DOJ-OGR
OrganizationRelationship Network
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person
Rick Ricarey
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6
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This document is the first page of a '[Proposed] Protective Order' filed on March 4, 2016, in the civil case of Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York. The order outlines protocols for handling confidential information during discovery, specifically citing the need to protect sensitive personal information relating to victims of sexual abuse. It emphasizes that confidentiality designations should be used sparingly and must be withdrawn if the material no longer qualifies for protection.
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This document is page 6 of a 7-page Protective Order from a legal case (1:15-cv-07433-RWS), filed on March 2, 2016. It outlines the procedures for handling disputed confidential information, including the process for a party to challenge a 'CONFIDENTIAL' designation via a motion to the Court, and the requirements for returning or destroying such materials at the conclusion of the case.
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This document is page 16 (filed page 21 of 23) of a defense motion in the case *United States v. Ghislaine Maxwell* (1:20-cr-00330-AJN), filed on February 4, 2021. The defense argues for an evidentiary hearing to investigate alleged coordination between the government and a redacted third party who provided Maxwell's 2016 civil deposition transcripts to 'stir up a criminal prosecution.' The motion requests the suppression of evidence obtained from this redacted party, specifically the April and July 2016 depositions, and the dismissal of Counts Five and Six.
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This document is page 18 of a court filing (Document 134) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-AJN), filed on February 4, 2021. The text argues that the government/prosecutor engaged in misconduct similar to the 'Chemical Bank' precedent, specifically by misleading the court regarding previous meetings with a firm and encouraging an investigation despite protective orders. The document contains significant redactions regarding the judge's specific comments and rulings.
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This document is page 9 (filed as page 14 of 23) of a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It discusses David Boies' frustration that the government initially failed to pursue perjury charges against Maxwell despite his belief they had her 'dead to rights.' The filing argues that a redacted individual (likely a judge, referred to as 'she') modified a protective order based on misrepresentations made by an Assistant U.S. Attorney. A large portion of the page is redacted.
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This document is the table of contents for a legal filing, specifically Document 124 in case 1:20-cr-00330-AJN, filed on January 25, 2021. It outlines the structure of the parent document, which includes sections for introduction, argument, conclusion, and a certificate of service. A Bates number at the bottom (DOJ-OGR-00002312) suggests it is part of a production from the Department of Justice.
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This document is a Notice of Motion filed on January 25, 2021, in the U.S. District Court for the Southern District of New York (Case 1:20-cr-00330-AJN). In this filing (Pretrial Motion #8), Defendant Ghislaine Maxwell requests the dismissal of either Count One or Count Three of the Superseding Indictment on the grounds that they are multiplicitous.
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This legal document, part of a court filing, discusses the legal arguments concerning the enforceability of an anticipatory waiver of extradition in the case of Ghislaine Maxwell. The text cites various legal precedents, noting that while some defendants have offered such waivers, courts have often not ruled on their enforceability or have deemed them unenforceable, as in the Epstein case where it was called an "empty gesture." The document highlights the significant legal uncertainty surrounding whether a foreign country would enforce such a waiver, making it a contentious point in the defendant's case against extradition to the United States.
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This legal document, page 3 of a court filing from December 30, 2020, outlines the legal standard for pretrial detention. It discusses a defendant's right to bail under the Eighth Amendment and the Bail Reform Act, detailing the conditions under which a court can deny bail. The text explains the rebuttable presumption against release for certain offenses and clarifies the respective burdens of proof for the defendant and the government in such hearings, citing several precedent cases.
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This legal document is a court filing arguing against a defendant's motion for bail reconsideration. The author contends that the defense is improperly relitigating issues already decided and that the precedent cases cited (Esposito, Dreier, Madoff) are factually different from the current case. The document emphasizes the Court's findings that the defendant has 'significant foreign connections' and has shown 'sophistication in hiding those resources and herself' as justifications for continued detention.
