DOJ

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Also known as:
Justice Department (DOJ) DOJ Redaction DOJ (referenced in footer stamp) Office (referring to SDNY or main DOJ office) FBI / DOJ DOJ (implied by USANYS) US Government / DOJ US DOJ DOJ (implied via FOIA context) The Brass (DOJ/US Attorney Leadership) DOJ (Department of Justice - inferred from footer stamp) Public Integrity Section (DOJ) TD-DOJ

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Event Timeline

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Date Event Type Description Location Actions
2019-01-01 N/A Justice Department launched probe into prosecutor misconduct Washington D.C. View

DOJ-OGR-00009294.jpg

This document is page A-5690 of an index for a court transcript from the case United States of America v. Paul M. Daugerdas, et al. (Case 1:20-cr-00330-PAEum), dated February 15, 2012. The index, prepared by Southern District Reporters, covers terms from 'petition' to 'product' and provides their page and line number locations within the full transcript. The document carries a Department of Justice Bates number DOJ-OGR-00009294.

Legal document index
2025-11-20

DOJ-OGR-00009284.jpg

This document is a word index (concordance) page from a court transcript dated February 15, 2012, for the case 'United States of America v. Paul M. Daugerdas, et al.' It lists words alphabetically from 'duty' to 'experience' (including 'Edelstein', 'email', 'evidence', 'Exhibit') alongside their corresponding page and line numbers in the full transcript. The document was filed as Exhibit A-5680 in the Ghislaine Maxwell case (Case 1:20-cr-00330) on February 24, 2022.

Court transcript index / concordance
2025-11-20

DOJ-OGR-00009279.jpg

This document is a word index (concordance) page from a court transcript dated February 15, 2012, for the case 'United States v. Paul M. Daugerdas'. It was filed as Exhibit A-5675 in the 'United States v. Ghislaine Maxwell' case (Case 1:20-cr-00330-PAE) on February 24, 2022. The index lists names and terms appearing in the transcript, including significant mentions of 'Benhamou' (38 times), 'Brune' (48 times), 'Bronx' (43 times), and 'Bronxville' (47 times), along with their specific page and line citations.

Court transcript index / concordance
2025-11-20

DOJ-OGR-00009277.jpg

This document is a single page from a court transcript index (concordance) for the case 'United States of America v. Paul M. Daugerdas, et al.', dated February 15, 2012. It lists words alphabetically (from 'abide' to 'Allen') alongside their frequency of use and page:line citations within the transcript. While the header indicates a filing date of 08/24/22 (associated with case 1:20-cv-00380-PAE, likely related to Ghislaine Maxwell/Epstein civil litigation), the content itself is a standard legal index from the Daugerdas tax fraud trial, likely included in the production as an exhibit or related file.

Court transcript index / concordance
2025-11-20

DOJ-OGR-00009276.jpg

This document is a concordance or index page from a court transcript dated February 15, 2012, for the case United States v. Paul M. Daugerdas. It lists occurrences of specific terms (mostly dollar amounts, numbers, and dates) alongside their corresponding page and line numbers in the full transcript. The document was subsequently filed on February 24, 2022, as Exhibit A-5672 in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE).

Court transcript index / trial exhibit
2025-11-20

DOJ-OGR-00003282.jpg

This page from a DOJ OPR report details the specific negotiations regarding Jeffrey Epstein's Non-Prosecution Agreement (NPA). It highlights the inclusion of the controversial clause granting immunity to 'any potential co-conspirator,' which AUSA Villafaña added and DOJ official Lourie failed to reject, despite Lourie explicitly rejecting a separate request for an immigration waiver. The document also records Lourie's later admission to OPR that the broad non-prosecution agreement likely stemmed from U.S. Attorney Acosta's reluctance to charge Epstein at all.

Doj office of professional responsibility (opr) report
2025-11-20

DOJ-OGR-00003257.jpg

This document details the plea negotiations between Jeffrey Epstein's defense team and the U.S. Attorney's Office (USAO) in early August 2007. On August 2, Epstein's lawyer, Sanchez, proposed a sentence of home confinement and restitution, arguing a state prison sentence was unacceptable. The following day, the USAO, through a letter drafted by Villafaña, rejected this offer and countered that a two-year term of imprisonment was the minimum acceptable sentence to resolve the federal investigation.

