Nicole Simmons
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Legal representative |
12
Very Strong
|
12 | |
|
person
GHISLAINE MAXWELL
|
Professional |
10
Very Strong
|
8 | |
|
person
Alison Moe
|
Legal representative |
8
Strong
|
4 | |
|
person
MAURENE COMEY
|
Legal representative |
8
Strong
|
4 | |
|
person
Alison Moe
|
Professional adversarial |
8
Strong
|
4 | |
|
person
Lara Pomerantz
|
Professional adversarial |
7
|
3 | |
|
person
ANDREW ROHRBACH
|
Legal representative |
7
|
3 | |
|
person
Lara Pomerantz
|
Legal representative |
7
|
3 | |
|
person
MAURENE COMEY
|
Professional adversarial |
7
|
3 | |
|
person
ANDREW ROHRBACH
|
Professional adversarial |
7
|
3 | |
|
person
Jeffrey Pagliuca
|
Business associate |
6
|
6 | |
|
person
Adam Mueller
|
Professional |
6
|
2 | |
|
person
Pomerantz
|
Legal representative |
6
|
1 | |
|
person
ANDREW ROHRBACH
|
Professional |
5
|
1 | |
|
person
MAURENE COMEY
|
Professional |
5
|
1 | |
|
person
Ms. Maxwell
|
Professional |
5
|
1 | |
|
person
ALEX ROSSMILLER
|
Legal representative |
5
|
1 | |
|
person
Pomerantz
|
Professional adversarial |
5
|
1 | |
|
person
Alison Moe
|
Professional |
5
|
1 | |
|
person
MAXWELL
|
Professional |
5
|
1 | |
|
person
Jeffrey S. Pagliuca
|
Legal representative |
5
|
1 | |
|
person
Lara Pomerantz
|
Professional |
5
|
1 | |
|
person
Adam Mueller
|
Professional co counsel |
5
|
1 | |
|
person
Ms. Maxwell
|
Legal representative |
5
|
1 | |
|
person
Jeff Pagliuca
|
Business associate |
5
|
5 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2022-03-11 | Legal filing | The Certificate of Service (Document 644) was filed with the court. | Court (SDNY) | View |
| 2022-02-09 | Legal filing | Electronic filing of "Ghislaine Maxwell’s Reply in Support of Her Motion for a New Trial". | Court (SDNY) | View |
| 2022-01-19 | Legal filing | Electronic filing of Ghislaine Maxwell’s Motion for a New Trial. | N/A | View |
| 2021-11-22 | N/A | Submission of Maxwell's Response to Letter Motions to Quash Rule 17(c) subpoena to the Epstein Vi... | US District Court SDNY (via... | View |
| 2021-11-22 | N/A | Submission of Ghislaine Maxwell's Response to Letter Motions to Quash subpoena to the Epstein Vic... | Email/Court Filing | View |
| 2021-11-13 | N/A | Filing of Defense Response to Motion In Limine | NYSD Court (via email) | View |
| 2021-11-12 | N/A | Submission of Maxwell's Response to Government's Motion In Limine to Preclude Expert Testimony of... | NYSD (New York Southern Dis... | View |
| 2021-11-01 | N/A | Submission of Rule 16(b)(1)(C) Disclosures for U.S. v. Maxwell | Email correspondence | View |
| 2021-10-29 | Legal filing | The Certificate of Service (Document 391) was filed with the court. | N/A | View |
| 2021-10-29 | Legal filing | Filing of the Certificate of Service (Document 385). | N/A | View |
| 2021-10-28 | N/A | Filing of Ms. Maxwell's Reply In Support of Her Motions in Limine | NYSD Court (via email) | View |
| 2021-10-27 | N/A | Submission of Defense Reply Brief ISO Motions in Limine in U.S. v. Maxwell. | NYSD Court | View |
| 2021-10-26 | N/A | Filing of Ms. Maxwell's Response to Government's Omnibus Motions in Limine | NYSD Court (via email) | View |
| 2021-10-25 | Legal filing | Electronic filing of "Ghislaine Maxwell’s Response to Government’s Omnibus Motions In Limine" wit... | Clerk of Court (via CM/ECF ... | View |
| 2021-10-19 | N/A | Filing of Motions in Limine for U.S. v. Maxwell | NYSD (via email) | View |
| 2021-10-18 | Legal filing | Electronic filing of Ghislaine Maxwell’s Motion to Exclude Any Evidence Offered by the Government. | N/A | View |
| 2021-10-18 | Legal filing | Electronic filing of Ghislaine Maxwell’s Motion to Preclude the Introduction of Alleged Co-Conspi... | N/A | View |
| 2021-10-18 | Legal filing | Electronic filing of "Ghislaine Maxwell’s Motion Preclude Testimony About Any Alleged “Rape” by J... | CM/ECF system | View |
| 2021-10-18 | Legal filing | Electronic filing of the 'Memorandum of Ghislaine Maxwell’s Motion to Suppress Identification' wi... | Clerk of Court | View |
