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 |
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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