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22-1426_Documents.pdf
This document consists of a Docketing Notice from the Second Circuit Court of Appeals dated July 8, 2022, for the appeal of Ghislaine Maxwell (Case 22-1426), and a Notice of Appeal and Criminal Docket from the Southern District of New York (Case 1:20-cr-00330-AJN) filed July 7, 2022. It details Maxwell's conviction and sentencing, including multi-year imprisonment terms and a $750,000 fine for charges related to conspiracy to entice minors for illegal sex acts, transport minors for sexual activity, and sex trafficking, with some counts dismissed or deemed multiplicitous.
20-3061_Documents.pdf
This document is the complete appellate record for case 20-3061, an interlocutory appeal by Ghislaine Maxwell against the United States. Maxwell appealed a District Court order denying her motion to modify a protective order, seeking permission to share confidential criminal discovery materials under seal with the judge in a related civil case (Giuffre v. Maxwell) to challenge the government's acquisition of evidence. The Second Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, ruling that the protective order decision was not a final judgment or an appealable collateral order, and denied Maxwell's motion to consolidate the criminal appeal with the civil appeal.
036.pdf
A legal filing (Sur-Reply) by Ghislaine Maxwell's attorneys arguing that Plaintiff Bradley Edwards must produce solicitation letters sent to former Epstein employees and their responses. The defense argues Edwards waived work-product privilege by failing to produce a privilege log and that the letters sent to third parties do not constitute work product.
033.pdf
This document is a Reply Memorandum filed by attorney Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell. Edwards argues that Maxwell's requests for his communications with 'prospective witnesses' are overbroad, unduly burdensome, and seek protected attorney work-product. The filing notably alleges that Maxwell has failed to explain her presence on 23 flights with a teenaged Virginia Giuffre or the message pads documenting underage girls calling Epstein's mansion for 'massages'.
030.pdf
This document is a Civil Docket Report for Case No. 0:16-mc-61262-JG, filed in the U.S. District Court for the Southern District of Florida on June 13, 2016. The case involves Plaintiff Bradley J. Edwards filing a motion to quash a subpoena against Defendant Ghislaine Maxwell. The docket records various motions, including requests to seal exhibits and appear Pro Hac Vice, culminating in an order on December 22, 2016, to transfer the motion to the Southern District of New York to be handled as part of the case Giuffre v. Maxwell (1:15-cv-07433-RWS). The case was terminated in the Florida court on December 23, 2016.
023.pdf
This document is a formal notice filed on December 16, 2016, in the Southern District of Florida, by attorneys for Ghislaine Maxwell. It informs the court and opposing counsel (specifically Bradley J. Edwards' attorney Jack Scarola) that 'Exhibit B' related to a subpoena status notice has been filed under seal. The underlying case referenced is Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York.
022.pdf
This document is a motion filed on December 16, 2016, by Ghislaine Maxwell's attorneys in the Southern District of Florida. The motion requests permission to file 'Exhibit B' under seal, noting that the exhibit is a sealed order from the Southern District of New York in the underlying 'Giuffre v. Maxwell' case. The document lists legal counsel for Maxwell and for Bradley J. Edwards, who is the subject of a subpoena in this miscellaneous action.
015.pdf
This document is a Motion to Seal filed on July 7, 2016, by attorney Jack Scarola on behalf of Bradley J. Edwards in the U.S. District Court for the Southern District of Florida. Edwards seeks to seal exhibits attached to his Motion to Quash a subpoena, specifically referencing confidential depositions of Ghislaine Maxwell and Rinaldo Rizzo, as well as documents related to Alan Dershowitz, which are already under seal in the Southern District of New York. The motion argues that sealing is necessary to comply with protective orders from the underlying case.
013.pdf
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
010.pdf
Declaration by Jeffrey S. Pagliuca, attorney for Ghislaine Maxwell, filed on June 30, 2016, in the Southern District of Florida. The document lists 18 exhibits (A-R) supporting Maxwell's opposition to Bradley J. Edwards' motion to quash a subpoena. Several exhibits are filed under seal, while others include procedural documents from related cases (Cassell v. Dershowitz, Epstein v. Rothstein, Jane Doe v. US) and communications regarding discovery and subpoenas.
006.pdf
This document is a motion filed on June 29, 2016, by attorneys for Ghislaine Maxwell in the Southern District of Florida. The motion requests permission to file specific exhibits (A, G, H, I, and N) under seal because they were designated as confidential in the underlying case (Giuffre v. Maxwell) in the Southern District of New York. The document includes a certificate of service indicating the motion was served electronically to attorney Jack Scarola representing Bradley J. Edwards.
001-05.pdf
This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.