| 2021-10-18 | Legal filing | Ghislaine Maxwell’s Motion in Limine was electronically filed with the Clerk of Court. | N/A | View |
| 2021-10-18 | Legal filing | Electronic filing of "Ghislaine Maxwell’s Motion to Preclude Law Enforcement Witnesses from Offer... | CM/ECF system | View |
| 2021-10-18 | N/A | Electronic filing of Ghislaine Maxwell's Motion in Limine to Exclude Government Exhibit 52 | New York, NY (SDNY) | View |
| 2021-10-18 | Legal filing | Electronic filing of 'Defendant Ghislaine Maxwell's Notice of Motions in Limine'. | CM/ECF system | View |
| 2021-10-18 | Legal filing | Electronic filing of Ghislaine Maxwell’s Motion In Limine to Preclude Reference to the Accusers a... | CM/ECF system | View |
| 2021-10-18 | N/A | Filing of Ghislaine Maxwell’s Motion to Exclude Under Federal Rule of Evidence 702 and Request fo... | New York (via Electronic Fi... | View |
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.
024.pdf
This document is a legal notice filed by Ghislaine Maxwell's attorneys on December 16, 2016, in the Southern District of Florida regarding a subpoena served on Bradley J. Edwards. Maxwell argues that rulings made by the Southern District of New York on a similar subpoena served on Paul Cassell (another attorney for Virginia Giuffre) should be binding (res judicata) on the Edwards subpoena. The filing includes a table comparing the requests in both subpoenas and the corresponding rulings from the SDNY court, asking the Florida court to issue a consistent order requiring production of certain documents and granting the motion to quash for others.
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.
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.
007.pdf
This document is a 'Notice of Filing' submitted to the U.S. District Court for the Southern District of Florida on June 29, 2016. It serves to notify the court and opposing counsel that Defendant Ghislaine Maxwell has filed Exhibits A, G, H, I, and N under seal. These exhibits are attached to a declaration by her attorney, Jeffrey S. Pagliuca, in support of her opposition to Bradley J. Edwards' motion to quash a subpoena.
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.
005.pdf
This document is a Motion to Appear Pro Hac Vice filed on June 29, 2016, in the Southern District of Florida. Attorney Denise D. Riley requests that attorney Jeffrey S. Pagliuca of the Colorado firm Haddon, Morgan and Foreman be admitted to represent Defendant Ghislaine Maxwell in matters related to a subpoena issued to Bradley J. Edwards. The document includes contact information for the attorneys involved and a certificate of service to opposing counsel Jack Scarola.
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
EFTA00032796.pdf
This document is an email dated October 19, 2021, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers in the NYSD. The email serves to submit 'Ms. Maxwell's Motions in Limine' and supporting documents for the case U.S. v. Maxwell (Case No. 20 Cr. 330), done at the request of attorney Jeffrey Pagliuca. The document contains redactions of contact information.
EFTA00032783.pdf
This document is an email chain from April 22, 2021, concerning the case US v. Maxwell. It details internal communications within the US Attorney's Office (USANYS) regarding a draft response to a defense request for a 120 or 180-day trial adjournment. The chain includes an underlying email from Laura Menninger, counsel for Ghislaine Maxwell, submitting the motion to Judge Nathan and arguing for the redaction of other clients' names based on attorney-client privilege rules.
EFTA00032234.pdf
This document is an email dated August 18, 2020, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers. The email serves to transmit a sealed Letter Motion, Affidavit, and ten exhibits on behalf of defendant Ghislaine Maxwell regarding a 'Request to Modify Protective Order' in the case United States v. Ghislaine Maxwell. The filing was made at the request of attorney Jeffrey S. Pagliuca.
