DOJ-OGR
OrganizationRelationship Network
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Rick Ricarey
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This legal document, part of a court filing from April 16, 2021, argues for the retroactive application of a 2003 amendment to Section 3283, a statute of limitations. It contends that applying the amendment to pre-enactment conduct satisfies the Supreme Court's two-step 'Landgraf' analysis, as it does not impair the rights or increase the liability of the defendant, Maxwell. The document asserts that the amendment merely preserves the status quo rather than attaching new legal consequences.
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This document is page 34 of a legal filing (Document 204) from the Ghislaine Maxwell case (1:20-cr-00330), filed on April 16, 2021. It discusses the legal interpretation of Jeffrey Epstein's Non-Prosecution Agreement (NPA), specifically rejecting the defendant's argument that the NPA binds the entire federal government rather than just the Southern District of Florida. The text quotes the specific NPA section granting immunity to potential co-conspirators, explicitly naming Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova.
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This legal document, part of a court filing from April 16, 2021, presents an argument about the jurisdictional scope of plea agreements. The author refutes a defendant's motion by citing case law, primarily *Annabi*, to argue that a plea agreement only binds the specific U.S. Attorney's Office that made it, unless it explicitly states a broader scope. The document contrasts this with the defendant's argument that without an explicit limitation, an agreement should bind the entire federal government.
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This document is a table of contents for a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It outlines legal arguments against various motions made by the defendant, including challenges to the indictment, requests for disclosure, and the propriety of using a grand jury in White Plains. The filing also addresses the defendant's claim that the grand jury unfairly represented Blacks or Hispanics.
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This document is a page from a message pad containing four message slips. One slip records a phone message for 'JE' from 'Alysia R' at 12 A.M., providing the callback number 917-774-4452. An adjacent, otherwise blank, slip is signed with the date 'S07/26/07', likely indicating the date the message was taken.
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This document contains four telephone message slips from a spiral-bound log book, likely belonging to Jeffrey Epstein (addressed as J.E./JE). The messages date from May 2005 and include calls from 'Eva' asking to be called at home, 'Mrs Maxwell' (Ghislaine Maxwell), 'Danielle' leaving a 646 area code number, and 'Nadia' confirming that an unnamed female 'got there Safe'. The document bears a Department of Justice footer from a 2017 public records request.
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This document contains four phone message slips addressed to Jeffrey Epstein (listed as Mr. Epstein, J.E., or JE) from February 2005. Callers include 'Jon Luc' (likely Jean-Luc Brunel), 'Ms Wexler', 'George Mitchel', and 'Natalie'. The message from Natalie contains significant scheduling information regarding individuals named Pascal, Kiara, and Anya, and includes a crossed-out note stating 'Polish girl is NOT good'.
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This document contains four handwritten phone message slips from January 2005. Three messages are directed to 'J.E' (Jeffrey Epstein) from a caller named 'Alicia' seeking a return call, while one message is for 'Adriana' from a redacted caller confirming an appointment. The document includes Department of Justice file stamps and Public Records Request identifiers.
DOJ-OGR-00032487.jpg
This document is a page from a spiral-bound message book containing four phone messages for 'J.E.' or 'JE' (Jeffrey Epstein). One message is dated November 21, 2004. Notable callers include magician David Copperfield, who left a message stating 'It's important' with a Las Vegas number, and hedge fund manager Glen Dubin. Other callers include Jannie Saunders and 'Darren' (possibly Darren Indyke). The document bears Department of Justice stamps indicating it was released via a public records request.
DOJ-OGR-00032484.jpg
This document contains a page from a spiral-bound message book featuring four phone messages for 'JE' (Jeffrey Epstein). Notable callers include Donald Trump (leaving a 212 area code number), 'Court. Wilde' (likely Courtney Wild), and a redacted caller asking if Epstein wants a female to 'work tomorrow.' One message is dated November 11, 2004.
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This document consists of four phone message slips from a notepad. Three messages are for an individual identified as 'JE' from callers named Amanda, ALINA, and Shantz, with two providing callback numbers. A fourth message, dated January 24, 2003, is for 'GM' from 'Ms Maxwell' with the instruction to 'CALL YOUR MOTHER'. At least two of the messages were taken by a person named Michael.
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This document contains a page from a spiral-bound message book containing four separate phone message slips. Three slips are explicitly addressed to Jeffrey Epstein ('Mr Epstein' or 'JE') from callers identified as 'Tony,' 'Miss Eva,' and 'EVA' between March 2002 and February 2003. A fourth slip captures a message from 'Sam' with a 917 area code phone number and the handwritten note '5.30'.
