Ms. Moe
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
The Court
|
Legal representative |
19
Very Strong
|
26 | |
|
organization
The government
|
Representative |
17
Very Strong
|
21 | |
|
person
Mr. Everdell
|
Opposing counsel |
15
Very Strong
|
13 | |
|
organization
The government
|
Legal representative |
12
Very Strong
|
8 | |
|
organization
The Court
|
Professional |
11
Very Strong
|
228 | |
|
person
MR. PAGLIUCA
|
Opposing counsel |
11
Very Strong
|
13 | |
|
person
MS. MENNINGER
|
Professional adversarial |
10
Very Strong
|
6 | |
|
person
Mrs. Hesse
|
Professional |
10
Very Strong
|
5 | |
|
person
Ms. Sternheim
|
Professional |
10
Very Strong
|
13 | |
|
person
JANE
|
Professional |
10
Very Strong
|
7 | |
|
person
your Honor
|
Professional |
10
Very Strong
|
7 | |
|
person
Maguire
|
Professional |
10
Very Strong
|
8 | |
|
person
Mr. Everdell
|
Professional |
10
Very Strong
|
28 | |
|
person
the Judge
|
Professional |
10
Very Strong
|
6 | |
|
person
MS. MENNINGER
|
Professional |
10
Very Strong
|
27 | |
|
person
MR. PAGLIUCA
|
Professional |
10
Very Strong
|
11 | |
|
person
Jane
|
Professional |
10
Very Strong
|
10 | |
|
person
MR. COHEN
|
Professional |
10
Very Strong
|
6 | |
|
person
Mr. Everdell
|
Professional adversarial |
10
Very Strong
|
9 | |
|
person
Special Agent Maguire
|
Professional |
10
Very Strong
|
6 | |
|
person
Ms. Sternheim
|
Professional adversarial |
9
Strong
|
5 | |
|
person
Ms. Drescher
|
Professional |
9
Strong
|
4 | |
|
person
MS. MENNINGER
|
Opposing counsel |
9
Strong
|
5 | |
|
person
Ms. Comey
|
Business associate |
8
Strong
|
4 | |
|
person
Mr. McHugh
|
Professional |
8
Strong
|
4 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Court proceeding regarding trial schedule, closing arguments, and jury deliberation timing relati... | Courtroom | View |
| N/A | N/A | Jury Deliberations and Court Response to Note | Courtroom | View |
| N/A | N/A | Legal argument regarding the admissibility of photographic exhibits and the timing of defense obj... | Courtroom | View |
| N/A | N/A | Sentencing Hearing (likely for Ghislaine Maxwell) | Courtroom (Southern District) | View |
| N/A | N/A | Court hearing regarding sentencing enhancements for Ghislaine Maxwell. | Courtroom | View |
| N/A | N/A | Dismissal of Counts Seven and Eight against Ghislaine Maxwell. | Court | View |
| N/A | N/A | Carolyn testified and wrote down her mother's phone number to avoid saying it aloud. | Courtroom | View |
| N/A | N/A | Court hearing regarding sentencing or appeal arguments (Case 22-1426). | Courtroom (likely SDNY) | View |
| N/A | N/A | Examination of Jane | Courtroom | View |
| N/A | N/A | Court hearing regarding upcoming sentencing and review of the presentence report. | Courtroom (Southern District) | View |
| N/A | N/A | Prosecution announces intent to rest case | Courtroom | View |
| N/A | N/A | Sentencing Hearing / Pre-sentencing argument | Southern District of New Yo... | View |
| N/A | N/A | Examination of witness Patrick McHugh | Courtroom | View |
| N/A | N/A | Examination of witness Kelly Maguire | Courtroom | View |
| N/A | N/A | Direct examination of witness Dubin regarding media reports of Epstein's flight logs | Courtroom | View |
| N/A | N/A | Examination of Nicole Hesse | Courtroom | View |
| N/A | N/A | Sentencing Hearing Calculation | Courtroom (Southern District) | View |
| N/A | N/A | Court hearing regarding Maxwell's sentencing or appeal points concerning her role in the conspiracy. | Courtroom (likely SDNY) | View |
| N/A | N/A | Conclusion of Shawn's testimony and calling of Nicole Hesse to the stand. | Courtroom (Southern Distric... | View |
| N/A | N/A | Legal argument regarding the admissibility of Exhibit 52 (a book) to the jury. | Courtroom | View |
| N/A | N/A | Discussion regarding jury deliberation schedule and closing arguments | Courtroom | View |
| N/A | N/A | Direct examination of witness Dubin regarding sexualized massages and relationship timeline. | Courtroom | View |
| N/A | N/A | Legal sidebar regarding cross-examination of witness 'Jane'. | Courtroom | View |
| N/A | N/A | Government meeting with witness Brian | Unknown | View |
| N/A | N/A | Legal argument regarding jury questions and instructions for Count Four. | Courtroom (Southern Distric... | View |
DOJ-OGR-00017709.jpg
This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Jane. The questioning focuses on a discrepancy in her prior statements to the government regarding a trip to New York with Maxwell and Epstein at age 14, specifically about seeing the Broadway show 'The Lion King,' which did not premiere until she was 17. The transcript reveals communications between the government and Jane occurred through her legal representatives, including a Mr. Glassman.