Legal document
2025-11-20

DOJ-OGR-00003223.jpg

This document is a page from a DOJ OPR report detailing the initial federal handling of the Jeffrey Epstein case in July-August 2006. It highlights the distrust federal prosecutors (Acosta, Sloman) held toward the Palm Beach State Attorney's Office, fearing leaks to Epstein. It also details the unusual reporting structure where 'Miami' senior management took direct authority, bypassing local supervisors, and notes the FBI's collection of flight manifests and victim testimony despite intimidation tactics by the defense.

Government report (doj office of professional responsibility - opr)
2025-11-20

DOJ-OGR-00003207.jpg

This document, page 31 of a DOJ report (likely the OGR report), details the professional biographies and specific roles of USAO officials Jeffrey Sloman, Matthew Menchel, and Andrew Lourie in the Epstein investigation and the negotiation of the Non-Prosecution Agreement (NPA). It highlights Sloman's negotiation of an NPA addendum, Menchel's communication of the two-year plea deal, and Lourie's role in the NPA negotiations before his departure. The text also notes Alexander Acosta's resignation as Labor Secretary in 2019 due to criticism regarding the Epstein case.

Legal filing / government report (doj office of professional responsibility)
2025-11-20

DOJ-OGR-00003138.jpg

This document is a page from a legal filing, dated April 16, 2021, arguing against the misuse of a 'bill of particulars'. It cites numerous court cases to establish the legal precedent that a bill of particulars is not a tool for the defense to compel the Government to disclose its evidence, witnesses, or trial strategy. The document asserts that such a bill is only warranted when an indictment is so vague that it prevents the defendant from preparing a defense.

Legal document
2025-11-20

DOJ-OGR-00003137.jpg

This document is page 203 of a legal filing (Document 204) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal arguments citing various precedents (Bortnovsky, Mandell, Levy, etc.) to support the Government's position that providing voluminous discovery negates the need for a 'bill of particulars,' arguing that the defense is not entitled to a preview of the Government's legal theories, only what is strictly necessary for defense preparation.

Legal filing / court memorandum (page 203 of 239)
2025-11-20

DOJ-OGR-00003134.jpg

This is page 200 of a legal filing (Document 204) in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text outlines the Government's argument that separate counts for 'conspiracy to transport' and 'conspiracy to entice' minors are not multiplicitous because a jury could theoretically convict on one while acquitting on the other. The Government asserts it intends to prove the defendant did both.

Legal filing (government opposition to motion to dismiss)
2025-11-20

DOJ-OGR-00003127.jpg

This document is a page from a legal filing (Case 1:20-cr-00330-PAE, likely United States v. Ghislaine Maxwell) arguing for the admissibility of evidence. It cites numerous Second Circuit precedents to establish that 'uncharged criminal conduct' is admissible in conspiracy cases when it explains the relationship between coconspirators or completes the story of the crime, rather than merely showing bad character. The text focuses on Federal Rule of Evidence 404(b).

Court filing / legal memorandum
2025-11-20

DOJ-OGR-00003118.jpg

This page is from a Government legal filing (Document 204, filed April 16, 2021) in the case against Ghislaine Maxwell. The Government argues against the defendant's motion to dismiss counts 1-4 and specifically opposes the motion to strike references to 'Minor Victim-3' from the indictment. The prosecution asserts that interactions between the defendant, Epstein, and Minor Victim-3 were part of the broader conspiracy to entice and transport minors, even if specific acts involving this victim might be time-barred as substantive charges.

Legal filing (government opposition to motion to dismiss/strike)
2025-11-20

DOJ-OGR-00003117.jpg

This page is from a legal filing (Document 204) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against the defendant's claims that the indictment is vague or that 'grooming' is not illegal behavior, citing Second Circuit precedents that define grooming as a form of enticement or inducement of minors for illegal sexual activity. The document asserts that the indictment adequately informs the defendant of the charges under 18 U.S.C § 371, § 2422, and § 2243.

Legal filing / court document (government response)
2025-11-20

DOJ-OGR-00003113.jpg

This document is a legal filing from April 16, 2021, arguing that an indictment against a defendant is legally sufficient. It cites several legal precedents, including Russell v. United States and United States v. Pirro, to establish the standards for specificity in indictments. The author contends that the indictment in question meets these standards by laying out all essential elements of the crimes charged and that the defendant has provided no legal authority to suggest otherwise.

