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.
DOJ-OGR-00008964.jpg
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.
DOJ-OGR-00008911.jpg
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.
DOJ-OGR-00019881.jpg
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'.
DOJ-OGR-00017242.jpg
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.
DOJ-OGR-00017236.jpg
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.
DOJ-OGR-00017231.jpg
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.
DOJ-OGR-00013751.jpg
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.
DOJ-OGR-00010661.jpg
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.
DOJ-OGR-00010584.jpg
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.
DOJ-OGR-00010276.jpg
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.
DOJ-OGR-00009565.jpg
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 |
Production of documents/material
the government served [Redacted] with a subpoena to produce [Redacted]
Redactions and sealing
Government consents to sealing cosigner names and confidential discovery materials but opposes in camera conference.
Concerns about future employment
Expressed substantial concern about risks association with the case will pose to future employment.
Witness testimony
Reference to a letter discussing a witness regarding the contact book.
Case arguments
Referenced by the speaker: 'The government said in its opening brief...'
Discovery Disc
Federal Express envelope containing an unreadable discovery disc, delayed by two weeks.
Obtaining evidence
Subpoenas to the Recipient used to obtain evidence for the criminal case.
Retainer fee
Dispute over whether Jane told the government she didn't know she needed a $250,000 retainer.
Closing Arguments/Briefs
Arguments establishing the 'playbook' pattern and conspiracy.
Modifications for presentation of evidence
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.
Expert Witness Notice
Notice proposing Rocchio as an expert witness and outlining expected testimony topics.
Providing information
Lawyers provided information to the government; government helped build civil cases/settlements.
Usage of boots
Witness explained to the government that she did not wear the boots previously, but then did wear them later.
Initial Bail Hearing
Proffer that testimony would be corroborated by 'significant contemporaneous documentary evidence'.
Gov. Mem. at 11
Concessions regarding evidence (specifics redacted).
Exhibits/Redactions
Email sent regarding exhibits/redactions.
Jury Instructions
[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.
Eye Mask Policy
Informed Government that eye masks are contraband and cannot be provided.
Documents related to Ms. Maxwell
Subpoenas issued for documents related to Maxwell.
Conditions of Confinement
Details on material changes to confinement, access to legal materials, and search frequency
Missed Flight
Witness told the government she missed her flight.
Regarding Juror No. 1
A letter received by the government that prompted them to Google the juror.
Protective Order/Subpoena
Representations that reassured the recipient to modify a Protective Order.
Compliance with subpoenas
Stated they would not contest compliance but believed protective orders precluded full compliance
Conferral regarding filing
Government sought to confer with defense counsel but received no response.
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