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-00008418.jpg
This document is a page from a court transcript filed on December 17, 2021, in the case against Ghislaine Maxwell. The discussion involves the admissibility of evidence regarding 'non-testifying alleged victims' and 'prior statements of Ms. Maxwell' (referred to as government 8). The government attorney, Ms. Moe, mentions producing a large volume of electronically-stored discovery to the defense.
DOJ-OGR-00008415.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on December 17, 2021. It details a legal argument by defense attorney Ms. Menninger, who asserts that if the government introduces evidence (such as message pads) relating to individuals other than the four primary accusers, the defense should be allowed to introduce statements from those individuals claiming Ms. Maxwell was not involved. Prosecutor Ms. Moe agrees to defer the issue until trial, provided the defense does not mention it in their opening statement.
DOJ-OGR-00008413.jpg
This document is a court transcript from a hearing dated December 17, 2021, in the case against Ms. Maxwell. The prosecution, represented by Ms. Moe, is arguing that the defense should be precluded from introducing statements from other alleged victims unless they first formally proffer which witnesses they intend to call. The government contends this is necessary to prevent the introduction of inappropriate hearsay evidence during opening statements or cross-examination.
DOJ-OGR-00008412.jpg
This document is a page from a court transcript filed on December 17, 2021, in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330). The Judge discusses procedural matters regarding background information for the jury and addresses 'No. 6, evidence that goes to consent issues.' Attorneys Ms. Moe (Government) and Christian Everdell (Defense) are present, and the court suggests deferring the consent argument to the discussion of the Rule 412 motion due to overlapping issues.
DOJ-OGR-00008328.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on December 10, 2021. It details a discussion between the prosecution (Ms. Moe), the defense (Mr. Pagliuca), and the Judge regarding the physical inspection of evidence that occurred on November 1st. The Judge instructs the government not to mention specific evidence with uncertain admissibility in their opening statement and transitions the proceedings to discuss the admissibility of co-conspirator statements.
DOJ-OGR-00008327.jpg
This court transcript from case 1:20-cr-00330-PAE, filed on December 10, 2021, documents a pretrial discussion. The judge rules on the process for determining the admissibility of testimony and orders the government to make a document exhibit available for defense inspection, after which the attorneys confirm the inspection already occurred on November 1st and that the original exhibit will be present at trial.
DOJ-OGR-00008326.jpg
This document is a court transcript from December 10, 2021, detailing a discussion about a motion to preclude Government Exhibit 52. The judge denies the motion to preclude before trial, opting to hear witness testimony first. The conversation, primarily between the judge and attorney Ms. Moe, clarifies that a witness will authenticate the exhibit by testifying they saw a very similar, but not necessarily identical, book, without knowing how the specific exhibit came into government possession.
DOJ-OGR-00008321.jpg
This document is page 11 of a court transcript from the Ghislaine Maxwell trial (Case 1:20-cr-00330) dated December 10, 2021. The dialogue is between Ms. Moe (Prosecution) and the Court regarding the logistics of presenting evidence; specifically, they agree that while electronic display is standard, sensitive documents containing identifying information of victims should be provided to jurors in paper binders to prevent them from being seen on public courtroom screens.
DOJ-OGR-00008318.jpg
This court transcript from December 10, 2021, captures a discussion where attorney Ms. Moe informs the court of a potential conflict of interest. Ms. Moe explains that prospective Juror No. 93 is an attorney at the same financial institution where a key trial witness is an executive director, and that this issue has also been flagged for the defense.
DOJ-OGR-00001923.jpg
This document is a page from a court transcript dated December 10, 2020. An attorney argues during a bail hearing, dismissing the government's evidence concerning a threat from a 'Ms. Moe' as irrelevant 'spin' not connected to their client, 'Ms. Maxwell'. The attorney then pivots to the legal standard for pretrial release, quoting statute 3142 to argue for release under the least restrictive conditions.
DOJ-OGR-00001917.jpg
This page of a court transcript captures a hearing in the case against Ghislaine Maxwell. It begins with a quote from a 'Jane Doe' expressing fear of Maxwell's potential to flee or cause harm. Subsequently, Ms. Moe introduces victim Annie Farmer, who addresses the court to describe her abuse by Maxwell starting at age 16.
DOJ-OGR-00001911.jpg
This document is a transcript from a court proceeding filed on December 10, 2020. In it, a speaker identified as Ms. Moe argues that the defendant is a flight risk due to significant financial resources. Ms. Moe cites bank records from January 2019 showing the defendant's annual income is between $200,000 and $500,000, net worth is over $10 million, and that the defendant is the grantor of a trust with over $4 million in assets.