Legal document
2025-11-20

DOJ-OGR-00003109.jpg

This document is page 175 (labeled 148 internally) of a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It argues legal points regarding perjury counts, specifically discussing materiality standards for false statements in civil depositions and citing case law (Kross, Gaudin, Kungys). The text argues that a jury can follow limiting instructions to separate the substance of Giuffre's allegations from the determination of whether the defendant committed perjury.

Legal filing / court brief (case 1:20-cr-00330-pae)
2025-11-20

DOJ-OGR-00003103.jpg

This page from a legal filing argues against severing the indictment into separate trials, positing that evidence relevant to perjury counts (Count Six) is inextricably linked to the conspiracy charges (Counts One through Four). The Government contends that a joint trial is necessary to avoid forcing a minor victim (Minor Victim-2) to testify twice about sexual abuse and argues that the defendant's false statements demonstrate a consciousness of guilt relevant to all charges.

Court filing / legal brief
2025-11-20

DOJ-OGR-00003101.jpg

This document is a page from a legal filing, likely a brief or motion, dated April 16, 2021. It argues against the severance of counts or defendants in a criminal case by citing numerous legal precedents. The text establishes that defendants have a 'heavy burden' to show 'substantial prejudice' to justify separate trials, and that courts generally favor joint trials for efficiency, leaving the decision to the district court's discretion.

Legal document
2025-11-20

DOJ-OGR-00003095.jpg

This page from a 2021 court filing (Case 1:20-cr-00330-PAE) presents arguments regarding the defendant's (Ghislaine Maxwell) perjury or false statements. It quotes a deposition where the defendant unequivocally denies ever giving anyone a massage, specifically denying giving massages to Mr. Epstein or '[Minor Victim-2].' The government argues that these answers were not ambiguous and that a jury could conclude the defendant lied.

Court filing / legal brief (government response)
2025-11-20

DOJ-OGR-00003082.jpg

This document is a page from a legal filing, specifically a memorandum of law, discussing the legal standards for perjury. The author argues against dismissing a perjury count before trial based on 'fundamental ambiguity,' citing numerous court cases to establish that such challenges are typically evaluated after a trial. The text distinguishes between answers that are literally true but misleading (which may not be perjury) and answers that are outright false, regardless of responsiveness (which can be perjury).

Legal document
2025-11-20

DOJ-OGR-00003081.jpg

This document is page 147 of a court filing (Document 204) from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on April 16, 2021. It contains legal analysis regarding perjury charges, specifically discussing the legal standard for 'fundamental ambiguity' in questioning. The text cites various precedents to argue that a perjury count stands unless a question is so ambiguous that people of ordinary intellect cannot agree on its meaning, noting that simple amenability to multiple meanings is not a sufficient defense.

Court filing (legal brief/opinion)
2025-11-20

DOJ-OGR-00003077.jpg

This document is page 143 of a legal filing by the Government in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. The text argues against granting the defendant an evidentiary hearing regarding a 'Franks' analysis and asserts that the defendant failed to meet the burden of proof to obtain discovery or dismiss perjury counts. The Government contends that a jury should decide whether the defendant committed perjury during two depositions in a prior civil matter.

Legal filing (government response/memorandum of law in criminal case)
2025-11-20

DOJ-OGR-00003075.jpg

This legal document, a page from a court filing dated April 16, 2021, discusses the legal standard for challenging an affidavit based on alleged omissions of fact. It cites numerous precedents, primarily from the Second Circuit and the Southern District of New York, to argue that a motion to suppress evidence should be denied unless the omissions were intentional, deliberate, or made with reckless disregard for the truth. The document emphasizes that this is a high standard to meet, as courts recognize that all affidavits will inevitably omit some facts that may seem significant in retrospect.

Legal document
2025-11-20

DOJ-OGR-00003074.jpg

This legal document, page 140 of a court filing from April 16, 2021, outlines the legal standard for a defendant to obtain a "Franks hearing" to challenge the validity of an affidavit used for probable cause. It details the three-part test a defendant must meet, requiring a "substantial preliminary showing" of inaccuracies or omissions in the affidavit that were material and made with deliberate falsehood or reckless disregard for the truth. The document explains that a court must then determine the materiality of these errors by revising the affidavit to see if it still supports a finding of probable cause.

Legal document
2025-11-20
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