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

Production of documents/material

From: the government
To: [REDACTED]

the government served [Redacted] with a subpoena to produce [Redacted]

Subpoena
N/A

Redactions and sealing

From: Defense counsel
To: the government

Government consents to sealing cosigner names and confidential discovery materials but opposes in camera conference.

Consultation
N/A

Concerns about future employment

From: One Minor Victim
To: the government

Expressed substantial concern about risks association with the case will pose to future employment.

Statement/complaint
N/A

Witness testimony

From: the government
To: Defense/Court

Reference to a letter discussing a witness regarding the contact book.

Letter
N/A

Case arguments

From: the government
To: Court

Referenced by the speaker: 'The government said in its opening brief...'

Opening brief
N/A

Discovery Disc

From: the government
To: Ms. Maxwell

Federal Express envelope containing an unreadable discovery disc, delayed by two weeks.

Mail
N/A

Obtaining evidence

From: the government
To: the Recipient

Subpoenas to the Recipient used to obtain evidence for the criminal case.

Subpoena
N/A

Retainer fee

From: JANE
To: the government

Dispute over whether Jane told the government she didn't know she needed a $250,000 retainer.

Statement
N/A

Closing Arguments/Briefs

From: the government
To: Court

Arguments establishing the 'playbook' pattern and conspiracy.

Legal argument
N/A

Modifications for presentation of evidence

From: the government
To: Defense counsel

Agreement to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence.

Meeting
N/A

Expert Witness Notice

From: the government
To: The Court / Defense

Notice proposing Rocchio as an expert witness and outlining expected testimony topics.

Notice
N/A

Providing information

From: Lawyers for witnesses
To: the government

Lawyers provided information to the government; government helped build civil cases/settlements.

Communication
N/A

Usage of boots

From: A. Farmer
To: the government

Witness explained to the government that she did not wear the boots previously, but then did wear them later.

Meeting
N/A

Initial Bail Hearing

From: the government
To: THE COURT

Proffer that testimony would be corroborated by 'significant contemporaneous documentary evidence'.

Transcript
N/A

Gov. Mem. at 11

From: the government
To: Defense/Court

Concessions regarding evidence (specifics redacted).

Legal memorandum
N/A

Exhibits/Redactions

From: MS. MENNINGER
To: the government

Email sent regarding exhibits/redactions.

Email
N/A

Jury Instructions

From: the government
To: The court/jury

[A]t least as to these Mann Act charges, and the jury is going to be instructed here that the relevant illegal sexual activity has to be the violation of the New York offense.

Court transcript
N/A

Eye Mask Policy

From: MDC legal counsel
To: the government

Informed Government that eye masks are contraband and cannot be provided.

Internal communication
N/A

Documents related to Ms. Maxwell

From: the government
To: Unknown Entities

Subpoenas issued for documents related to Maxwell.

Subpoenas
N/A

Conditions of Confinement

From: the government
To: THE COURT

Details on material changes to confinement, access to legal materials, and search frequency

Written status updates
N/A

Missed Flight

From: Kate
To: the government

Witness told the government she missed her flight.

Statement
N/A

Regarding Juror No. 1

From: Unknown
To: the government

A letter received by the government that prompted them to Google the juror.

Letter
N/A

Protective Order/Subpoena

From: the government
To: [REDACTED]

Representations that reassured the recipient to modify a Protective Order.

Legal representations
N/A

Compliance with subpoenas

From: Boies Schiller
To: the government

Stated they would not contest compliance but believed protective orders precluded full compliance

Advisement
N/A

Conferral regarding filing

From: the government
To: Defense counsel

Government sought to confer with defense counsel but received no response.

Attempted conference
N/A

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