DOJ-OGR-00001910.jpg
This document is page 33 of a court transcript from Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on December 10, 2020. The discussion between the Court and prosecutor Ms. Moe concerns the details of the defendant's arrest, specifically confirming that the defendant ignored law enforcement commands to open the door and retreated to a separate room. The Court also notes an allegation that the defendant attempted to block location monitoring by wrapping a cell phone in foil.
DOJ-OGR-00001899.jpg
This document is a court transcript from a hearing on December 10, 2020, in case 1:20-cr-00330-AJN. The judge rules to set a firm trial date for July 12, 2021, justifying the delay as necessary for discovery and preparation, and finding it serves the ends of justice. The court then prepares to hear arguments regarding the government's motion for the defendant's detention.
DOJ-OGR-00001898.jpg
This document is page 21 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. The proceedings involve Judge Nathan setting a trial date for July 12, 2021, and establishing deadlines for pretrial motions. Prosecutor Ms. Moe requests to exclude time under the Speedy Trial Act to facilitate discovery review, to which the defense (represented by Mr. Cohen) does not object regarding scheduling.
DOJ-OGR-00001888.jpg
This document is page 11 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. In this excerpt, the Defendant (Maxwell) waives the public reading of the indictment and formally enters a plea of 'Not guilty.' The Court then transitions to a scheduling conference and asks prosecutor Ms. Moe for a status update regarding the discovery process.
DOJ-OGR-00001886.jpg
This document is a page from a court transcript filed on December 10, 2020. The judge justifies holding the proceeding with COVID-19 safety restrictions, citing a national emergency and public safety, before turning to the arraignment on an S1 superseding indictment. The judge then begins to question counsel, Ms. Moe, about the specifics of this new indictment compared to the original.
DOJ-OGR-00001881.jpg
Page 4 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell) dated December 10, 2020. The text records the opening of a remote arraignment and bail hearing, with the Judge (The Court) confirming the presence of counsel Ms. Moe, Court Reporter Kristen Carannante, and Pretrial Services Officer Leah Harmon. The Judge notes the proceeding is being held remotely due to the COVID-19 pandemic under the CARES Act.
DOJ-OGR-00001880.jpg
This document is a court transcript from December 10, 2020, for case 1:20-cr-00330-AJN. The judge begins by confirming that the defendant, Ms. Maxwell, and counsel, Mr. Cohen, have a working audio connection. Another individual, Ms. Moe, interrupts to report that the public call-in line is full and proposes an alternative for her colleagues to listen, which the court questions due to concerns about speakerphone feedback.
DOJ-OGR-00001095.jpg
This document is a court transcript from April 1, 2021, detailing the conclusion of a hearing. The judge rules that the government has proven the defendant is a flight risk and orders the defendant to be detained pending trial. The judge then confirms with both defense counsel (Mr. Cohen) and government counsel (Ms. Moe) that there are no further issues before adjourning the court.
DOJ-OGR-00001080.jpg
This court transcript from April 1, 2021, details a discussion between The Court and Ms. Moe, representing the government, regarding the legal relevance of victim statements in a bail analysis. Following a point raised by Mr. Cohen, The Court seeks the government's position. Ms. Moe clarifies that while victims have a right to participate under the Crime Victims Rights Act, their statements are not part of the government's motion, and their substance should not be considered by the court for the bail analysis.
DOJ-OGR-00001079.jpg
This document is a page from a court transcript dated April 1, 2021, from Case 21-770 (United States v. Ghislaine Maxwell). Prosecutor Ms. Moe argues that the defendant poses a flight risk and has failed to meet the burden of production to rebut the presumption of detention, citing recommendations from Pretrial Services and victims' requests. The Judge questions Ms. Moe regarding defense attorney Mr. Cohen's arguments about the government's burden of proof regarding flight risk.
DOJ-OGR-00001075.jpg
This document is a partial court transcript from April 1, 2021, where Ms. Moe, representing the U.S. Attorney's Office for the Southern District of New York, addresses the court. She asserts that the government's presentation of the defendant's conduct, detailed in an indictment returned by a grand jury, consists of undisputed facts and evidence, not 'spin.' Ms. Moe highlights the chilling conduct described in the indictment, involving an adult woman cultivating underage girls for sexual abuse and exploitation by an adult man, and also mentions the defendant's undisputed actions of living in hiding and financial matters.