DOJ-OGR-00017705.jpg
This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Jane. The questioning focuses on inconsistencies in her prior statements to the government about a trip to New York with Epstein and Maxwell, specifically a trip to see 'The Lion King'. The witness's attorney, Ms. Moe, objects to the line of questioning, which is overruled by the court.
DOJ-OGR-00017703.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022, recording the cross-examination of a witness named 'Jane'. Defense attorney Ms. Menninger questions Jane about a statement she made to the government regarding being flown to New York by Jeffrey Epstein and Ghislaine Maxwell to see 'The Lion King'. The proceedings are briefly interrupted when a juror suffers a coughing fit, causing a recess.
DOJ-OGR-00017701.jpg
This document is a court transcript of the cross-examination of a witness named Jane. The questioning focuses on inconsistencies in her story, specifically regarding a trip she took to New York with Ghislaine and Epstein at age 14 to see 'The Lion King'. The questioner highlights a discrepancy between her current testimony and what she initially told the government in a meeting in September 2019, particularly concerning whether anything inappropriate occurred on that trip.
DOJ-OGR-00017700.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022, featuring the cross-examination of a witness named 'Jane' by attorney Ms. Menninger. The testimony focuses on clarifying Jane's memory regarding statements made to the FBI and the government in November 2019 and April 2020. Specifically, Jane confirms reporting that she was abused '90 percent of the time' she traveled with Epstein and Maxwell.
DOJ-OGR-00017699.jpg
This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Jane. An attorney questions Jane about incidents in New York involving Ghislaine Maxwell, and despite objections from another attorney, Jane confirms that she did tell the government about at least one such incident.
DOJ-OGR-00017697.jpg
This is a page from the court transcript of the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). Defense attorney Ms. Menninger is cross-examining a witness identified as 'Jane' regarding inconsistencies between her current testimony and notes taken by the government during interviews in September 2019 and February 2020. Jane disputes the accuracy of the government's notes regarding her 'first trip to New York,' stating she was never recorded and the notes are 'out of sequence and incorrect.'
DOJ-OGR-00017696.jpg
This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Jane. The questioning focuses on inconsistencies between her current testimony and prior statements made to the government in 2019 regarding a trip to New York at age 14 where she allegedly met Epstein. Jane denies the accuracy of the statements being presented, and her counsel, Ms. Moe, objects to the line of questioning, with the court sustaining the objection.
DOJ-OGR-00017694.jpg
This document is a page from the court transcript of Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on August 10, 2022. It details a procedural discussion between the Judge and defense attorney Mr. Everdell regarding a juror's question about a 'letter of recommendation' and 'Interlochen applications' contained in evidence binders. Following this discussion, the jury enters, and the court instructs Ms. Menninger to resume her cross-examination of the witness identified as 'Jane'.
DOJ-OGR-00017693.jpg
This document is a page from a court transcript dated August 10, 2022, detailing a dialogue between an attorney, Ms. Moe, and the judge. They discuss a legal point concerning "Rule 408" and a previous motion to quash, after which Ms. Moe raises an issue of "brief anonymity," prompting the judge to call for a sidebar discussion. The transcript is part of the cross-examination of a witness named Jane.
DOJ-OGR-00017692.jpg
This document is a court transcript from August 10, 2022, capturing a legal discussion between a judge and an attorney, Ms. Moe. The conversation centers on the admissibility of evidence for impeaching a witness named Jane, debating whether the issue falls under Rule 408, and emphasizing the necessity of the witness's personal knowledge. The judge also elaborates on the binding nature of Second Circuit precedent on district courts unless overturned by a higher authority.
DOJ-OGR-00017691.jpg
This document is a court transcript from August 10, 2022, capturing a dialogue between an attorney, Ms. Moe, and the judge. They are discussing a complex legal issue regarding an amended rule and a Second Circuit decision on the admissibility of civil litigation settlements in a criminal case. The judge expresses doubt that the rule amendment overrules the binding Second Circuit precedent and asks Ms. Moe, representing the government, to research the issue.
