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This legal document is a letter dated February 24, 2022, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter serves as a response to a court order issued the same day, proposing that the defense will make limited redactions to an attached Opinion and Order that was filed under a temporary seal.
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This document is a professional biography and list of publications for Stephen Gillers, the Elihu Root Professor of Law at New York University, dated January 2012. It details his contact information, areas of teaching, prior courses taught, and a list of his major published books and anthologies, including information about his co-authors and publishers. The document appears to be part of a larger legal filing, as indicated by the case numbers in the header.
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The document consists of four handwritten telephone message slips addressed to 'Mr. J.E.' (Jeffrey Epstein) from December 16 and 18, 2004. Callers include a realtor from Sotheby's, Jean-Luc (likely Brunel), Eva, and Natalie. Notably, Natalie's message confirms she spoke with Jean-Luc and that 'everything it's ok,' suggesting coordination between the parties.
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This document contains a page from a phone message log book comprising four individual message slips addressed to Mr. Epstein. The messages are dated August 19 and August 20, 2002. Callers include Melissa Hanes (requesting to change an appointment time from 9:00 to 8:30), a person named Cristal (providing a 646 area code number), and Dr. Anderson (leaving a message noted as '10 MINUTES'). The document includes phone numbers associated with Palm Beach (561) and New York (917, 646). The page is marked as part of a Public Records Request (No. 17-295) released in 2017.
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This legal letter, dated July 2, 2021, from Cohen & Gresser LLP to Judge Alison J. Nathan, cites the recent Pennsylvania Supreme Court decision vacating William Henry Cosby Jr.'s conviction. The letter argues that this precedent supports Ghislaine Maxwell's supplemental motion to dismiss charges, as the government allegedly failed to honor a non-prosecution agreement, similar to the District Attorney's office in the Cosby case. It details the circumstances of the Cosby case, including Andrea Constand's allegations and the initial decision by DA Bruce Castor not to prosecute due to insufficient evidence.
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This document is an email chain from August 12, 2019, where MCC New York Associate Warden Charisma Edge resends four emails to Ray Ormond regarding Jeffrey Epstein's psychological observation. Ormond had previously reported that the attachments were corrupted. The forwarded messages specify the observation took place from July 8 to July 10, 2019, and note that an 'I/M companion' was utilized.
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This is the final page (Conclusion) of a legal motion filed on February 23, 2021, in the case of United States v. Ghislaine Maxwell. Her defense team argues that additional proposed conditions—including renouncing foreign citizenship and asset monitoring—should satisfy the Bail Reform Act. The document lists the defense attorneys representing Maxwell.
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A letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan disputing the government's characterization of Ghislaine Maxwell's confinement conditions at the MDC. The letter details excessive searches, lack of access to discovery materials, and argues that the strict surveillance is a reaction to BOP negligence regarding Jeffrey Epstein.
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This is an email dated August 23, 2019, from a Staff Attorney at the Metropolitan Correctional Center to a Lieutenant. The attorney is following up on the Lieutenant's prior agreement to be interviewed by the Office of Inspector General (OIG) about inmate Epstein (#76318-054). The email provides the phone number of an OIG agent and requests that the Lieutenant call to schedule the interview.
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This is an email chain from July 31, 2019, concerning inmate Jeffrey Epstein (#76318-054). The initial message from a Bureau of Prisons employee clarifies that Epstein does have a cellmate, Reyes (#85993-054). A subsequent follow-up email from a Staff Attorney at the Metropolitan Correctional Center adds a correction that psychology staff, along with medical staff, are responsible for determining if an inmate's suicidal gesture is sincere or for manipulation.
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This document is the cover page for a legal filing in the case of United States of America v. Ghislaine Maxwell, case number 20 Cr. 330 (AJN), in the U.S. District Court for the Southern District of New York. Filed on December 23, 2020, it is a reply memorandum in support of Maxwell's renewed motion for bail. The document lists the names and contact information for her legal team from three different law firms.
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This document is the signature page of a court filing (Document 386) from Case 1:20-cr-00330-PAE, filed on October 29, 2021. It lists the legal counsel representing Ghislaine Maxwell, including attorneys Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim. The document also provides the names and addresses of their respective law firms in Denver and New York.