EFTA00038222.pdf
This document is a chain of emails between Jennifer Clark (Western Union Financial Intelligence Unit) and a redacted FBI agent (NYO DSAC Coordinator). Clark informs the FBI that Western Union's internal investigation team, triggered by open-source news articles, identified activity with a 'Western Union touch' related to the Jeffrey Epstein investigation. Western Union subsequently filed a regulatory report and sought to proactively share this intelligence with the FBI New York office. The emails discuss the logistics of transferring this encrypted report to the appropriate FBI squad.
EFTA00031918.pdf
This document is a Reply Memorandum filed on March 16, 2021, by Ghislaine Maxwell's defense team in support of her third motion for bail. The defense proposes a comprehensive bail package including a $28.5 million bond, asset monitoring by a retired federal judge, and renunciation of her British and French citizenships to mitigate flight risk concerns. Attached as Exhibit A is a legal opinion from French attorney William Julié arguing that if Maxwell renounces her French citizenship, she would no longer be protected from extradition by France, countering the French Ministry of Justice's position.
EFTA00031113.pdf
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 24, 2021, detailing the production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials for individuals the government does not currently intend to call. The letter also clarifies protective order designations for the enclosed documents.
EFTA00030904.pdf
A letter from the U.S. Attorney for the Southern District of New York to Ghislaine Maxwell's defense counsel, Jeffrey Pagliuca, denying a request to use criminal discovery materials in a separate civil lawsuit. The Government cites a Protective Order issued by Judge Alison J. Nathan which restricts the use of such materials solely to the defense of the criminal case to protect an ongoing investigation. The letter suggests counsel use FOIA or Touhy requests if seeking records for civil litigation purposes.
EFTA00030569.pdf
This document is a formal response from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 22 specific discovery requests made on October 13, 2020. The government addresses requests for Epstein's diary, the 'Billionaires Playboy Club' manuscript, flight logs (implied in broader requests but not itemized), and the identities of minor victims, often denying immediate production based on Rule 16 restrictions or asserting that materials have already been produced. The letter also discusses the handling of potential 'Brady' and 'Giglio' materials, stating that impeachment evidence will be produced closer to trial.
EFTA00030069.pdf
This document is an email chain from March 9, 2021, regarding the case U.S. v. Ghislaine Maxwell. Defense attorney Laura Menninger submits a letter to Judge Nathan detailing objections to the government's proposed redactions in an Omnibus Response. Subsequent emails in the chain involve coordination between the defense and the US Attorney's Office (USANYS) regarding the exchange of proposed redactions.
EFTA00029843.pdf
This document is an email chain from March 9, 2021, regarding the legal case U.S. v. Ghislaine Maxwell (20 Cr. 330). Laura Menninger of Haddon, Morgan & Foreman, P.C. writes to Judge Nathan to submit a letter detailing Ms. Maxwell's objections to redactions proposed by the government in their Omnibus Response. The email includes several attachments related to these redactions and exhibits.
EFTA00029601.pdf
This document is the Curriculum Vitae (CV) of a redacted FBI Expert Witness and Computer Forensic Examiner based in the New York Field Office. The subject has been with the FBI since 2005, following careers in programming and environmental health. The CV details extensive training in digital forensics (cell phones, Windows, Mac, Linux), certifications (EnCase, Cellebrite), and a significant history of instructing and speaking at international conferences and training sessions (including in Ghana and Egypt) regarding cyber security and digital investigations up to July 2021.
EFTA00028733.pdf
A discovery production letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated May 20, 2021. The production includes 'Interlochen records' and native 'carved' image files from various electronic devices (identified by codes such as NYC024321) that were previously produced in PDF format. The letter and materials are marked confidential under a Protective Order.
EFTA00027296.pdf
This document is a discovery production letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 4, 2021. It lists produced materials including FBI recovered metadata, Missouri records, a JPMorgan Chase return, and a letter from 1995 related to Oxford. The letter also clarifies new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00027072.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated October 20, 2020, serving as a cover letter for a discovery production. The production includes various materials such as FBI documents from Florida and NY, PBPD materials, and videos, listed with Bates numbers. The letter also addresses the status of data extracted from electronic devices seized from Jeffrey Epstein's properties, noting that privilege reviews are ongoing and that the Epstein Estate has not waived privilege.
EFTA00025287.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense counsel dated October 11, 2021. It details the production of Jencks Act and Giglio materials, notes that audio files from a Palm Beach grand jury testimony are unplayable, and discloses a specific allegation involving 'Minor Victim-4' instructing another to lie to Epstein about their age. The letter extensively lists financial benefits provided to various redacted witnesses by the FBI and USAO, including payments for travel, hotels, meals, and therapy sessions.
EFTA00025206.pdf
This document is an email chain from March 2021 between defense attorneys for Ghislaine Maxwell (Laura Menninger, et al.) and Assistant United States Attorneys for the Southern District of New York. The correspondence concerns scheduling a call to discuss evidence requests and includes the transmission of an index of physical items held in FBI custody by the Miami office. The prosecutor references a previous discovery production from August 2020 and specific Bates ranges for scanned items.
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