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-00005817.jpg
This is page 34 of a legal filing (Document 397) in case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The Government argues against the defendant's motion to exclude certain evidence under Rule 404(b), asserting they provided sufficient notice and Jencks Act materials. The text cites Second Circuit case law to define relevant evidence and justify the admission of uncharged crimes if they are inextricably intertwined with the charged offense.
DOJ-OGR-00005778.jpg
This document is a court filing from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE) dated October 29, 2021, in which the defense objects to specific government exhibits. The defense argues that photographs (Exhibits 251 and 288, description redacted) and a box containing 'Twin Torpedos' (Exhibit 294) seized from Epstein's Palm Beach home in 2005 are irrelevant, prejudicial, and inadmissible under Federal Rules of Evidence.
DOJ-OGR-00002897.jpg
This is page 8 of a court filing (Document 195) in Case 1:20-cr-00330-PAE (US v. Maxwell), filed on April 5, 2021. The Government argues against the defendant's attempt to issue a subpoena to 'BSF' (Boies Schiller Flexner), characterizing it as an improper 'fishing expedition' for victim information and impeachment material that violates the 'Nixon test.' The Government also notes that the defendant failed to file a required response by the April 2, 2021 deadline.
DOJ-OGR-00002711.jpg
This document is page 18 of a legal filing (Document 148) in Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on February 4, 2021. The text constitutes 'Section V. Motion for Accelerated Disclosure of Witness Statements,' where the defense argues they need early access to Jencks Act material to prepare for trial. They cite the age of the allegations (25 years), the lack of electronic records from that era, the location of witnesses in foreign countries, and the logistical difficulties posed by the COVID-19 pandemic as reasons for the request.
DOJ-OGR-00002709.jpg
This document is page 16 of a legal filing (Document 148) in the case United States v. Ghislaine Maxwell, filed on February 4, 2021. It contains legal arguments by the defense requesting the immediate disclosure of 'Brady' and 'Giglio' material (exculpatory and impeachment evidence) from the government. The defense argues that Ms. Maxwell needs this information early to prepare an effective defense, citing various legal precedents (United States v. Rodriguez, Bagley, etc.) to support the claim that impeachment evidence falls under the Brady rule.
DOJ-OGR-00005239.jpg
This is Page 3 of a legal filing (Document 351) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 15, 2021. The Government argues that the Defense's proposed deadline of November 15, 2021, for filing Rule 412 motions (concerning the admissibility of evidence regarding a victim's sexual behavior) is too close to trial, specifically conflicting with jury selection and the Thanksgiving holiday. The Government requests an earlier deadline to ensure victims have sufficient notice and the Court has time to resolve sensitive issues.
DOJ-OGR-00002870.jpg
This page is from a Government court filing (Case 1:20-cr-00330-PAE, US v. Ghislaine Maxwell) dated March 29, 2021. It details the discovery schedule, specifically noting the provision of evidence related to 'Minor Victim-4' and the intent to produce statements from over 250 non-testifying witnesses related to the Epstein investigation by April 12, 2021. It also confirms the trial is scheduled to proceed on July 12, 2021, and discusses potential motions regarding the 'S2 Indictment.'
DOJ-OGR-00008763.jpg
This document is a page from the jury instructions (Instruction No. 40) for the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 19, 2021. It defines the legal concept of 'Venue' within the Southern District of New York and lists the specific counties included in that jurisdiction. The instruction clarifies that the Government must prove venue by a 'preponderance of the evidence' rather than 'beyond a reasonable doubt,' stating that Maxwell must be acquitted of any specific offense if venue is not established for it.
DOJ-OGR-00008745.jpg
This document is page 39 of 83 from a court filing (Document 565) dated December 19, 2021, in the case against Ghislaine Maxwell. It contains specific jury instructions defining the legal standards for 'aiding and abetting,' clarifying that mere presence at a crime scene or knowledge of a crime is insufficient for conviction; the defendant must have willfully sought to help the crime succeed.
DOJ-OGR-00008664.jpg
This document is page 126 of 167 from a court filing (Document 563) in the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on December 18, 2021. It contains jury instructions explaining legal standards for proving a conspiracy, specifically regarding 'Count One, Three, and Five' of the indictment. The text instructs that circumstantial evidence ('actions speak louder than words') can be used to prove a mutual understanding between conspirators beyond a reasonable doubt.
DOJ-OGR-00005841.jpg
This document is page 58 of a legal filing (Document 397) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on October 29, 2021. It details a legal dispute regarding discovery, specifically the defendant's repeated requests for the Government to identify uncharged co-conspirators and their statements. The text outlines a history of motions (Dkt. Nos. 293, 297, 317, 320, 331) where the defense sought this information and the Government's opposition to identifying specific co-conspirator statements within their production.
DOJ-OGR-00002699.jpg
This document is page 6 of a legal filing (Case 1:20-cr-00330-AJN) dated February 4, 2021, filed by Ghislaine Maxwell's defense. The defense argues that despite receiving millions of pages of discovery in November 2020, there is almost no information regarding the specific allegations from the 1994-1997 indictment period. Consequently, the defense requests a 'bill of particulars,' early access to the government's witness list (Jencks Act material), and 404(b) evidence to adequately prepare for trial given the 25-year age of the case and COVID-19 delays.
