S.D.N.Y.
LocationRelationship Network
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
EFTA00030792.pdf
This document contains an email chain from July 29, 2020, discussing a new court filing in the civil case against Ghislaine Maxwell (1:15-cv-07433-LAP). Sigrid McCawley of Boies Schiller Flexner LLP alerts recipients to a letter filed by Maxwell's attorney, Ty Gee, regarding a reconsideration of a court ruling. The subsequent internal emails react strongly to the filing, with one sender calling the defense 'fucking idiots' and another stating the filing was 'ridiculous' and caused by a failure to communicate effectively.
EFTA00019661.pdf
This document is an email dated August 20, 2019, from Michael Miller of Steptoe & Johnson LLP regarding the case United States v. Jeffrey Epstein. The email discusses serving requests/letters to the SDNY, MCC, and FBI, asking the recipient (likely a government prosecutor) if they will accept service for all entities. The email includes attachments of letters addressed to each of the three organizations.
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This document is a legal opinion or court order concerning pretrial proceedings related to Maxwell. It addresses motions in limine, pretrial disclosures, and scheduling, citing legal precedents like United States v. Thompson and United States v. Percevault. The Court sets a schedule for disclosures and notes that the S2 superseding indictment moots Maxwell's grand jury challenge.
DOJ-OGR-00000135.tif
This document discusses legal arguments made by Maxwell to dismiss an indictment, focusing on the unavailability of witnesses and the impact of pretrial publicity. It references the Palm Beach investigation into Epstein and questions the credibility of potential testimony from Epstein himself, while noting that Maxwell's reputation has shifted from Epstein's friend to a co-conspirator.
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This legal document discusses the denial of Maxwell's motions to dismiss charges related to the sexual abuse of minors, focusing on the application of § 3283. It references the Weingarten v. United States case, which established a 'case-specific approach' for interpreting statutory provisions, and notes that one of the victims is identified as 'Jane'. The document cites several legal precedents, including United States v. Sampson, Weingarten v. United States, United States v. Maxwell, and Taylor v. United States.
DOJ-OGR-00000036.tif
This document outlines the parties and related legal proceedings concerning Ghislaine Maxwell. It identifies Ghislaine Maxwell as the Petitioner, Defendant, and Appellant, with the United States as the Respondent, and references two specific court cases: United States v. Maxwell in the Second Circuit (2024) and United States v. Maxwell in the S.D.N.Y. (2021).
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This legal document, filed on August 11, 2025, details a motion by the Deputy Attorney General to unseal grand jury materials from the Maxwell and Epstein cases. The motion is justified by significant public interest and a directive from the President, following a July 6, 2025, DOJ/FBI memorandum on the Epstein investigation. In response, the court has requested additional information from the government to rule on the motion.
DOJ-OGR-00015107.jpg
This legal document, filed on August 6, 2025, argues for the unsealing of grand jury transcripts related to Epstein and Maxwell's criminal scheme, advocating for the redaction of victims' names while opposing similar protection for third-party enablers. It references a July 6, 2025 Memorandum and several civil cases, asserting that transparency and accountability necessitate the release of information concerning individuals involved in sex trafficking.
DOJ-OGR-00015106.jpg
This document is a legal filing (page 4 of an internal document, page 11 of the court filing) arguing for the unsealing of grand jury transcripts with specific conditions. The filing argues that while victim identities (such as Ms. Farmer) must be redacted to protect their privacy and psychological wellbeing, the Court should not 'rubber stamp' redactions for third-party affiliates of Epstein and Maxwell who have not been charged, suggesting such broad redactions would resemble a cover-up. It cites multiple legal precedents regarding privacy interests in sexual abuse cases, including *Giuffre v. Maxwell* and *Doe 1 v. JP Morgan Chase Bank*.
DOJ-OGR-00015105.jpg
This legal document argues for the unsealing of grand jury transcripts related to the Jeffrey Epstein and Ghislaine Maxwell case, asserting that the extraordinary nature of their crimes and the victims' need for transparency outweigh standard secrecy protocols. It highlights that unsealing is necessary to expose the full scope of the abuse and the network of enablers without forcing victims to expose themselves to retaliation. The filing further contends that living witnesses, specifically the victims, actively support this disclosure rather than opposing it.
DOJ-OGR-00015092.jpg
This legal document discusses precedents for unsealing grand jury testimony of historical significance. It cites the case of David Greenglass, whose testimony in the Rosenberg trial was released after his death, and the case of Alger Hiss, where grand jury transcripts from an espionage investigation were unsealed after fifty years due to public interest.
DOJ-OGR-00015091.jpg
This legal document argues against the release of grand jury transcripts in the pending case of Maxwell. The author contends that secrecy is necessary to protect still-living witnesses, including active law enforcement personnel and alleged victims. The document also refutes the government's cited precedent, the Rosenberg case, arguing it is inapplicable because it involved a decades-old, concluded case, unlike Maxwell's ongoing one.