EFTA00030900.pdf
An email dated August 9, 2020, from attorney Jeff Pagliuca to redacted recipients and several cc'd attorneys (Menninger, Everdell, Cohen, Simmons). The email transmits an attached conferral letter regarding a protective order and discovery to the USA (likely US Attorney). The document originates from the Ghislaine Maxwell defense team (Haddon, Morgan and Foreman; Cohen Gresser).
EFTA00029180.pdf
This document is an email chain from November 2021 regarding the legal case U.S. v. Maxwell. Attorney Nicole Simmons submits Ghislaine Maxwell's response to the government's motion to preclude the expert testimony of Dr. Park Dietz and Dr. Elizabeth Loftus to Judge Nathan's chambers. The documents were submitted under temporary seal to allow for government redaction proposals.
EFTA00027167.pdf
This document is an email chain from April 22, 2021, involving the defense team for Ghislaine Maxwell and the US Attorney's Office (USANYS). Laura Menninger, representing Maxwell, emailed Judge Nathan attaching a Letter Motion for an adjournment of the trial (120 or 180 days) and requesting permission to redact names of other clients based on professional conduct rules. Subsequent emails between government attorneys discuss a draft response due by 5 PM that same day.
EFTA00027165.pdf
This document is an email chain from April 22, 2021, concerning the case US v. Maxwell. The initial email features Laura Menninger, defense counsel for Ghislaine Maxwell, submitting a Letter Motion for an adjournment of the trial to Judge Nathan and requesting redactions to protect client confidentiality under Rule 1.6. Subsequent emails show internal coordination among USANYS prosecutors drafting a response to this motion, which was due by 5 PM that day.
EFTA00027162.pdf
An email chain from April 21, 2021, between attorneys Sigrid McCawley (Boies Schiller Flexner), Jeff Pagliuca, and Laura Menninger regarding compliance with an order from Judge Nathan. McCawley requests confirmation to send specific documents and redactions related to the Ghislaine Maxwell case to the Government. Pagliuca forwards the relevant PDF attachments, noting they were missing from a previous email.
EFTA00025147.pdf
This document is an email dated October 28, 2021, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers in the Southern District of New York. It serves as a transmittal for the filing of 'Ms. Maxwell's Reply In Support of Her Motions in Limine' in the case U.S. v. Maxwell (Case No. 20 Cr. 330). The email was sent at the request of attorney Jeffrey Pagliuca.
EFTA00025059.pdf
An email from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers, dated October 26, 2021. The email serves as a cover letter for the submission of Ghislaine Maxwell's response to the Government's Omnibus Motions in Limine, sent at the request of attorney Jeffrey Pagliuca.
EFTA00024232.pdf
This document is an email chain from October 2021 regarding the legal case U.S. v. Maxwell. The initial email is from defense attorney Nicole Simmons to Judge Nathan's chambers, submitting Ghislaine Maxwell's reply in support of motions in limine. This email was subsequently forwarded internally within the US Attorney's Office (USANYS) with a note attaching both the defense reply and the government's final brief.
EFTA00023748.pdf
This document is an email chain from September 2020 regarding the filing of legal documents in the case US v. Maxwell (Case No. 20-3061). Nicole Simmons of the law firm Haddon, Morgan and Foreman, P.C. sent an unredacted opening brief and sealed appendix to the Second Circuit Court of Appeals ('newcases@ca2.uscourts.gov') at the request of Adam Mueller. The email was subsequently forwarded to personnel at the US Attorney's Office for the Southern District of New York (USANYS).
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.
EFTA00021898.pdf
This document is an email chain from August 9-12, 2020, between defense attorneys (Jeff Pagliuca, Nicole Simmons, Christian Everdell, Mark Cohen) and the US Attorney's Office for the SDNY regarding a discovery dispute. The defense is pressing for a quick response to an August 9th letter, citing a tight schedule with the Circuit and threatening to advise Judge Nathan if they do not receive a response sooner than the Government's proposed date of August 13th. The correspondence also notes technical email issues at the defense firm Haddon, Morgan and Foreman.
EFTA00021875.pdf
This document is an email chain from August 2020 involving legal counsel for Ghislaine Maxwell (Jeff Pagliuca, Laura Menninger, etc.) and likely government prosecutors (names redacted). The discussion concerns a discovery letter sent by the defense, the handling of criminal grand jury materials in relation to Maxwell's civil cases, and a dispute over the disclosure of victim names. The redacted senders discuss strategy for responding to 'Jeff and Laura,' specifically refuting claims of government malfeasance and debating whether to allow materials to be filed under seal.