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This document is a cover page for 'Exhibit A' from a legal filing. It is identified as page 24 of 30 of Document 97-22 in case 1:20-cr-00330-AJN, filed on December 14, 2020. The page is also marked with the Bates number DOJ-OGR-00002148.
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This page is part of a legal filing (Document 97-21) filed on December 14, 2020, analyzing the likelihood of Ghislaine Maxwell successfully contesting extradition under UK law. The text argues that Maxwell cannot rely on 'passage of time' or 'forum' bars to prevent extradition, citing that while some conduct occurred in London, the majority of harm occurred in the US. It heavily references the Extradition Act 2003 and various legal precedents (Tollman, Gomes, Kakis).
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This document is page 7 (filed as page 8 of 10) of a financial analysis report filed in the case United States v. Ghislaine Maxwell. It details a review of Maxwell's domestic and foreign bank accounts and Limited Liability Corporations (LLCs), noting that many accounts were closed prior to the relevant time period or held immaterial sums. The report mentions Maxwell's spouse in the context of beneficiary status for trusts and LLCs, and concludes that her personal expenditures appear consistent with her reported annual income, though specific entity names are heavily redacted.
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This legal document, filed on behalf of Ms. Maxwell, argues that her pretrial detention conditions at the MDC are excessively punitive and inappropriate. Her counsel asserts these conditions—including de facto solitary confinement and constant surveillance—are an overreaction to Epstein's death, are disproportionate for a non-violent detainee, and are impeding her ability to prepare a defense. The document references multiple unsuccessful attempts by counsel to remedy the situation through communication with the MDC, its legal department, and prosecutors.
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This document is the final signature page (Page 4 of 4) of a legal filing submitted to Judge Alison J. Nathan on November 25, 2020, and filed on December 4, 2020. It is signed by Christian R. Everdell of the law firm Cohen & Gresser LLP, representing the defense in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The page includes the firm's contact information and indicates that all counsel of record were copied via email.
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This is page 3 of a Government legal filing (Case 1:20-cr-00330-AJN) dated October 20, 2020. The Government argues that certain materials requested by the defense are not relevant under Rule 16 because the charges are strictly limited to conduct between 1994 and 1997, and do not allege Maxwell acted as a 'madam' generally. The Government proposes disclosing the disputed materials (approx. 40 pages) eight weeks prior to trial, citing 'United States v. Coppa' to support that immediate disclosure is not required for 'Brady' material.
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This document is a scanned page (129 of 131) from a Department of Justice FOIA release (17-295). It features personalized stationery with 'Jeffrey E. Epstein' printed at the bottom. A handwritten note dated 1996 reads 'for a good time call 635-3454', includes drawings of two hearts, and is signed 'Love Laura'. The page also contains the number '324' at the top left.
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This document is a search result from the online directory 411.com for Richard Figueroa, dated July 26, 2017. It provides a phone number (561-790-5475), indicates that address history is available, and includes a map of the Royal Palm Beach area. The document is marked as page 1 of 3 and bears a public records request number and a DOJ control number.
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This document appears to be a cover sheet or a note from a larger file related to Jeffrey E. Epstein. It contains handwritten numbers "434 2288" and "C07", and is marked with the document identifier "DOJ-OGR-00030589" as part of a Public Records Request.
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This document appears to be a scanned evidence page containing a handwritten note. The note lists a first name, 'Danielle,' and a phone number (646-226-1463). The name 'Jeffrey E. Epstein' is typed below the handwriting. The footer indicates this is page 117 of 131 from a DOJ production dated 07/26/17.
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This document is a scan of a file folder or evidence envelope label. Handwritten notes indicate a 'Trash Pull' was conducted on September 21, 2005, noting that this was the 'Day after Epstein left.' The document includes Department of Justice Bates stamping and public records request metadata from 2017.
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This document is a page from a legal transcript dated July 26, 2017, in which a witness describes visits by young girls to a house. The witness states the girls typically came at night, had dinner, and went to the movies, and that they did not know their names. The witness also clarifies the layout of the property, noting their living quarters were separate and that new guest quarters were built in 2001.
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