DOJ-OGR-00017690.jpg
This document is a page from the court transcript of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated August 10, 2022. Prosecutors and defense attorneys argue over the admissibility of questions regarding a witness's ('Jane') settlement negotiations, with the defense arguing it proves bias and the prosecution objecting under Rule 408. The Judge intercedes by citing *Manko v. United States*, suggesting that the civil settlement exclusion rule (Rule 408) may not apply in criminal prosecutions.
DOJ-OGR-00017689.jpg
This document is a transcript page from a court proceeding (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) involving a sidebar discussion between the defense (Ms. Menninger), the prosecution (Ms. Moe), and the Judge. The defense argues for the right to cross-examine a witness named 'Jane' regarding her participation in the Epstein Victims' Compensation Program to show bias or financial motivation. Specifically, the defense highlights that Jane was offered $5 million but her lawyer rejected it, filing a motion for reconsideration to demand an 'eight-figure settlement' (at least $10 million).
DOJ-OGR-00017688.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 captures a procedural argument between attorneys Ms. Menninger and Ms. Moe before the Court regarding the cross-examination of a witness named 'Jane.' The dispute centers on whether a letter written by Jane's civil attorney can be used to refresh her recollection without introducing hearsay into the record.
DOJ-OGR-00017686.jpg
This document is a court transcript from August 10, 2022, detailing a legal argument between attorneys and a judge during the cross-examination of a witness named Jane. The core issue is whether questions about a $25 million settlement demand, made by the witness in a civil case, are admissible under Rule 408 to show bias, particularly as the demand was made while a related criminal case against Ms. Maxwell was pending. Attorney Ms. Menninger argues the questions are proper to show bias, while attorney Ms. Moe seeks to limit the scope of the examination.
DOJ-OGR-00017684.jpg
This document is a court transcript from August 10, 2022, detailing a conversation between counsel and the judge during a break in a trial. After the jury is excused for a ten-minute break, counsel Ms. Moe raises two procedural matters with the Court: an ongoing anonymity issue and a Rule 408 issue concerning documents that were just received that morning.
DOJ-OGR-00017682.jpg
This document is a page of a court transcript from August 10, 2022, detailing the cross-examination of a witness named 'Jane'. The questioning focuses on her past interactions with 'Ghislaine' and 'Epstein' and a statement she allegedly made to the government in December 2019. The witness states she does not recall making the statement and is directed to review a document (3509-005) to refresh her memory.
DOJ-OGR-00017681.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It depicts the cross-examination of a witness identified as 'Jane' by defense attorney Ms. Menninger. The questioning focuses on a statement Jane made to the government on February 27, 2020, where she admitted she was 'not sure' if she had ever been alone in a room with just Jeffrey Epstein and Ghislaine Maxwell, contradicting or challenging her current memory.
DOJ-OGR-00017677.jpg
This document is a page from the court transcript of the cross-examination of a witness identified as 'Jane' in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). The defense attorney attempts to impeach the witness's credibility by highlighting inconsistencies between her current testimony, a statement given in December 2019 (where she had no specific memory), and a statement from February 2020 (where she recalled two other girls being present). The witness claims the government's written record of her statement contains a 'typo' or incorrect wording.
DOJ-OGR-00017676.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) documenting the cross-examination of a witness named 'Jane' by attorney Ms. Menninger. The defense attorney questions the consistency of Jane's memory regarding her first encounter with Ghislaine Maxwell, suggesting she fabricated a memory recently that she did not possess in December 2019. The dialogue also references a meeting between Jane and the government in February 2020.
DOJ-OGR-00017673.jpg
This document is a page from a court transcript of the cross-examination of a witness named Jane, filed on August 10, 2022. The questioning focuses on Jane's prior testimony about seeing Ghislaine Maxwell undressed and an alleged incident where she, Epstein, and Maxwell went upstairs to a room. The transcript includes objections from an attorney, Ms. Moe, and rulings from the court.
DOJ-OGR-00017672.jpg
This document is a page from a court transcript of the cross-examination of a witness named "Jane," filed on August 10, 2022. The questioning focuses on the witness's recollections of incidents involving Epstein and Ghislaine, specifically probing her memory of seeing Ghislaine topless by a pool and an occasion where Epstein demanded she follow him upstairs. The witness's ability to recall specific questions from a previous day's testimony by a "Ms. Moe" is also challenged.
DOJ-OGR-00017671.jpg
This document is a page of a court transcript from August 10, 2022, showing the cross-examination of a witness named Jane. The questioning focuses on Jane's prior statements to government agents about Jeffrey Epstein's behavior, specifically whether he controlled where people sat in movie theaters. The transcript includes a legal objection by an attorney, Ms. Moe, which is overruled by the court.
Permissibility of closing arguments
A dialogue between the judge (THE COURT) and an attorney (MS. MOE) regarding whether an argument made by another attorney (Ms. Menninger) in her closing summation crossed the line established by the court's pretrial rulings. The argument in question is whether the government was substituting the defendant, Ms. Maxwell, for Jeffrey Epstein.
