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EFTA00025035.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding the production of Jencks Act and Giglio materials for potential trial witnesses. The letter clarifies a stamping error in a previous production (October 11, 2021) involving records 3501.507-516 and explains new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00024987.pdf
This document is a discovery production letter dated November 24, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It details the production of confidential records related to JPMC (JPMorgan Chase) and Lockheed Martin, governed by a Protective Order. The letter explains the specific confidentiality markings applied to the produced materials.
EFTA00024791.pdf
A discovery production letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated October 28, 2021. The letter lists produced materials including a scanned contact book page, records from the United Kingdom, and materials from the Estate of Jeffrey Epstein, noting confidentiality designations under a protective order.
EFTA00023360.pdf
This document is a letter dated November 20, 2021, from the U.S. Department of Justice to Ghislaine Maxwell's defense team regarding the production of discovery materials. The government provided Jencks Act and Giglio materials for potential trial witnesses, as well as witness statements for individuals they did not currently intend to call to testify. The letter also clarifies confidentiality designations under a Protective Order.
EFTA00023217.pdf
This document is a letter from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell, dated October 25, 2021. It details the production of discovery materials, including Jencks Act and Giglio materials, for potential trial witnesses and others the government does not currently intend to call. The letter also clarifies a labeling change for confidential documents to avoid confusion with classified materials, replacing 'confidential' stamps with references to the Protective Order.
EFTA00023047.pdf
This document is a 'Notice of Motion' filed on January 25, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The motion seeks to suppress all evidence obtained from a government subpoena to the law firm Boies Schiller and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The document lists the legal counsel representing Maxwell.
EFTA00022960.pdf
This document is a legal filing by Ghislaine Maxwell's defense team objecting to the unsealing of specific docket entries (143, 173, 199, 164, and 230) in the civil case brought by Virginia Giuffre. The defense argues that these documents contain sensitive information regarding non-parties ('Does'), inadmissible hearsay, and prejudicial materials such as flight logs and police reports that were improperly filed to bias the court. The filing emphasizes the need to protect the privacy of non-parties and the integrity of ongoing criminal investigations into Jeffrey Epstein's conduct.
EFTA00021944.pdf
This document is a motion filed by Ghislaine Maxwell's defense team on October 18, 2021, requesting the court to preclude the introduction of Government Exhibits 251, 288, 294, 313, and 606. The defense argues these items—including specific photographs, sex toys ('Twin Torpedos') seized in 2005, and a 'Household Manual'—are irrelevant, lack proper evidentiary foundation, or are unfairly prejudicial under Federal Rules of Evidence 401 and 403. The motion contends that these items do not prove any material fact regarding the charges against Maxwell and serve only to confuse issues or introduce character flaws of Jeffrey Epstein.
EFTA00021902.pdf
This document is a letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's attorney, Jeffrey Pagliuca, denying his request to use discovery materials from her criminal case in a separate civil lawsuit. The Government argues that the materials are related to an ongoing grand jury investigation and are subject to a Protective Order issued by Judge Alison J. Nathan, which explicitly restricts their use to the criminal defense only. The letter suggests that if Pagliuca seeks these records for civil litigation, he must utilize FOIA or a Touhy request.
EFTA00021685.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 12, 2021. It serves as notice that the Government intends to introduce evidence showing Maxwell provided other men with access to women, in addition to her conduct with Epstein. The letter also discloses a redacted witness who worked for Epstein in 2005-2006 and will testify about scheduling sexualized massages with underage girls.
EFTA00021019.pdf
This document is a Notice of Motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell (20 Cr. 330). The defense team, consisting of attorneys from three separate law firms, formally requests a severance and separate trial for Counts Five and Six of the Superseding Indictment. The filing includes the attorneys' contact information and signatures.
EFTA00020815.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated October 13, 2021. It accompanies the production of spreadsheets previously reviewed by the defense at an FBI office in Denver. The letter notes that the original spreadsheets contained embedded hyperlinks to images of 'child exploitation materials,' necessitating the creation of a sanitized version for production.
EFTA00020322.pdf
This document is a chain of emails between Ghislaine Maxwell's defense counsel, Laura Menninger, and the US Attorney's Office (SDNY) regarding the logistics of reviewing physical and electronic evidence. The discussion focuses on arranging a secure location (500 Pearl Street) for Maxwell and her team to review 'highly confidential' materials, including thousands of images seized from Jeffrey Epstein's devices and residences, as well as physical evidence stored in an FBI warehouse. The defense raises concerns about access to laptops, the ability to compare physical and electronic evidence, and the specific handling of sensitive materials.
