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-00002295.jpg
This document is the conclusion page of a legal motion filed on January 25, 2021, in the case against Ghislaine Maxwell. The defense argues that the Court should sever the Perjury Counts (Counts 5-6) from the Mann Act Counts (Counts 1-4) pursuant to Federal Rules of Criminal Procedure 8(a) and 14. The defense contends that a joint trial would unfairly prejudice the jury against Maxwell by attacking her credibility regarding 'salacious topics,' potentially causing a conviction on the sex trafficking charges based on character attacks rather than evidence.
DOJ-OGR-00002295(1).jpg
This document is the conclusion page of a legal motion filed on January 25, 2021, in the case against Ghislaine Maxwell. The defense argues that the Court should sever the Perjury Counts (Counts 5-6) from the Mann Act Counts (Counts 1-4) pursuant to Federal Rules of Criminal Procedure 8(a) and 14. The defense contends that a joint trial would unfairly prejudice the jury against Maxwell by attacking her credibility regarding 'salacious topics,' potentially causing a conviction on the sex trafficking charges based on character attacks rather than evidence.
DOJ-OGR-00002241.jpg
Page 9 of a court order filed on December 30, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court rejects the Defendant's renewed motion for bail, maintaining that no conditions of release can assure her appearance in court, despite the Government not proving she poses a danger to the community. The text discusses the weight of evidence, with the defense arguing the case relies too heavily on the uncorroborated recollections of three unidentified accusers.
DOJ-OGR-00002217.jpg
This document is page 11 of a legal filing (Document 103) dated December 23, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues for Maxwell's release on bail, stating she and her spouse have pledged all assets and that her wealth suggests strict conditions rather than denial of bail. It refutes the government's claim that she is a flight risk or adept at hiding, and clarifies financial details regarding her spouse's assets and banking records.
DOJ-OGR-00002215(1).jpg
This document is page 9 of a legal filing (Document 103) from December 23, 2020, in the case against Ghislaine Maxwell. The text argues that Maxwell and her spouse only discussed divorce prior to her arrest to protect him from 'terrible consequences,' not because the relationship was failing, and asserts that the spouse is willing to co-sign her bond. It also defends Maxwell's financial disclosures, stating she has pledged all her and her spouse's assets and that the government has not successfully challenged the accuracy of her financial report.
DOJ-OGR-00002161.jpg
This is the second page of a court order (Document 99) filed on December 18, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). Judge Alison J. Nathan orders the Government to docket redacted documents and exhibits by that same day, ruling that the redactions are narrowly tailored to protect third-party privacy interests. The document cites legal precedents regarding the presumption of access to judicial documents.
DOJ-OGR-00001983.jpg
This is page 5 (filed as page 11 of 45) of a defense motion arguing for Ghislaine Maxwell's release on restrictive bail. The defense argues that the government lacks corroborating documentary evidence, relying instead on old witness testimony, and asserts that Maxwell is suffering under oppressive confinement conditions at the MDC, including isolation and COVID-19 risks. The document also references extradition laws in the UK and France and complaints about discovery failures.
DOJ-OGR-00001960.jpg
This document is page 83 of a court transcript filed on December 10, 2020, regarding the bail determination for Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The court argues that Maxwell poses a significant flight risk due to her awareness of the strong case against her, her substantial international ties, her French citizenship (noting non-extradition policies), and her extraordinary financial resources. The court dismisses her defenses regarding the non-prosecution agreement at this stage of the bail hearing.
DOJ-OGR-00001949.jpg
This document is page 72 of a court transcript from the case U.S. v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on December 10, 2020. The prosecution argues to the Judge that the defendant is a serious flight risk, justifying why they did not offer her the chance to surrender voluntarily. The prosecutor also notes the defendant's lack of candor regarding finances and references separate civil litigation where defense counsel refused to accept service on the defendant's behalf.
DOJ-OGR-00001946.jpg
This is page 69 of a court transcript from Case 1:20-cr-00330-AJN, filed on December 10, 2020. Ghislaine Maxwell's defense attorney is arguing before the judge regarding her continued detention, stating that the government's cited case law regarding COVID-19 risks involves dangerous felons and is not relevant to Maxwell's situation. The attorney emphasizes the impossibility of preparing for trial with only four months of discovery while unable to meet the client in person due to BOP restrictions.