DOJ-OGR-00015067.jpg
This document is page 6 of a legal filing dated July 29, 2025, in which the Government argues for the unsealing of grand jury transcripts related to the Epstein and Maxwell cases. Citing the 'magnitude and abhorrence of Epstein's crimes' and a July 6, 2025 Memorandum, the Government asserts that public interest warrants disclosure, subject to redactions protecting victims. The document details that the Epstein grand jury met in June/July 2019, and the Maxwell grand jury met in June/July 2020 and March 2021.
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This legal document, page 3 of a court filing from July 18, 2025, argues for the release of grand jury records related to the Jeffrey Epstein case. It cites multiple legal precedents to establish that while grand jury proceedings are traditionally secret, this secrecy is not absolute and can be overridden in 'special circumstances' of significant public and historical interest. The document asserts that the Epstein matter, involving 'the most infamous pedophile in American history,' qualifies as such a circumstance, making the grand jury records 'critical pieces' of national history that should be made public.
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This legal document is a court opinion addressing an appeal by Maxwell, who argues that Counts Three and Four of her indictment are untimely. She contends the offenses do not fall under the extended statute of limitations provided by § 3283 and that a 2003 amendment to the statute cannot be retroactively applied. The court disagrees on both points, affirming the District Court's decision to deny her motion to dismiss and citing precedent from 'Weingarten v. United States'.
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This legal document, filed on December 17, 2021, is a page from a court proceeding in the case against Ms. Maxwell. The judge is providing guidance on the admissibility of evidence, citing the 2013 case 'United States v. Borrero' as precedent. The court will permit the defense to cross-examine government witnesses about their prior statements that did not implicate Ms. Maxwell in order to impeach their credibility.
DOJ-OGR-00008401.jpg
This document is a page from a legal filing, likely a court transcript or motion, dated December 17, 2021. The speaker argues against a defense strategy that challenges the thoroughness of a government investigation, citing multiple legal precedents (e.g., Watson, Gray v. Ercole, United States v. Birbal) to support the principle that the government's choice of investigative techniques is generally irrelevant to the defendant's guilt. The argument distinguishes these cases from another, Bowen v. Maynard, where evidence of an alternative suspect was deemed material.
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This legal document is a page from a court filing, specifically page 5 of 6 from Document 548 in case 1:20-cr-00330-PAE, filed on December 15, 2021. The Court denies the Defense's request for a witness to testify under a pseudonym, arguing that the witness does not qualify as a victim under the Crime Victims' Rights Act because her anticipated testimony is that she was not a target of sexual misconduct by Epstein or Ms. Maxwell. The Court distinguishes this situation from a prior ruling where pseudonyms were allowed to protect the identities of other, actual victims.
DOJ-OGR-00008390.jpg
This legal document, page 4 of a court filing dated December 15, 2021, details the Court's rejection of the Defense's request to allow a witness to testify under a pseudonym. The Court finds the request untimely, notes that other legal tools like a letter rogatory were available to compel testimony, and distinguishes the case from precedents involving undercover officers whose safety or operational effectiveness would be compromised by revealing their identity.
DOJ-OGR-00008368.jpg
This legal document, part of a court case and addressed to Judge Alison J. Nathan, argues that any potential attorney-client privilege regarding statements about a person named Carolyn was waived. The argument posits that because Mr. Scarola disclosed this information to the government, the confidentiality required for privilege was broken. The document cites multiple legal precedents to support the claim that this voluntary disclosure to a third party (the government) results in the forfeiture of the privilege, which is relevant for assessing Carolyn's credibility as she testifies against Ms. Maxwell.
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This legal document, filed on December 9, 2021, addresses the authentication and admissibility of Government Exhibit 52, described as a 'book' or 'household manual' belonging to Epstein and Maxwell. It discusses the defendant's challenge to Alessi's knowledge regarding the exhibit's origins and highlights the manual's contents, which detail practices and relationships between the defendant, Epstein, and other individuals. The document asserts that authentication does not require direct knowledge of creation or seizure, and chain of custody issues pertain to weight rather than admissibility.
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This page from a court filing (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) argues that attorney-client privilege protects communications between a witness named 'Jane' and her attorney 'Glassman.' It asserts that Glassman could not waive this privilege as it belongs to Jane, and distinguishes the situation from the 'Bergonzi' case precedent regarding documents prepared for the Government.
DOJ-OGR-00001864.jpg
This legal document, dated November 25, 2020, is a letter to Judge Alison J. Nathan arguing for the sealing of information related to Ms. Maxwell's bail application. The author contends that the privacy of Ms. Maxwell's sureties (co-signers) and other third parties outweighs the public's right to access, citing fears of harassment and legal precedent from cases like U.S. v. Amodeo and U.S. v. Nejad. The filing requests an in-camera conference to discuss the redaction of the sureties' names and other confidential materials.
DOJ-OGR-00001853.jpg
This document is page 3 of a legal letter to Judge Alison J. Nathan dated November 25, 2020, filed on December 4, 2020. The defense argues against the public identification of Ms. Maxwell's bail sureties (co-signers), citing significant privacy interests and fears of harassment for the sureties and their children. The defense requests an in camera conference and notes that the government consents to sealing the names of cosigners and confidential discovery materials but opposes the conference.
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