EFTA00019599.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team responding to a discovery request. The Government declines to produce broad FOIA-related documents citing lack of legal basis under Rule 16, but provides specific materials related to Radar Online and FBI-NY's involvement in the SDFL investigation as a courtesy. The letter also corrects a defense assertion regarding the FBI Florida office's role in the prosecution team.
EFTA00019422.pdf
A discovery letter dated December 16, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter accompanies the production of materials stamped SDNY_GM_00274187 through SDNY_GM_0274302, which are identified in the index as a 'UBS Subpoena Return' dated 12-15-2020. The document notes that the letter and materials are subject to a protective order.
EFTA00019291.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on December 18, 2020, in support of her renewed motion for bail. The defense argues that the government lacks significant documentary evidence, relies solely on witness testimony from decades ago, and that Maxwell has strong ties to the U.S. through her spouse (whose name is redacted) and friends who have pledged assets. The document also addresses flight risk concerns, arguing that extradition from France or the UK is possible or unlikely to be needed due to waivers, and cites a COVID-19 surge at the detention center as further justification for release.
EFTA00018300.pdf
This document is a 72-page Curriculum Vitae for Gail S. Goodman, Ph.D., a Distinguished Professor of Psychology at the University of California, Davis. It details her extensive career (1977-2022) as a researcher and expert in developmental psychology, specifically focusing on child memory, child maltreatment, and eyewitness testimony in legal contexts. The document lists her education, academic positions, millions of dollars in research grants, committee memberships, and a vast list of publications and presentations, establishing her credentials as a leading expert witness in cases involving child sexual abuse and testimony.
EFTA00016206.pdf
This document is a motion in limine filed by Ghislaine Maxwell's defense team on October 18, 2021, seeking to exclude evidence offered by the government under Rule 404(b) due to lack of proper notice. The defense argues the government failed to identify specific evidence or articulate a non-propensity purpose for its admission. The motion references disputed evidence including emails between Maxwell and 'influential men' regarding dates, testimony from a former Epstein employee (2005-06) regarding 'sexualized massages,' and various exhibits including flight logs (GX-661 & 662) and financial statements.
EFTA00016032.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense counsel dated December 18, 2020. The letter corrects Bates stamping errors in prior discovery productions and provides replacement copies of Deutsche Bank materials relating to Jeffrey Epstein and a UBS subpoena return. It confirms ongoing discovery obligations and mentions physical evidence in FBI custody.
EFTA00015823.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 16 evidence discs labeled as 'Epstein Encase Files.' The government identified these discs as containing a forensic image of a computer seized from Epstein's Palm Beach residence in 2005. However, the government concluded that the original warrant authorized seizure but not the search of the computer's contents, and thus they lack the lawful authority to review the files or allow the defense to access them.
EFTA00015303.pdf
This document is a legal memorandum filed on January 25, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The motion seeks to suppress evidence obtained via a grand jury subpoena issued to a third party (name redacted) and to dismiss Counts Five and Six of the indictment. The defense argues that the subpoena violated the Fourth Amendment due to overbreadth and lack of a warrant, violated the 'Martindell' doctrine regarding the sanctity of protective orders in civil litigation, and infringed upon Maxwell's Fifth Amendment rights against self-incrimination regarding her 2016 civil deposition testimony.
EFTA00014496.pdf
This document contains an email chain between a partner at Edwards Pottinger LLC and likely federal authorities (SDNY/FBI) from late 2018/early 2019. The correspondence outlines preparations for a new investigation or prosecution, including requests for victim lists beyond those in the original Non-Prosecution Agreement (NPA). Crucially, it provides a comprehensive list of lawyers who represented Jeffrey Epstein, his pilots, staff, and Ghislaine Maxwell, noting that Bruce Reinhart (now a magistrate judge) represented the pilots and staff.
EFTA00011115.pdf
This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that due to 'tsunami' of negative pretrial publicity surrounding Maxwell and Jeffrey Epstein (including books, podcasts, and documentaries), standard jury selection is insufficient. They request the Court allow individual sequestered voir dire and limited attorney-conducted questioning to identify and remove biased jurors.
EFTA00011096.pdf
This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues for individual sequestered voir dire (jury selection questioning) and permission for attorneys to conduct limited questioning of jurors, citing 'tsunami' levels of negative pretrial publicity and the inflammatory nature of the sexual abuse charges. The motion lists numerous documentaries, podcasts, and books as evidence of prejudicial media coverage that allegedly demonizes Maxwell and links her inextricably to Jeffrey Epstein's crimes.
EFTA00010160.pdf
This document is a letter dated November 16, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It serves as a cover letter for the production of discovery materials, specifically AT&T records, phone records, and photographs, noting that these materials are subject to a protective order.
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