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This document is the cover page for a legal motion filed on October 29, 2021, in the case of United States of America v. Ghislaine Maxwell in the U.S. District Court for the Southern District of New York. The motion, submitted by Maxwell's legal team, seeks to exclude evidence based on Federal Rule of Evidence 702 and the precedent set by Daubert v. Merrell Dow Pharmaceuticals, and requests a hearing on the matter. The document lists the names and contact information for Maxwell's attorneys from three different law firms.
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This document is a Certificate of Service filed on October 29, 2021, in the case of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). Signed by Nicole Simmons, it certifies that on October 18, 2021, a motion to exclude evidence on behalf of Maxwell was electronically filed and served to four individuals at the U.S. Attorney's Office for the Southern District of New York.
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This document is a Certificate of Service from a legal case, filed on October 29, 2021. It certifies that on October 18, 2021, Nicole Simmons electronically filed a motion on behalf of Ghislaine Maxwell to preclude certain evidence. Notification of this filing was sent to four individuals at the U.S. Attorney's Office for the Southern District of New York (SDNY).
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This document is the cover page for a legal motion filed on October 29, 2021, in the U.S. District Court for the Southern District of New York for the case of United States v. Ghislaine Maxwell. The motion, submitted by Maxwell's legal team, seeks to prevent the prosecution from introducing statements from alleged co-conspirators. This request is framed as a sanction for the prosecution's purported failure to adhere to a court order issued on September 3, 2021.
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This document is a signature page from a court filing (Document 382) in Case 1:20-cr-00330-PAE, filed on October 29, 2021. It lists the legal counsel representing Ghislaine Maxwell, including Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim, along with their respective law firms and contact information. The document is respectfully submitted on behalf of their client, Ghislaine Maxwell.
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This document is the signature page from a legal filing (Document 378) in case 1:20-cr-00330-PAE, dated October 27, 2021. It lists the legal counsel representing Ghislaine Maxwell, including Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim. The document also provides the names and addresses of their respective law firms in Denver and New York.
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This document is the second page of a legal filing (Document 145) in case 1:20-cr-00330-AJN, filed on February 4, 2021. It lists the contact information for the law firms Haddon, Morgan & Foreman P.C. and the Law Offices of Bobbi C. Sternheim, identifying them as the attorneys representing Ghislaine Maxwell.
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This document is page 8 of a Cingular phone bill for account holder Holly Robson, dated February 12, 2005. It details voice usage for the number (561) 308-0282 specifically on February 6th and 7th, 2005. The log shows a high volume of calls to West Palm Beach and Lake Worth numbers, with particularly frequent contact with the numbers (561) 889-7686 and (561) 313-6730, as well as numerous incoming calls.
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This document is an email chain from August 12, 2019, in which MCC New York Associate Warden Charisma Edge responds to Ray Ormond. Edge states she will resend emails concerning Jeffrey Epstein's psychological observation from July 8-10, 2019, because Ormond reported that the original attachment, sent by Lamine N'Diaye, was corrupted and could not be opened.
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This document is an email dated July 23, 2019, from the Chief Psychologist to the Assistant Human Resource Manager at the Metropolitan Correctional Center in New York. The sender forwards an unspecified item and apologizes for a delay, attributing it to being occupied with a 'crazy task'. The names of both individuals are redacted, but their roles and workplace are clearly identified.
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This is an email dated August 12, 2019, from Associate Warden Charisma Edge (sent by Lamine N'Diaye) to Ray Ormond, concerning inmate Jeffrey Epstein (Reg. No. 73618-054). The email summarizes events from late July 2019, stating that an inmate companion monitored Epstein from July 23 to July 24, after which Epstein was transferred to psychological observation until July 30.
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This document is Page 42 of 43 from a court filing (Document 397-1) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on October 29, 2021. It contains a bibliography ('References') listing academic studies and books related to child sexual abuse, grooming, offender psychology, and witness suggestibility. The document bears a Department of Justice footer (DOJ-OGR-00005909), indicating it was part of discovery or an evidence production.
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This document is the cover page for a legal motion filed on October 29, 2021, in the case of United States v. Ghislaine Maxwell in the U.S. District Court for the Southern District of New York. The motion, submitted by Maxwell's legal team, seeks to preclude the introduction of specific government exhibits (251, 288, 294, 313, and 606) in her trial. The document lists the names and contact information for her attorneys from three different law firms.
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