DOJ-OGR-00017454.jpg
This document is a page from the cross-examination transcript of a witness named Visoski (likely David Visoski, a pilot) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on August 10, 2022. The questioning focuses on pre-trial meetings between Visoski and the government (prosecution), specifically regarding flight log entries. Visoski confirms that the government pointed out specific flights where a female passenger was listed only by a first name, which matched the true first name of a person referred to as 'Jane'.
DOJ-OGR-00014510.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022, featuring the closing summation by defense attorney Ms. Menninger. She attacks the credibility of a witness named 'Jane' by highlighting discrepancies between Jane's testimony about the Palm Beach house layout (specifically the location of the massage room and master bathroom) and the actual floor plans/photos. Menninger argues that Jane's description of a 'light beachy feel' and a separate massage room off the master bath is factually incorrect, asserting the attached room is merely a closet.
DOJ-OGR-00011686.jpg
This document is page 21 of a court transcript from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on August 10, 2022. It contains instructions from the Judge to the jury regarding their conduct, specifically forbidding them from discussing the case with one another or outside parties until deliberations begin. The text explicitly lists various communication technologies and social media platforms (Facebook, Reddit, Twitter, etc.) that jurors are prohibited from using to discuss the trial.
DOJ-OGR-00011573.jpg
This page from a court transcript (case 1:20-cr-00330-PAE) details sentencing proceedings for Ms. Maxwell. The Judge rejects the claim that Maxwell is indigent, citing $22 million in assets reported in 2020 and a lack of documentation regarding her marriage/divorce, and states an intention to impose a fine. The Judge also notes the government is not seeking restitution, finds no grounds for downward departures from sentencing guidelines, and calls for a lunch break.
DOJ-OGR-00011558.jpg
This document is page 39 of a court transcript from the sentencing of Ghislaine Maxwell (Case 1:20-cr-00330). The judge is ruling on which sentencing guidelines apply (2003 vs 2004) based on the timeline of evidence involving 'Epstein's house' and a victim named Carolyn. The judge determines that message pads evidence (including exhibit GX-4B) does not sufficiently prove the offense continued after November 1, 2004, leading to the application of the 2003 guidelines and a discussion of the 4B1.5(b) enhancement for a pattern of prohibited sexual conduct.
DOJ-OGR-00002751.jpg
This document is Page 4 of a court filing (Document 165) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on March 9, 2021. The text is the Government's argument opposing the defendant's third request for bail, citing her extreme flight risk, substantial foreign ties (including citizenship in a non-extradition country), and lack of candor regarding finances. The Government argues that the defendant's offer to renounce citizenship and place assets in monitorship is insufficient to assure her appearance in court.
| 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 |
Investigation evidence
Subpoena issued in connection with the investigation, requiring modification of protective orders for compliance.
Application to modify Rule 26(c) protective orders
Arguments regarding the applicability of the Martindell standard.
Opposition Brief
Gov’t Opp. Br. at 4 - arguing that indicting in White Plains and trying in Manhattan is common practice.
Good-faith witness list
Pagliuca expects to send the government their good-faith witness list tonight.
Notice of resting case
The government warned the defense that they would rest their case.
Docketed letter on the issue
Contains facts the Defendant wishes to convey.
Investigation into Jeffrey Epstein
Request for materials responsive to the investigation.
Age verification
Discussions about whether Jane was 13 or 14 when she met Epstein.
Expected outcome in the case
Statement about the attorney's conversation with Jane regarding her expected outcome.
Unspecified contacts prior to a grand jury subpoena.
The document alleges the government approached prosecutors multiple times before a grand jury subpoena was issued, and that an Assistant U.S. Attorney later omitted mentioning these contacts.
Allegations of sexual massages
Jane told the government about a woman named Sophie and another named Eva, claiming they joined in 'sexual massages'.
Request to delay disclosure of certain materials
The Government conferred with Ghislaine Maxwell's defense counsel to request a delay in disclosing materials related to victims of Jeffrey Epstein. The defense counsel did not consent to the delay.
Rule 404(b) Letter
A letter identifying evidence/witnesses intended for trial, though defense argues it lacked required reasoning.
Jencks Act materials
Detailed notes and reports of the Government’s interviews of the witness referenced in the letter.
Application for modification
Request to modify protective order ex parte.
Logistical arrangements
Government must inform the Court regarding victim notification efforts.
Unknown
Ms. Menninger refers to a potential communication from the witness's attorney to the government, which the witness might deny knowledge of.
Austrian passport
Defense counsel declined to respond when asked by the Government about the seized Austrian passport.
Contact with witness N.F.
The government presented a 'cryptic report' that witness N.F. was allegedly contacted by an unnamed individual about the case, which the Court found to be unsubstantiated.
Contact with witness N.F.
The government presented a 'cryptic report' that witness N.F. was allegedly contacted by an unnamed individual about the case, which the Court found to be unsubstantiated.
Discovery materials for trial preparation
The Government disseminates Discovery to its potential witnesses and their counsel for the sole purpose of preparing for the criminal trial.
Discovery materials for trial preparation
The Government disseminates Discovery to its potential witnesses and their counsel for the sole purpose of preparing for the criminal trial.
Grand jury materials in Maxwell's case
A memorandum from the government which acknowledges that law enforcement and complaining witnesses are still alive, and that some aspects of the grand jury transcript became public during Maxwell's trial.
Grand jury witnesses
A sealed list of witnesses whose accounts were conveyed in the grand jury and a corresponding list of which witnesses testified at trial.
School verification procedures
The transcript references a prior interview between the witness (Kane) and the government, where the witness stated the school may verify student contact information and names.
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