Mr. Everdell
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
DAVID RODGERS
|
Professional |
5
|
1 | |
|
person
Unnamed Speaker (Judge)
|
Professional |
5
|
1 | |
|
person
MS. MENNINGER
|
Opposing counsel |
5
|
1 | |
|
person
Juan Alessi
|
Adversarial in court |
5
|
1 | |
|
person
Special Agent Maguire
|
Professional |
5
|
1 | |
|
person
witness 3
|
Professional |
5
|
1 | |
|
person
M. Maxwell
|
Professional |
5
|
1 | |
|
person
Visoski
|
Professional adversarial |
5
|
1 | |
|
person
She (Defendant)
|
Client |
5
|
1 | |
|
person
Mr. Parkinson
|
Professional |
5
|
1 | |
|
person
Mr. Visoski
|
Professional |
5
|
1 | |
|
person
PATRICK McHUGH
|
Professional |
5
|
1 | |
|
person
Kelly Maguire
|
Professional |
5
|
1 | |
|
person
defendant
|
Professional |
5
|
1 | |
|
person
Ms. Comey
|
Adversarial professional |
5
|
1 | |
|
person
Unnamed male
|
Legal representative |
5
|
1 | |
|
person
potential witnesses
|
Legal representative |
5
|
1 | |
|
person
The Juror
|
Legal representative |
5
|
1 | |
|
person
Keith Rooney
|
Legal representative |
5
|
1 | |
|
person
defendant (implied)
|
Legal representative |
5
|
1 | |
|
person
Ms. Sternheim
|
Business associate |
5
|
1 | |
|
person
witness 3
|
Legal representative |
5
|
1 | |
|
person
Ms. Sternheim
|
Co counsel defense |
5
|
1 | |
|
person
Chapell
|
Witness examiner |
5
|
1 | |
|
person
Aznaran
|
Legal representative |
5
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Jury Deliberations and Court Response to Note | Courtroom | View |
| N/A | N/A | Introduction of Government Exhibit 1004 (Stipulation) | Courtroom | View |
| N/A | N/A | Cross Examination of Tracy Chapell | 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 | Court hearing regarding sentencing or appeal arguments (Case 22-1426). | Courtroom (likely SDNY) | View |
| N/A | N/A | Examination of Lawrence Visoski | 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 | Rule 29 Argument | Courtroom | View |
| N/A | N/A | Legal argument regarding jury instructions and a question asked by the jury. | 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 | Cross-examination of witness Dawson regarding a residence and inconsistent statements. | Courtroom | View |
| N/A | N/A | Legal argument regarding supplemental jury instructions | Courtroom | View |
| N/A | N/A | Examination of David Rodgers | Courtroom | View |
| N/A | N/A | Court ruling on the 'attorney witness issue' regarding the defense case-in-chief. | Courtroom | 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 | Admission of Government's Exhibit 296R | Courtroom | View |
| N/A | N/A | Extension of Jury Deliberations | New York City Courtroom | View |
| N/A | N/A | Admission of Defendant's Exhibit MA1 into evidence under seal. | Courtroom | View |
| N/A | N/A | Conference between Defense and Government | Courtroom (implied) | View |
| N/A | N/A | Legal argument regarding jury questions and instructions for Count Four. | Courtroom (Southern Distric... | View |
| N/A | N/A | Trial Resumption | Courtroom (Southern District) | View |
| N/A | N/A | Cross-examination of Michael Dawson | Courtroom | View |
| N/A | N/A | Legal argument regarding jury instructions and admissibility of testimony for conspiracy counts. | Courtroom | View |
DOJ-OGR-00011653.jpg
This document is a page from a court transcript (Case 1:20-cr-00330) filed on August 10, 2022. Defense attorney Mr. Everdell argues that the government's proposed jury instructions are confusing and contrasts them with the defense's position. The argument centers on jurisdiction and the age of consent, specifically regarding 'Accuser 2' and acts committed in New Mexico that were allegedly legal under New Mexico law at the time, versus how they are treated under New York conspiracy law.
DOJ-OGR-00011641.jpg
This document is page 20 of a court transcript filed on August 10, 2022, from Case 1:20-cr-00330-PAE (the Ghislaine Maxwell trial). The text documents a legal argument between attorneys (Mr. Everdell and Ms. Menninger) and the Judge regarding a witness named Kelso. The debate centers on whether Kelso will testify as a fact witness or an expert witness regarding computer forensics and metadata, and whether sufficient disclosure has been made under Federal Rule of Criminal Procedure 16.