DOJ-OGR-00001780.jpg
This document is page 2 of a court filing (Document 60) in the case of USA v. Ghislaine Maxwell (1:20-cr-00330-AJN), filed on October 6, 2020. It details the specific charges against Maxwell (enticement, conspiracy, transport of minors, perjury) focused on the 1994-1997 timeframe, while discussing the production of discovery materials related to a broader investigation of Epstein's abuse post-1997. The Government argues for the delayed disclosure of specific 'Materials' (approx. 40 photos and 40 pages of documents) to protect the identities of non-testifying victims and to avoid interfering with ongoing investigations.
DOJ-OGR-00022069.jpg
This document is page 7 of a government legal filing (Document 35) from April 24, 2020, in the case against Michael Thomas and Tova Noel (the guards on duty when Jeffrey Epstein died). The prosecution argues against Thomas's motion to compel the production of BOP records and a DOJ-OIG draft report, stating these materials are irrelevant, not in the prosecution's possession, or privileged. The document also restates the facts of the November 19, 2019 indictment charging the defendants with conspiracy and making false records.
DOJ-OGR-00022014.jpg
This document is a page from a court transcript (Case 1:19-cr-00830-AT) filed on February 10, 2020. Defense attorney Mr. Foy argues that the trial should consider the broader 'culture of the institution' and security failures at the MCC, rather than just the specific '14-hour period' alleged by the government. Foy highlights a discovery dispute, noting that of 192 existing videos, only three were provided, and of nine cameras in the SHU, only one was produced which 'shows almost nothing.' The Court orders the trial to begin on June 8.
DOJ-OGR-00021711.jpg
This document is a page from a legal filing (Case 22-1426) discussing the jury selection process (voir dire), specifically addressing how potential jurors with past experiences of sexual abuse were handled. It notes that defense counsel did not strike jurors who disclosed such history but affirmed their impartiality, citing specific examples of disclosures. The text transitions to a specific discussion regarding 'Juror 50' and their questionnaire responses to Judge Nathan.
DOJ-OGR-00021599.jpg
This document is a page from a court transcript (likely the sentencing hearing) for Ms. Maxwell. The judge rejects the defense's claim that Maxwell is indigent, citing her previous report of $22 million in assets and a lack of documentation regarding her marriage or divorce settlement, and states an intention to impose a fine. The judge also notes that the government is not seeking restitution and prepares to discuss sentencing guidelines after a lunch break.
DOJ-OGR-00021543.jpg
This document is Page 19 of a court ruling filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court denies the Defendant's request for pre-hearing discovery, labeling it a 'fishing expedition,' and rules that Juror 50 will be provided a copy of his completed jury questionnaire. The Court also orders that the questionnaire be docketed (unsealed), citing the presumption of public access to judicial documents.
DOJ-OGR-00019588.jpg
This is page 4 of a legal filing from September 24, 2020, in Case 20-3061. Ms. Maxwell's legal counsel requests permission to file several documents under seal, including an unredacted opening brief, Appendix Volume 2 (which is entirely confidential), and a response to the government's opposition. The document notes that the government does not oppose this motion.
DOJ-OGR-00019577.jpg
This is page 4 of a legal filing dated August 24, 2020, addressed to Judge Alison J. Nathan regarding United States v. Ghislaine Maxwell (Case 1:20-cr-00330). Maxwell's defense argues for the ability to provide sealed materials to 'two arbiters' (likely judges in other civil cases) without violating a Protective Order, countering the government's claim that this would harm an ongoing criminal investigation. The document also contains a footnote objecting to the government providing ex parte information about an ongoing grand jury investigation to the judge.
DOJ-OGR-00019540.jpg
This is page 7 of a court order (Document 30, filed July 2, 2020) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The text outlines strict protocols for handling 'Confidential Information,' specifically prohibiting the use of such materials for civil proceedings and restricting the Defendant from possessing hard copies unless in the presence of Defense Counsel. It also establishes that the Bureau of Prisons (BOP) will facilitate electronic access to discovery materials for the defendant.
DOJ-OGR-00019428.jpg
A page from a legal filing (Case 20-3061) dated September 24, 2020. The text argues that the government failed to follow proper procedures to access court-protected documents from a civil case. It highlights Ms. Maxwell's unique position as the only individual involved in all six related judicial proceedings.
