[Redacted] (Assistant United States Attorney)
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
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Documents | Actions |
|---|---|---|---|---|
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person
Judge Nathan
|
Legal representative |
1
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1 | |
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person
Laura Menninger
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Legal representative |
1
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1 | |
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person
[REDACTED] (witness)
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Interrogated by |
1
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1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2021-11-20 | N/A | Email exchange regarding proposed limiting instructions for Judge Nathan. A draft response was sh... | N/A | View |
| 2007-04-24 | N/A | Federal Grand Jury 07-103 testimony regarding 'OPERATION LEAP YEAR' | Federal Building, U.S. Cour... | View |
| 2007-02-27 | N/A | Federal Grand Jury proceeding (07-103) in West Palm Beach, Florida, for 'OPERATION LEAP YEAR'. Te... | West Palm Beach, Florida | View |
United States v. Ghislaine Maxwell -- [Redacted] opens
Announcement regarding the start of the trial, logistical details for the courtroom, and a motivational message about holding Maxwell accountable.
United States v. Ghislaine Maxwell -- [Redacted] opens
Announcement of opening statements for the Ghislaine Maxwell trial, logistical details for the courtroom, and a statement on the importance of the case.
United States v. Ghislaine Maxwell -- [Redacted] opens
Internal announcement regarding the opening of the Ghislaine Maxwell trial, emphasizing the resolve of SDNY prosecutors compared to others (referencing Florida), outlining the charges of sexual exploitation of underage girls, and providing logistical details for attending the trial.
FW: 20cr330, US v. Maxwell
Inquiry regarding the most efficient way to receive a copy of materials (file sharing platform vs thumb drive).
[Redacted] outline
Sender provides an outline for a conversation scheduled for that day. Mentions the recipient is currently in jury selection. Suggests options for reviewing the outline before or after the call.
Maxwell fact witness travel - [REDACTED]
Requesting travel arrangements for a fact witness in the Maxwell trial, anticipating testimony between Dec 1 and Dec 3, with a need to return to [Redacted] by Dec 3.
Daubert motion
Sender distributes a draft Daubert motion (Motion_to_preclude_Dietz_and_Loftus_v4.docx) to the team for comments. Notes that the Dietz section is done and the Loftus section is being revised.
Daubert motion
Circulating Daubert motion for comments; noting Dietz section is done and Loftus section is under revision.
Cover letter
Would you mind taking a quick look at this too?
Citecheck
Requesting a citecheck on an attached brief ('Govt_Reply_v2.docx'). Instructions given to highlight cites where documents are missing.
MIL opps - Daubert
Sender attaches a draft response to a Daubert motion ('Daubert_v3.docx'). Mentions waiting for expert information and planning to send additional motions in tranches over the next few days. Notes this is the most complicated motion.
Draft joint proposed request to charge
Sending draft joint proposed request to charge, due to Court Oct 27. Asking for comments by Oct 24.
Unknown/Blank
Email containing an attachment named '2021.10.05_scheduling_order.pdf'. The body text is minimal, consisting primarily of a signature block.
US v. Maxwell, 20 Cr. 330 (AJN) - discovery production
Notifying counsel of additional discovery production via USAfx and logistics for sending a CD or drive to Ms. Maxwell at MDC.
Maxwell - RTC
Sender attaches a draft RTC (likely Requests to Charge) for the Maxwell case, asking for comments. Mentions a deadline to file a joint proposed RTC on October 27 and plans to send it to the defense a week prior.
Maxwell - RTC
Original email attaching a draft of the RTC in the Maxwell case. Mentions deadline to file joint proposed RTC on Oct 27.
[EXTERNAL EMAIL] - photo project
Checking in on the photo sourcing project and requesting the spreadsheet.
Names for tomorrow
Listing names to be presented to prospective jurors: Ghislaine Maxwell, Jeffrey Epstein, Cora Friedland, Emily Barnes, Rachel Greene, Christina Hake, Kimberly Savino, Jane Heinerth.
disclosure letter (today)
Sender asks recipient to review attached 'Maxwell_Discovery_Letter' and asks a procedural question about omitting a specific female colleague's name from the signature block if she is not reviewing the letters.
CBP Question
Introduction referencing Jared Eannucci and request to connect by phone regarding a case question.
Subpoena to Lockheed Martin
Sending attached subpoena discussed in a previous call. Offering to work together to triage voluminous records if necessary.
Re: U.S. v. Ghislaine Maxwell
Acknowledges Markus as counsel. Notes most referenced entries do not appear redacted. Directs Markus to obtain materials from defense counsel (copied on email). Notes case is governed by protective order ECF No. 36.
GM - Draft Third Bail Opposition
Submitting draft opposition to third bail application for review. Discusses waiting for OIA feedback regarding France and citizenship renunciation.
Working doc
Requesting the working doc to check redactions.
NPA
Submission of the NPA brief draft. Sender admits struggling with the second half of the arguments and requests review.
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