DOJ-OGR-00011572.jpg
This document is page 53 of a court transcript from the sentencing of Ghislaine Maxwell (Case 1:20-cr-00330). The Court overrules an objection regarding the inclusion of assets in the Presentence Report (PSR), specifically noting a $10 million bequest from Jeffrey Epstein to Maxwell. The Judge determines that Maxwell has failed to establish an inability to pay a fine, citing the bequest and $3.8 million in assets reported in July 2020.
DOJ-OGR-00011571.jpg
This document is a court transcript from July 22, 2022, detailing a conversation between an attorney, Mr. Everdell, and the court. Mr. Everdell argues that a bequest made to an estate currently in bankruptcy should not be considered a firm asset for the purpose of calculating fines, as the estate has outstanding victims' claims and the bequest itself is likely to be contested. He states it was disclosed on a financial affidavit out of an abundance of caution and good faith.
DOJ-OGR-00011570.jpg
This court transcript from July 22, 2022, details a discussion about victims in a conspiracy, establishing a recruitment chain where the defendant recruited Virginia, who recruited Carolyn, who then recruited Melissa. The court agrees with the government's position on this matter and overrules objections related to Carolyn's prior testimony about her age. The document also notes the defendant's objection to including a $10 million bequest from Epstein in her assets when determining her ability to pay fines.
DOJ-OGR-00011569.jpg
This document is a court transcript from a hearing on July 22, 2022, concerning sentencing guidelines. The attorneys, Mr. Everdell and Ms. Moe, and the Court discuss the calculation of the total offense level, resulting in a guideline range of 188 to 235. Mr. Everdell, while agreeing with the calculation, formally preserves an objection to the government's request to treat two individuals, Virginia and Melissa, as separate offense groups, an issue the Court has previously ruled on.
DOJ-OGR-00011555.jpg
This document is a transcript page from the sentencing hearing of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on July 22, 2022. The Judge is issuing a ruling regarding objections to the Pre-Sentence Report (PSR), specifically noting the defense's argument to use 2003 sentencing guidelines versus 2004 guidelines. The text explicitly mentions that the government's sole objection to the guideline calculation is that Virginia Roberts and Melissa should be formally considered victims.
DOJ-OGR-00011554.jpg
A page from a court transcript filed on July 22, 2022, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). Defense attorney Mr. Everdell argues that sentencing guidelines regarding 'repeat and dangerous sex offenders' should not apply to his client, noting she has not been accused of a crime in over 18 years. The prosecutor, Ms. Moe, declines to respond verbally, resting on previous written briefings.
DOJ-OGR-00011553.jpg
This document is a page from a court transcript dated July 22, 2022, concerning Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The text features arguments between the defense (Mr. Everdell) and the prosecution regarding sentencing enhancements, specifically debating whether Maxwell exercised 'supervisory authority' over an employee named Kellen who scheduled massage appointments. The defense argues that Maxwell's presence in the house while Kellen worked does not constitute supervision, while the prosecution relies on pilot testimony to establish a chain of command.
DOJ-OGR-00011550.jpg
This document is a court transcript from July 22, 2022, detailing arguments in a criminal case. The prosecution, represented by Ms. Moe, asserts that the defendant held a leadership role over Sarah Kellen, citing flight records showing they both traveled on Jeffrey Epstein's private jet during the same period. The defense, represented by Mr. Everdell, begins to challenge the prosecution's legal interpretation regarding the need to prove supervision of another criminal participant.
DOJ-OGR-00011547.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell sentencing) dated July 22, 2022. The defense argues that money transfers for a helicopter and Larry Visoski holding car assets for Epstein do not prove the defendant's continued involvement in the conspiracy. Prosecutor Ms. Moe counters that the financial evidence was offered to refute the claim that the defendant had 'moved on' from her association with Epstein.
DOJ-OGR-00011546.jpg
This document is page 27 of a court transcript from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on July 22, 2022. Defense attorney Mr. Everdell argues against a sentencing enhancement, disputing the reliability of a 'message pad' and arguing that the conspiracy effectively ended in 2004, meaning 2003 guidelines should apply. The defense also contests a government claim that the defendant received $7 million into the 2007 time period.
