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

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.

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

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.

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

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.

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

Status of Video

From: the government
To: The Court and Defense ...

Informed that MCC staff confirmed video preservation (later found to be incorrect).

Update
2019-12-19

Witness Statement

From: JANE
To: the government

Discussion regarding abuse history; defense claims Jane stated abuse started in NY during this interview.

Interview
2019-12-01

Prior recollection

From: JANE
To: the government

Witness allegedly had 'no specific memory' at this time.

Statement/interview
2019-12-01

Hard Drive Provision

From: Defense counsel
To: the government

Informed Government regarding providing a hard drive for discovery.

Communication
2019-11-22

Unknown

From: JANE
To: the government

A conversation held between the witness and the government.

Conversation
2019-11-01

Unknown

From: Defense counsel
To: the government

Multiple communications.

Communication
2019-10-01

Notice of court proceeding

From: the government
To: ["all known victims"]

The government provided notice to all known victims about the day's court proceeding, either directly or through their counsel.

Notice
2019-09-03

Prior experiences/Trip to New York

From: A. Farmer
To: the government

Witness discussed her age and memories of a trip to New York; referenced in a summary document (3514-006).

Meeting/interview
2019-09-01

Witness Interview

From: A. Farmer
To: the government

Witness met with the government; discussed in the transcript regarding whether she refreshed her memory via a journal beforehand.

Meeting
2019-09-01

No Subject

From: JANE
To: the government

Witness confirms speaking with the government on this date.

Meeting
2019-09-01

First meeting

From: A. Farmer
To: the government

First meeting with government prosecutors, attended by Boies Schiller attorneys.

Meeting
2019-09-01

Witness Interview

From: A. Farmer
To: the government

Witness stated they maintained a journal throughout high school.

Interview
2019-09-01

Ms. Maxwell's financial information

From: the government
To: financial institutions

Government began issuing subpoenas for Ms. Maxwell's financial information.

Subpoena
2019-08-16

Unknown (referenced as 'yesterday's government letter')

From: the government
To: Defense/Court

Likely regarding the discovery of the passport.

Government letter
2019-07-17

Details regarding the defendant's case

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

The Government sent a letter to the Court providing details about allegedly suspicious payments made by the Defendant in 2018, a Palm Beach police report, an expired Austrian passport, and cash and diamonds found in Mr. Epstein's safe.

Letter
2019-07-16

Supplemental information regarding detention hearing (Pol...

From: the government
To: Hon. Richard M. Berman

Submission of unredacted police report and details regarding a foreign passport found in Epstein's safe.

Letter
2019-07-16

Arguments made yesterday

From: the government
To: THE COURT

Government arguments regarding detention.

Meeting/hearing
2019-07-15

Information regarding suspicious payments

From: the government
To: THE COURT

A letter in which the Government informed the Court it had obtained records from a financial institution showing suspicious payments made by Jeffrey Epstein.

Letter
2019-07-12

Views on Bail/Detention

From: Victims and Counsel
To: the government

Victims requested the Government seek detention, citing safety fears and fairness concerns regarding wealthy defendants.

Consultation
2019-07-12

Detention Memorandum

From: the government
To: THE COURT

Informed court of suspicious payments and police report.

Letter
2019-07-12

Request to remand Mr. Epstein

From: the government
To: THE COURT

The Government submitted a letter application requesting the court to deny bail for Mr. Epstein, arguing he poses a danger to the community and could obstruct justice by intimidating witnesses.

Letter application
2019-07-08

Request to remand Mr. Epstein

From: the government
To: THE COURT

The Government submitted a letter application requesting that the Court deny bail for Mr. Epstein, arguing he is a danger to the community and may obstruct justice.

Letter
2019-07-08

Subpoena Service Attempt

From: Defense counsel
To: the government

Defense contacted Gov when FBI attempted to serve subpoena but could not locate defendant.

Contact
2019-07-07

Regarding attempted subpoena service

From: Defense counsel
To: the government

Defense contacted Gov after FBI failed to locate defendant for subpoena service.

Contact
2019-07-07

Subpoena Service Attempt

From: Defense counsel
To: the government

Defense counsel contacted Government when FBI attempted to serve subpoena but could not locate defendant.

Contact
2019-07-07

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