counsel

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Unknown (presumably counsel for Ms. Maxwell) outside counsel Defense Counsel ('we') Unidentified Defense Counsel NY Counsel Noel's Counsel Jane Doe's Counsel Defense Counsel / USAO USAO / Defense Counsel Defense Counsel (mentioned) NY counsel Counsel for Jane Doe 1 and 2 Defense Counsel (Cohen & Gresser) Counsel / USANYS Regional Counsel

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Connected Entity	Relationship Type	Strength (mentions)	Documents	Actions
person Retired Police Officer	Employee	5	1	View
person REDACTED (Supervisory Staff Attorney)	Professional hierarchical	1	1	View

Date	Event Type	Description	Location	Actions
2022-08-10	Meeting	Meetings were held with a witness from the financial institution.	Unknown	View
2022-08-10	N/A	Court proceedings in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). Discussion rega...	Courtroom (Southern Distric...	View
2021-08-04	N/A	Preparation of the 'Nineteenth Production' of discovery materials in US v. Maxwell.	SDNY Office	View
2020-08-05	N/A	First batch of discovery provided by government to NY counsel on a hard disk.	New York	View
2019-09-03	N/A	Court Hearing (Case 1:19-cr-00490-RMB)	Southern District of New Yo...	View
2010-06-30	N/A	Epstein produced redacted tax returns to Jane Doe's counsel.	Email	View

DOJ-OGR-00001049.jpg

This document is a page from a court transcript (Page 45, filed on 04/01/2021) regarding a bail hearing. Defense counsel is arguing for the release of their client (implied to be Ghislaine Maxwell based on the case ID context), asserting that while the Crime Victims' Rights Act (CVRA) gives victims a voice, it does not give them a 'veto' over a defendant's right to release. The counsel cites Judge Orenstein's opinion in *United States v. Turner* (2005) to support the argument that victim objections regarding flight risk should not automatically deny bail.

Court transcript / legal filing (appendix)

2025-11-20

Analysis Source

DOJ-OGR-00021999.jpg

This document is page 2 of a government legal filing dated January 28, 2020, arguing against a defense request to adjourn the trial. The text references defendants 'Thomas' and 'Noel' (likely the guards on duty during Epstein's suicide), stating that the case revolves around a 'brief, fourteen-hour window' and is not complex enough to warrant a six-month delay. The government asserts it has already provided witness statements (3500 material) well in advance and notes that no search warrants were obtained nor did defendants make post-arrest statements.

Legal filing (government opposition to adjournment)

2025-11-20

Analysis Source

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Urging the government not to bring the case

From: counsel

To: the government

Defense counsel states they have been in contact with the government eight to ten times in the past year to urge them not to bring the case.

Contact

N/A

Communication Source

Constructive Amendment / Variance

From: counsel

To: The Honorable Alison J...

This document argues that without further instruction, the jury might convict Ms. Maxwell based on a constructive amendment or prejudicial variance from the indictment, which would violate her constitutional rights. It cites legal precedents to support this claim.

Legal document

2021-12-27

Communication Source