DOJ-OGR-00011545.jpg
This is page 26 of a court transcript from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on July 22, 2022. Defense attorney Mr. Everdell argues that the conspiracy charge cannot extend to 2005 because the individual named Carolyn was no longer a minor at that time (her birthday being in early January). Everdell also challenges the reliability and admissibility of an undated 'message pad' used as evidence, arguing it cannot be properly authenticated or dated.
DOJ-OGR-00011544.jpg
This document is a court transcript from July 22, 2022, detailing a discussion about the date of a specific message, believed to be from November 2004. An attorney, Ms. Moe, argues that surrounding dates on message pads, flight records, and the defendant's travel with Epstein during that time support this date. The testimony of a crime victim named Carolyn is also cited as evidence of an ongoing conspiracy, which the defendant has the burden to prove withdrawal from.
DOJ-OGR-00011538.jpg
This document is page 19 of a court transcript from a sentencing hearing filed on July 22, 2022, in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). Defense attorney Mr. Everdell argues that the 2003 sentencing guidelines should apply rather than the 2004 guidelines to avoid violating the Ex Post Facto Clause, noting that the Probation Department recommended a downward variance to 240 months despite a calculated range of 292-365 months.
DOJ-OGR-00011537.jpg
This document is a partial transcript from a court hearing on July 22, 2022, discussing factual objections and the calculation of sentencing guidelines. The Court, Mr. Everdell, and Ms. Moe participate in the discussion, with the Court adopting PSR recitations and outlining the process for guideline calculation. The defense contends a guideline calculation of 51 to 63 months' imprisonment, while the government's contention is cut off.
DOJ-OGR-00011535.jpg
This document is page 16 of a court transcript from Case 1:20-cr-00330-PAE (U.S. v. Ghislaine Maxwell), filed on July 22, 2022. The judge is ruling on defense objections to the Presentence Investigation Report. The court overrules objections regarding findings that records from the 2005 Palm Beach search prove Epstein received sexualized massages from minors (2001-2004) and affirms the defendant's responsibility for victimizing additional minors. It also addresses the inclusion of a victim impact statement from a survivor named 'Kate'.
DOJ-OGR-00011529.jpg
This document is a page from a court transcript dated July 22, 2022. In it, the judge makes findings of fact, stating it is probable the defendant paid Carolyn and Virginia for bringing and recruiting other girls. The judge then overrules two objections: one regarding the inclusion of a person named Kate, and another concerning the characterization of the defendant having groomed a person named Jane.
DOJ-OGR-00011526.jpg
This document is a transcript page from a court hearing dated July 22, 2022, involving the sentencing of Ghislaine Maxwell. The Court overrules defense objections regarding factual assertions, specifically crediting testimony that Maxwell targeted Virginia Giuffre at Mar-a-Lago and confirming via bank statements that Epstein transferred approximately $23 million to Maxwell during their conspiracy. The Judge also confirms Maxwell's authorship of a specific essay based on computer metadata linking the file to user 'Ghislaine' and computer 'GMax'.
Sentencing guidelines and Ex Post Facto Clause
Mr. Everdell argues that the jury, not the court, should determine which sentencing guidelines (2003 or 2004) apply, due to implications of the Ex Post Facto Clause.
2007 helicopter purchase and related financial transactions
Mr. Everdell questions Mr. McHugh about a series of financial transactions in June 2007 involving Jeffrey Epstein, Ghislaine Maxwell, Air Ghislaine, and Sikorsky for the purchase of a helicopter.
Volume of evidence from a 2019 search
Mr. Everdell argues that millions of files were taken from Mr. Epstein's residence, but the government has only presented a small portion to the jury, and he wants to establish the total volume.
Presentation of video evidence and order of witnesses
A dialogue in court where Mr. Everdell, Ms. Comey, and the Judge discuss how to show a sensitive video to the jury while protecting privacy, and confirm the upcoming witness schedule.
Witness order
Mr. Everdell requests a preview of the witness order in light of the day's developments.
Proposed edits to legal document language
Mr. Everdell proposes several edits to a document (pages 20 and 21) to the Court. These include omitting the phrase "or foreign" in multiple places, proposing to replace "an individual" with "Jane", and reiterating a previously overruled objection to the word "coerced".
