Mr. Everdell
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
The Court
|
Legal representative |
16
Very Strong
|
35 | |
|
person
Ms. Moe
|
Opposing counsel |
15
Very Strong
|
13 | |
|
person
MR. ROHRBACH
|
Opposing counsel |
15
Very Strong
|
14 | |
|
person
Ms. Comey
|
Opposing counsel |
13
Very Strong
|
16 | |
|
person
Ms. Sternheim
|
Co counsel |
13
Very Strong
|
11 | |
|
person
Ms. Maxwell
|
Client |
12
Very Strong
|
12 | |
|
person
GHISLAINE MAXWELL
|
Client |
11
Very Strong
|
7 | |
|
organization
The Court
|
Professional |
11
Very Strong
|
196 | |
|
person
Ms. Comey
|
Professional adversarial |
10
Very Strong
|
5 | |
|
person
Ms. Moe
|
Professional adversarial |
10
Very Strong
|
9 | |
|
person
MR. ROHRBACH
|
Professional |
10
Very Strong
|
22 | |
|
person
Ms. Maxwell
|
Legal representative |
10
Very Strong
|
6 | |
|
person
Ms. Comey
|
Professional |
10
Very Strong
|
38 | |
|
person
Ms. Sternheim
|
Professional |
10
Very Strong
|
6 | |
|
person
Ms. Moe
|
Professional |
10
Very Strong
|
28 | |
|
person
the Judge
|
Professional |
9
Strong
|
5 | |
|
person
MS. POMERANTZ
|
Professional |
9
Strong
|
4 | |
|
person
your Honor
|
Professional |
9
Strong
|
5 | |
|
person
MS. MENNINGER
|
Co counsel |
9
Strong
|
5 | |
|
person
Ms. Chapell
|
Professional |
8
Strong
|
4 | |
|
person
MR. ROHRBACH
|
Professional adversarial |
8
Strong
|
3 | |
|
person
Mr. Visoski
|
Legal representative |
8
Strong
|
3 | |
|
person
Ms. Maxwell
|
Professional |
8
Strong
|
4 | |
|
person
Espinosa
|
Professional |
8
Strong
|
2 | |
|
person
MS. POMERANTZ
|
Opposing counsel |
8
Strong
|
4 |
| 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'.
Jury Instruction 44
Mr. Everdell reads a proposed jury instruction regarding the credibility of witnesses with prior felony convictions.
Admissibility of property records and need for an additio...
Mr. Everdell discusses with the Court newly obtained property records for Stanhope Mews, which he intends to use to impeach a witness's deposition testimony about their residence. He argues that despite the government's objection, additional factual development is needed, possibly requiring another witness, to counter the government's argument.
Timeline of Ms. Maxwell's property ownership and residency
Mr. Everdell explains the complex leasehold title of a property purchased by Ms. Maxwell, stating the deal closed in 1997. He argues this evidence, along with witness testimony from 'Kate', proves Ms. Maxwell did not live at the property before 1996, countering allegations of events in '94 and '95.
Cross-examination regarding employment with Jeffrey Epstein
Mr. Everdell questions Mr. Rodgers about the start date of his employment with Jeffrey Epstein, his hiring of Larry Visoski, their respective roles as chief pilot and co-captain, and a role swap that occurred in late 2004.
Proposed Jury Instruction on 'Dominant Purpose'
Mr. Everdell argues to the Court that a new proposed jury instruction is more accurate because it tracks case law development from the Second Circuit, specifically from Judge Rakoff, as opposed to older language invented by Judge Sand that was not based on circuit case law.
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.
Admission of evidence
Mr. Everdell moves for the admission of Defendant's Trial Exhibit B.
Admissibility of Evidence
Argument regarding Government Exhibits 919, 920, and 53, specifically requesting they not be described as 'schoolgirl outfits' to the jury.
Jury Instructions
Argument regarding the elimination of a jury charge concerning investigative techniques.
Age of allegations and lack of evidence
Everdell argues that highlighting the 25-year age of the allegations is fair because records get destroyed over time, explaining the absence of corroborating evidence like geo-location data.
Exhibit 913 Privacy
Requesting privacy interests for photos on a desk.
Procedural point on cross-examination
Everdell raises a concern about the government referring to passengers as 'and others' without naming them during direct examination.
Issue with fourth witness
Mr. Everdell informs the court of a small issue regarding the fourth witness (Mr. Rogers) and requests time to confer with the government.
Scheduling of Defense Case
Discussion regarding the timeline for the defense to present their case and the scheduling of the charging conference.
Jury Instructions / Technical Issues
Discussion regarding the definition of 'entice' and citations of case law.
Jury Instructions/Verdict Sheet Language
Discussion regarding the phrasing of Counts Two, Three, Four, and Six, specifically regarding the age of victims and the name 'Jane'.
Cross Examination
Questioning regarding whether the witness saw any inappropriate activity during 30 years of employment.
Cross-examination
Questioning regarding FedEx invoices and their maintenance in the regular course of business.
TECS Reports
Confirmation that Aznaran ran three traveler reports in the TECS system for Jane, Kate, and Annie Farmer.
Cross-examination regarding Government Exhibits 234 and 245
Discussion regarding photos of Epstein's desk and bookcase.
Juror Exhibits
Request to put folders with exhibits under jurors' chairs.
Trial Logistics
Discussion regarding the handling of paper evidence binders and maintaining witness anonymity during cross-examination.
Admissibility of Evidence
Argument regarding the admissibility of property ownership records to impeach witness testimony.
Calling next witness
Everdell calls Raghu Sud to the stand.
Objection to scope of questioning
Argument regarding the relevance of Maxwell's father's death and her housing history.
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