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This document contains four phone message slips addressed to 'Jeffrey' (presumably Epstein). Three of the slips are filled out with dates in January 2005 (Jan 10 and 11). Two messages are from 'Jean-Luc' and one is from 'Darren', all indicating that the caller had called again. The document bears a footer indicating a Public Records Request from 2017 and a DOJ production number.
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This document contains four scanned 'Important Message' slips from January 9 and 10, 2005. The messages are directed to Jeffrey (Epstein) and one to Jeffrey/Sarah. Callers include Paula, Natalie, Richard, and Sarah, with phone numbers (area codes 917 and 516) recorded for each.
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This document contains four handwritten telephone message slips from a spiral-bound book. Two messages are for Jeffrey Epstein from 'Darren' (one referencing a call from 'Byron') and one is from 'Caroline Ambrious' asking Epstein for work and stating she needs cash. The fourth slip is for 'Sarah' regarding a call from 'Johanna'. The document includes Department of Justice Bates stamping.
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This document consists of four handwritten phone message slips from June 2004 for Jeffrey Epstein. The messages record calls from Ghislaine Maxwell, Francis Ward, and an individual named Tony. The notes, likely taken by an assistant identified as 'R', detail routine communications, including a non-urgent call from Maxwell, a request for a callback from Ward, and notification of an impending visit from Tony.
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This document is a fax cover sheet from Colonial Bank, N.A., dated December 10, 2001. It was sent by an individual named R. Segul to Alfredo Rodriguez, transmitting a 4-page document for review. The specific subject of the fax is not indicated on the cover sheet.
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This document is a court transcript from a sealed case, filed on July 2, 2021. In the transcript, the judge questions a government representative, Mr. Rossmiller, about a procedural issue: why the government has filed a motion for relief from a protective order on behalf of a third party, rather than the third party's own law firm, Boies Schiller, filing it. The judge expresses skepticism about this arrangement and asserts their judicial authority, referencing the Martindell case as applicable precedent.
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This document is an excerpt from a legal opinion (likely the PA Supreme Court ruling in Commonwealth v. Cosby) filed as an exhibit in the Ghislaine Maxwell case (1:20-cr-00330-PAE). The text argues that Bill Cosby's due process rights were violated by D.A. Castor's promise not to prosecute, which compelled Cosby to testify in a civil suit. The court concludes that the only appropriate remedy is to discharge Cosby and bar future prosecution, establishing a legal precedent presumably being used by Maxwell's defense regarding her own non-prosecution agreement arguments.
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This document is page 76 of a legal filing submitted on July 2, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text is an excerpt from the Pennsylvania Supreme Court opinion (J-100-2020) overturning Bill Cosby's conviction, specifically discussing the binding nature of prosecutorial promises and due process. It appears to be submitted by the defense as legal precedent to argue for the enforcement of a non-prosecution agreement (likely the Epstein NPA).
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This is page 57 of a legal filing (Document 310-1) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on July 2, 2021. The text presents legal arguments citing various precedents (including Martinez, Carrillo, and Baird) to establish that non-prosecution agreements should be treated as binding contracts similar to plea agreements. This argument is likely being used to support the defense's claim regarding the applicability of the 2007 Epstein non-prosecution agreement.
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This document is a page from a legal filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on July 2, 2021. While part of the Maxwell/Epstein docket, the text specifically details the sexual assault allegations against Bill Cosby by two women, Heidi Thomas (1984) and Chelan Lasha (1986). This is likely included in the filing as supporting case law or evidence regarding the admissibility of 'prior bad acts' or patterns of grooming and abuse.
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This document is a page from a legal filing in the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE), though the text itself details the legal history of the Bill Cosby non-prosecution agreement (Commonwealth v. Cosby). It describes communications between former DA Bruce Castor and DA Risa Ferman regarding a 2005 agreement where the Commonwealth promised not to prosecute Cosby so that he could not invoke the Fifth Amendment in a civil deposition. This document was likely submitted by Maxwell's defense to argue legal precedent regarding the enforceability of non-prosecution agreements.
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This document appears to be a page from a legal opinion (likely Commonwealth v. Cosby) filed as an exhibit in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It details the narrative of Andrea Constand's sexual assault by Bill Cosby in January 2004, her departure from his residence the following morning, and a subsequent confrontation in March 2004 regarding the pills he gave her.
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This document is a page from a filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330), but the text itself recounts the narrative of the Bill Cosby sexual assault case (Commonwealth v. Cosby, [J-100-2020]). It details the progression of the relationship between Andrea Constand and Bill Cosby, including meetings at Temple University, dinners at Cosby's Cheltenham residence involving unwanted physical contact, and a trip to Foxwoods Casino in late 2003. This document was likely filed in the Maxwell case as legal precedent regarding non-prosecution agreements or evidence of prior bad acts.
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