Acknowledgement of court's instructions.
Mr. Everdell confirms to the Court that the instructions are 'Totally clear' and states that the government has been provided with copies of the '3500 material'.
Admission of evidence
Mr. Everdell moves for the admission of Defendant's Trial Exhibit B.
Proposed edits to legal document language
Mr. Everdell proposes several edits to a document (pages 20 and 21) to the Court. These include omitting the phrase "or foreign" in multiple places, proposing to replace "an individual" with "Jane", and reiterating a previously overruled objection to the word "coerced".
Jury Instructions for Ms. Maxwell's case
Mr. Everdell argues for a supplemental jury instruction regarding the relevance of conduct in New Mexico to a conviction under New York law. The Court rejects the proposed instruction, stating it is incorrect and that the defense failed to seek a limiting instruction on the testimony earlier.
Admission of Government Exhibits 925 and 925-R
Mr. Everdell states he has 'No objection' to the government's offer of the exhibits.
Sufficiency of testimony for aiding and abetting charge
Mr. Everdell argues to the court that there is a lack of testimony to support the charge that Ghislaine Maxwell aided and abetted Jeffrey Epstein by enticing 'Jane' to travel to New York, a key element of the substantive count (Count Two).
Admissibility of property ownership records
Mr. Everdell argues for the admission of records showing the O'Neills owned a property until 1997, not Ms. Maxwell, to counter testimony about her residence there.
Request for jury instructions
Mr. Everdell requests that the jury be explicitly instructed that individuals named Kate and Annie were over the age of consent under New York law, and that related testimony should not be considered as evidence of illegal sexual activity. The Court agrees to a separate language change regarding the defendant's name.
Epstein's residences in Palm Beach
Mr. Everdell questions Mr. Rodgers about the location of Epstein's residence at 358 El Brillo Way and a time when Epstein temporarily moved to a rental property during renovations.
Withdrawal of request for a limiting instruction
Mr. Everdell informs the court that after conferring with the government, they are withdrawing their request for a limiting instruction, believing it would be counterproductive ('the cure is worse than the disease').
Redactions in documents
Mr. Everdell agreed with the Court's assessment regarding the permissibility of naming individuals not granted anonymity.
Scope of cross-examination for witness Ms. Espinosa
Mr. Everdell informs the court about an agreement reached with the government to not cross-examine the first witness, Ms. Espinosa, about a civil lawsuit involving Ms. Galindo and Epstein.
Withdrawal of request for a limiting instruction
Mr. Everdell informs the court that after conferring with the government, they are withdrawing their request for a limiting instruction, believing it would be counterproductive ('the cure is worse than the disease').
Redacted evidence and witness stipulation
Mr. Everdell discusses the logistics of preparing redacted versions of evidence (massage room photos) and informs the court that the government and defense have agreed to a testimonial stipulation for witness Sergeant Michael Dawson.
Admissibility of Government Exhibits 250, 251, and 270
Mr. Everdell discusses photographic evidence with the judge. He confirms Exhibit 270 will not be offered, notes the prior exclusion of Exhibit 251 (a photo of a naked toddler), and argues that Exhibit 250, which depicts Jeffrey Epstein with a young girl, should be excluded as irrelevant and prejudicial.
Conscious avoidance jury charge
Mr. Everdell argues that a 'conscious avoidance' charge would invite the jury to convict on an improper basis. The Court responds by asking for a specific response to the argument about the defendant's lack of knowledge.
Cross-examination regarding a photograph
Mr. Everdell questions the witness, Mr. Rodgers, about a photograph (exhibits GX250 and C10), asking if he has seen it before and if he recognizes the person in it. The witness tentatively identifies the person as Eva Dubin.
Border crossing data systems (TECS and APIS)
Mr. Everdell questions the witness, Aznaran, about the definition of 'border crossing' and the mechanisms by which traveler data is entered into government databases. Aznaran explains that international airline manifests are submitted to the Advanced Passenger Information System (APIS), which then links to the TECS system.
Exclusion of evidence (Government Exhibits 288, 270, 296)
Mr. Everdell argues that a portion of a video walk-through (Exhibit 296) should be excluded because it shows a photograph on a wall that the Court has already excluded as a separate piece of evidence (Exhibit 288).
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