DOJ-OGR-00019066.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely US v. Ghislaine Maxwell) featuring the cross-examination of a witness named Rodgers (likely a pilot). The questioning focuses on discrepancies between Rodgers' memory of when he first met 'Jane' (initially estimated as 2000) and flight logs from 1996, 1997, and 1998 which show a passenger with Jane's first name. Rodgers admits he was 'a couple of years off' in his initial statement to the government because he had not yet reviewed his logbooks.
DOJ-OGR-00017127.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) recording the defense summation by Ms. Menninger on August 10, 2022. Menninger argues that a key witness's testimony is inconsistent, specifically highlighting that the witness admitted she does not recall Ghislaine Maxwell touching her, giving her massage instructions, or being present during specific sexual acts with Jeffrey Epstein, contradicting the government's narrative.
DOJ-OGR-00017103.jpg
This document is a page from the defense summation by Ms. Menninger in the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). Menninger argues that the prosecution is attempting to punish Maxwell for Jeffrey Epstein's crimes because he is deceased. She highlights that the government seized nearly 38,000 photographs but only presented a small handful showing Maxwell and Epstein together, questioning what was in the remaining 37,960 photos.
DOJ-OGR-00016388.jpg
This document is a page from the cross-examination of witness A. Farmer (likely Annie Farmer) in the case United States v. Ghislaine Maxwell. The questioning focuses on the timeline of Farmer's legal representation, establishing that she spoke to attorneys in 2016 and retained Boies Schiller (specifically Ms. McCawley) by September 2019. The testimony confirms that these attorneys represented her in a civil lawsuit and filings with the Epstein Victims Compensation Fund.
DOJ-OGR-00009202.jpg
This document is a page from a legal filing (Document 616) in the case of United States v. Ghislaine Maxwell, filed on February 24, 2022. It is a legal argument rebutting the government's opposition to a new trial, specifically addressing standards of juror misconduct, prejudice, and the right to an impartial jury. The text cites various legal precedents including Tanner v. United States and United States v. Ianniello to discuss the balance between investigating juror misconduct and maintaining verdict finality.
| 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 |
Objection to Confidential Designation
Notification that Defense Counsel does not concur with the designation of specific materials as Confidential Information.
Response to March 18, 2021 order
Government's response regarding redactions.
Discovery Materials
Production of documents and materials relevant to the case, including sensitive, confidential, and highly confidential information.
Discovery relevant to motions
Ms. Maxwell asked the government for documents relevant to these motions, but was denied.
Evidence collection
Subpoena issued to a redacted entity which Maxwell seeks to suppress and obtain a copy of.
Literature on grooming and seduction
Dr. Rocchio provided an article by Park Dietz to the government to help explain concepts of grooming and seduction.
Gov. Mem.
Cited as 'Gov. Mem. at 11', containing concessions regarding evidence.
Usage of boots
Witness claims she told the government she wore the boots after 2006.
Gov. Mem.
Cited as 'Gov. Mem. at 11', containing concessions regarding evidence.
Government’s expert notice
Outlines Dr. Rocchio's experience treating hundreds of patients.
Application to detention
Notification that Ms. Maxwell was arrested yesterday.
Reply Brief
Described by Cohen as an effort to 'throw some dirt' on his client.
Preliminary interviews
Two preliminary interviews conducted via video due to COVID-19 constraints.
Explanation of evidence
Government explained its position in a letter regarding the deposition.
Discussions about trips
Witness discussed various conversations and trips with government officials.
Interview Topics
Mr. Scarola suggests ten topics for the interview with Carolyn.
First meeting with Jane
Rodgers stated he recalled meeting Jane around the year 2000, give or take a year or two.
Investigation
Regular contact with the government through counsel.
Reply Brief
Contains allegations trying to make the client look sinister.
Exhibit 52 / Names in books
Argument that names in books linked to people discussed by Jane regarding sexualized massages.
No Subject
Discussion regarding a deposition transcript raised by the government.
Status/Indictment
Maxwell stayed in contact with the government, potentially to stave off indictment.
Witness Brian
Disclosure that the government spoke with witness Brian.
Motions regarding S2 Indictment
Meet and confer to discuss potential additional motions based on the S2 Indictment.
Unknown
Mr. Scarola suggests ten topics for the interview with Carolyn
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