DOJ-OGR-00001046.jpg
A transcript from an April 2021 court hearing where defense attorney Mr. Cohen argues for the release of his client (implied to be Ghislaine Maxwell) on bail. Cohen cites the Bail Reform Act, the difficulty of preparing a defense during the COVID crisis while in custody, and explicitly argues that his client is 'not Jeffrey Epstein' and is being unfairly portrayed by the government and media as a 'sinister person.'
DOJ-OGR-00001045.jpg
This page of a court transcript records the conclusion of a victim impact statement by Ms. Farmer urging the detention of Ghislaine Maxwell due to flight risk and the severity of her alleged crimes. Following this, the Court confirms with the government representative, Ms. Moe, that there are no other victims wishing to speak and clarifies that the government is not seeking specific findings regarding danger to the community for pretrial detention purposes.
Sentencing Guidelines / Supervisory Role
Ms. Moe argues that trial evidence proves Maxwell supervised Sarah Kellen, satisfying the requirement for an organizer/leader enhancement.
Sentencing recommendation
Requesting an above-guideline sentence to hold the defendant accountable and send a message that no one is above the law.
Scheduling and Sealing
Ms. Moe updates the court that the prosecution anticipates resting their case 'this week' and discusses sealing a document containing pseudonym identities.
Admissibility of Photographs
Discussion regarding whether photographs corroborate a witness's blind description of a residence interior given the time lapse.
Verification of facts
Conferring with the agent involved in breaching the door to verify information.
Cross-examination regarding travel records
Clarifying the start date of travel bookings (1999) and the date range of records in exhibit RS-1 (1999-2006).
Response to Scheduling Concerns
Ms. Moe argues the request is premature but states that if the defense rests the week of the 20th, the jury should be permitted to deliberate.
Jury Instructions
Argument regarding clarification of New York vs New Mexico law in jury charges.
Sentencing arguments
Prosecution opening statement regarding sentencing recommendation for Ghislaine Maxwell.
Post-testimony discussion
Ms. Moe spoke with Jane's attorney following Jane's testimony, reminding him of something.
Discrepancy in conspiracy end date
Ms. Moe states that if the conspiracy end date mentioned by the court (July 2004) differs from the sentencing transcript, they will submit a letter to the Court.
Potential discrepancy in conspiracy end date
Ms. Moe states that if a review of exhibits shows a different date than the sentencing transcript, 'we will submit a letter to the Court'.
Potential discrepancy in conspiracy end date
Ms. Moe states that if a review of exhibits shows a different date than the sentencing transcript, 'we will submit a letter to the Court'.
Duration of a criminal conspiracy
MS. MOE argues to the Court that a conspiracy was still active at the end of 2004, citing Carolyn's testimony about visiting Epstein's house as evidence.
Duration of a criminal conspiracy
MS. MOE argues to the Court that a conspiracy was still active at the end of 2004, citing Carolyn's testimony about visiting Epstein's house as evidence.
Court proceedings
Ms. Menninger reports to the court that "Ms. Moe and I spoke briefly."
Jane's testimony
Ms. Moe spoke with Jane's attorney following Jane's testimony, recalling that she told and reminded him of something (the details are cut off).
Copy of notes
Ms. Moe suggests that during the court break, they will send an email containing a copy of the notes to the judge's chambers.
Discrepancy in conspiracy end date
Ms. Moe states that if the conspiracy end date from the exhibits differs from the sentencing transcript, she will submit a letter to the Court.
Testimony of Special Agent Maguire regarding their FBI ro...
Ms. Moe questions Special Agent Maguire about their employment at the FBI, their assignment to the C20 child exploitation and human trafficking task force, their specific job responsibilities, and their involvement in an FBI operation on July 6, 2019.
Unknown
Ms. Moe refers to a note she made about a conversation with Mr. Glassman, which she argues cannot be an exhibit at trial.
End date of a conspiracy and post-conspiracy evidence
Ms. Moe argues that trial evidence shows a conspiracy continued through 2004 and into 2005. The Court challenges this, suggesting the evidence is for post-conspiracy conduct as it exceeds the date of Carolyn's 18th birthday, a key element of the charge.
Anonymity Order Confirmation
MS. MOE asks the Court to confirm that the anonymity order for the witness Kate, particularly regarding sketch artists, is in effect.
Response to argument
Ms. Moe, when asked to respond to Mr. Everdell's point, declines to offer a verbal rebuttal and states that they rest on their previously submitted briefing on the issue.
Objection to Offense Level Calculation
Ms. Moe objects to the judge's calculation under guideline 3D1.4, stating that 5 units should add 4 levels, not 5.
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