Relevance of schoolgirl outfits as evidence
Ms. Moe argues that the evidence is relevant to counter the defense's narrative that the victims were overage and that there was no interest in underage girls. She points to the fact that Jeffrey Epstein had a collection of schoolgirl outfits in the same area as his massage room.
Involvement in accounts/transactions and interactions wit...
Ms. Moe questions Mr. McHugh, who denies personal involvement in the discussed financial transactions and denies ever interacting with Ghislaine Maxwell or Jeffrey Epstein.
Procedure for presenting evidence
Ms. Moe defends the proposal to use a witness to present evidence to avoid awkwardness and questions the objection to showing the jury evidence they haven't seen yet.
Admission of Government Exhibits 925 and 925-R
Ms. Moe offers Government Exhibits 925 and 925-R into evidence, explaining that 925 should be under seal because it contains identifying information for third parties. She then requests to publish the redacted version, 925-R, to the jury.
Admissibility of evidence under the business records exce...
An attorney (presumed to be Ms. Moe) argues that a sequentially numbered book qualifies as a business record and should be admissible. The argument focuses on the timing of record creation, stating that the rule does not require records to be made at the exact moment of an event. The Court and Ms. Moe then have a brief exchange.
Summation in the trial of Ghislaine Maxwell
Ms. Moe argues that the case is about manipulation, money, and memory, reframing the defense's points to argue that Maxwell and Epstein manipulated and exploited young girls from struggling families using their wealth, and that the victims' traumatic memories are central to the case.
Evidence Admissibility
Ms. Moe explains the prosecution's strategy regarding victim interviews (Jane and Kate) to avoid memory contamination. The Court questions the relevance of photos taken in 2019 of 'movable objects' (schoolgirl outfits) to a conspiracy that ended 15 years prior.
Exhibit 52G Review
Requesting jurors review Exhibit 52G, specifically mentioning 'massage, Florida'.
Admission of Government Exhibits 309 and 332
Discussion regarding photographs of witnesses and victims, specifically distinguishing between cropped and full versions of photos.
Admissibility of photographs
Clarifying the scope of the judge's ruling on photographs of the residence interior and requesting time to brief the issue.
Admissibility of evidence regarding age
Discussion regarding a photograph and the age of a specific person to disprove they were an underage personal assistant.
Admissibility of hearsay
Previewing questions regarding the witness's childhood disclosure to a guidance counselor and her mother's reaction.
Review of binders
Requesting opportunity for the government to review binders prepared by Mr. Everdell before they are shown to witnesses or jurors.
Procedure for document review
Clarifying that the government and court will see documents before they are shown, and asking if Ms. Moe wants to see the full binder in advance.
Government Exhibit 935/935R
Ms. Moe questions the witness, Maguire, about the contents and location depicted in a photograph identified as Government Exhibit 935.
Authentication of photograph evidence
Ms. Moe argued that the photographs are authenticated because testimony established they were seized on CDs from Jeffrey Epstein's residence and reviewed by the FBI.
Witness testimony regarding financial stake and anonymity
Ms. Moe questions the witness, Jane, who confirms she has no financial stake in the trial's outcome and has never publicly revealed her identity as a victim of Epstein and Maxwell. Jane explains her desire to remain anonymous is to move on with her life and avoid victim shaming.
Critique of defense expert Professor Loftus and the relia...
Ms. Moe argues that the defense's focus on memory experiments by Professor Loftus is a distraction. She characterizes Loftus as a biased, paid witness whose theories on implanted memories are irrelevant to the powerful, real memories of sexual abuse victims in the case.
Defense's attempt to discredit witness Jane
Ms. Moe argues to the jury that the defense's tactic of calling witnesses named Michelle and Ava was a meaningless 'sideshow' because the victim, Jane, never specifically identified Michelle Healey or Eva Dubin as being present during her abuse. She points to Epstein and Maxwell's contact book as evidence that there were other people with those names in their lives.
Case procedure
Ms. Menninger reports that she and Ms. Moe spoke briefly, assuming that the 'question of gatekeeping' would be addressed before other side issues.
Defense's Procedural Options
Ms. Moe adds that the defense had other methods to put sensitive names on the record, such as writing them on paper, but chose not to.
Pending redaction issues
Ms. Moe informed the court that she had spoken with Ms. Sternheim that morning about the redaction issues being discussed.
Response to defense arguments
Ms. Moe expresses surprise at the defense's arguments.
Objection/clarification on sentencing calculation
Ms. Moe responds to the judge by pointing out that under guideline 3D1.4, 5 units should add 4 levels to the offense score, not 5 as the judge had stated.
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