prove the juror committed a 'deliberate falsehood' rather than an honest mistake. Despite this, the Government notes that it consents to a 'limited hearing' on the matter.
DOJ-OGR-00009749.jpg
This document is page 57 of a legal filing (Document 642) from the US v. Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on March 11, 2022. In the text, Maxwell's defense requests a specific protocol for a hearing to question Juror No. 50 and potentially a second juror regarding allegations that they gave false answers during voir dire. The defense argues that this inquiry is necessary to prove the jury was not fair and impartial under the Sixth Amendment and asserts that Federal Rule of Evidence 606(b) does not prohibit this inquiry as they are not impeaching the verdict based on deliberations.
DOJ-OGR-00009573.jpg
This page is from a Government legal filing (Document 621, Case 1:20-cr-00330-PAE) arguing against a post-trial motion by the defendant (Ghislaine Maxwell). The Government asserts that the jury did not improperly convict the defendant based solely on sexual abuse of a victim named 'Jane' in New Mexico, but rather followed instructions regarding violations of New York law. The text discusses jury instructions, the lack of New Mexico specific legal charges presented to the jury, and refutes the defense's claim of a constructive amendment or variance.
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This document is page 3 of a legal filing (Document 621) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It contains the 'Preliminary Statement' and 'Legal Standard' sections of the Government's opposition to the defendant's post-trial motions for acquittal or a new trial. The text outlines the legal standards for Rule 29 (acquittal based on insufficient evidence) and Rule 33 (new trial in the interest of justice), citing various legal precedents.
DOJ-OGR-00009561.jpg
This document is page 20 of a Court Order filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell. The Judge orders that Juror 50's completed questionnaire be unsealed and docketed, citing that public interest outweighs privacy concerns following the juror's public comments. Additionally, the Court schedules a hearing for March 8, 2022, requiring Juror 50 to testify under oath regarding their answers to specific questions on the juror questionnaire.
DOJ-OGR-00003147.jpg
This is a page from a Government legal filing (Case 1:20-cr-00330-PAE) responding to defense motions regarding discovery. The Government argues that witness statements (Jencks Act material) need not be disclosed immediately, and that a request for an unredacted FBI report is moot because it was already provided in November 2020. A key revelation in the footnotes is that a redacted version of an FBI report submitted by the defense was actually recovered directly from one of Jeffrey Epstein's personal devices during a search warrant execution.
DOJ-OGR-00003047.jpg
This document is page 113 of a legal filing by the Government in the case against Ghislaine Maxwell, dated April 16, 2021. The Government argues that Maxwell lacks standing to challenge the seizure of materials (specifically deposition transcripts) from the law firm Boies Schiller because she had no Fourth Amendment privacy interest in them and voluntarily participated in the deposition. Additionally, the Government asserts that even if she had standing, the evidence should not be suppressed because the Government acted in 'good faith' pursuant to a court order.
DOJ-OGR-00003040.jpg
This document is page 106 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The text details the Government's argument that it did not circumvent the 'Martindell' legal standard when seeking evidence previously under protective orders, specifically referring to a subpoena issued to the law firm Boies Schiller. It notes that Judges McMahon and Netburn ruled that the Government had demonstrated 'extraordinary circumstances' justifying the release of testimony to the grand jury despite previous protective orders.
DOJ-OGR-00003013.jpg
This page is from a legal filing (Document 204) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues that the Defendant failed to prove the Indictment was delayed for an improper purpose. The text discusses the legal standards for pre-indictment delay, citing Supreme Court and Circuit precedents, and rejects the Defendant's request for a 'balancing test' regarding prejudice.
| 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 |
THE GOVERNMENT’S REPLY MEMORANDUM IN FURTHER SUPPORT OF D...
This document is a reply memorandum submitted by the government to argue for the continued detention of Ghislaine Maxwell, citing her as a flight risk.
Regular contact
Counsel was in regular contact with the government following Epstein's arrest.
Dial-in Information
Updated website to include dial-in information provided by the court.
Dial-in information for hearing
On July 9, the government updated its victim services website to include the dial-in information for the hearing provided by the court.
Draft Protective Order
Initial draft of a proposed protective order provided by the government.
Notification
Letter notifications to individuals identifying as victims of Maxwell or Epstein not referenced in indictment.
Scheduling order and right to be heard
By the day after the July 7 court order, the government notified victims and counsel of the scheduling order for the bail hearing and their right to be heard.
Notification to victims not referenced in indictment
On July 8, the government sent letters to self-identified victims of Ghislaine Maxwell or Jeffrey Epstein who were not specifically named in the indictment.
Indictment and hearing information
On the same day the court set the hearing date (July 7), the government posted a link to the indictment and scheduling information on its victim services website.
Victim Services Website Update
Posted link to indictment and scheduling information.
Request to exclude time under the Speedy Trial Act
Referenced as 'Government Letter dated July 5, 2020 (Dkt. 5)' which contained a request that is being renewed and amended in the current letter.
Request for scheduling arraignment
Requested scheduling arraignment, initial appearance, and bail hearing for July 10.
Memorandum in Support of Detention
Government's argument for detaining Maxwell.
Application for detention
Contact regarding the Government's application for detention consistent with CVRA requirements.
Memorandum in Support of Detention
Referenced as 'the Government’s Memorandum in Support of Detention, dated July 2, 2020 (Dkt. 4)' for which a briefing schedule is being proposed.
Indictment and arrest of Ghislaine Maxwell
Announcement of the indictment and arrest.
Motion for detention (Ex.A)
Government moved for detention after arrest.
Arrest of the defendant and initial presentment
The government notified victims and their counsel about the defendant's arrest and the scheduled initial presentment on July 2.
Detention Memorandum
A motion for detention filed by the government on July 2, 2020, referenced as (Dkt. 4).
Arrest Notification
Notification about the fact of the arrest and the initial presentment.
Detention views
Conveyed views regarding the defendant's detention.
Regular contact
Counsel remained in regular contact with the government following Epstein's arrest.
Interview topics
Email with bullet points for the government to interview about
Response to government inquiries
Witness responded to the government through her attorney.
Interview preparation
Email containing bullet points for the government to interview about.
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