Ghislaine Maxwell’s Reply in Support of Her Motion for a ...
Electronic filing of reply brief
Ghislaine Maxwell’s Motion for a New Trial
Nicole Simmons certifies that on January 19, 2022, she electronically filed Ghislaine Maxwell's Motion for a New Trial with the Court and served it to the listed counsel for the government via their official email addresses.
Ghislaine Maxwell’s Motion for a New Trial
Certification that Ghislaine Maxwell's Motion for a New Trial was electronically filed with the Court and served to the counsel for the government on January 19, 2022.
U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Res...
Submitting Maxwell's Response to Letter Motions to Quash her Rule 17(c) subpoena to the Epstein Victims' Compensation Program.
U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Res...
Submitting Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c) subpoena to the Epstein Victims' Compensation Program under temporary seal.
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ma...
Submission of Maxwell's response to Government's Motion In Limine regarding experts Dr. Park Dietz and Dr. Elizabeth Loftus, submitted under temporary seal.
U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN)
Submission of Maxwell's Response to Government's Motion In Limine regarding Dr. Dietz and Dr. Loftus.
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ma...
Submission of Maxwell's Response to Government's Motion In Limine regarding expert testimony.
[EXTERNAL] U.S. v. Maxwell, 20Cr330 (AJN) [Ms. Maxwell's ...
Dear Counsel: At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Rule 16(b)(1)(C) Disclosures.
[EXTERNAL] U.S. v. Maxwell, 20Cr330 (AJN) [Ms. Maxwell's ...
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Rule 16(b)(1)(C) Disclosures.
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms...
Submission of Ms. Maxwell's Reply In Support of Her Motions in Limine and supporting documents at the request of Jeffrey Pagliuca.
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms...
Submission of Ms. Maxwell's Reply In Support of Her Motions in Limine and supporting documents at the request of Jeffrey Pagliuca.
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms...
Submission of Ms. Maxwell's Response to the Government's Omnibus Motions in Limine.
Ghislaine Maxwell’s Response to Government’s Omnibus Moti...
A certificate confirming that a legal response on behalf of Ghislaine Maxwell was electronically filed with the Clerk of Court and that notification was sent to four individuals at the U.S. Attorney's Office via the CM/ECF system.
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms...
Submission of Ms. Maxwell's Motions in Limine and supporting documents to Judge Nathan at the request of Jeffrey Pagliuca.
Ghislaine Maxwell’s Motion in Limine to Exclude Items Pur...
Certification of the electronic filing of a motion on behalf of Ghislaine Maxwell to the Clerk of Court, with notification sent to four individuals at the U.S. Attorney's Office.
Ghislaine Maxwell’s Motion to Exclude Any Evidence Offere...
Certification that a motion on behalf of Ghislaine Maxwell was electronically filed with the Clerk of Court and that notification was sent to four individuals at the U.S. Attorney's Office via the CM/ECF system.
Filing of Ghislaine Maxwell’s Motion In Limine to Preclud...
This document certifies that a legal motion was electronically filed with the Clerk of Court on October 18, 2021, and that the CM/ECF system would send notification to all counsel of record, including four individuals at the U.S. Attorney's Office.
Filing of Defendant Ghislaine Maxwell's Notice of Motions...
A certification that a legal motion for Defendant Ghislaine Maxwell was electronically filed with the court and that notification was sent via the CM/ECF system to four individuals at the U.S. Attorney's Office.
Filing of Ghislaine Maxwell’s Motion to Preclude Law Enfo...
Certification that a motion on behalf of Ghislaine Maxwell was electronically filed via the CM/ECF system, which would notify all counsel of record.
Ghislaine Maxwell’s Motion to Preclude the Introduction o...
Certification that a motion on behalf of Ghislaine Maxwell was electronically filed with the Clerk of Court and that notification was sent via the CM/ECF system to four individuals at the U.S. Attorney's Office.
Filing of Ghislaine Maxwell’s Motion Preclude Testimony A...
Certification that a motion was electronically filed with the Clerk of Court and that notification was sent to four individuals at the U.S. Attorney's Office via the court's CM/ECF system.
Service of Ghislaine Maxwell’s Motion in Limine
Notification of filing regarding Motion to Exclude Government Exhibit 52
[EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms...
Submission of 13 motions in limine on behalf of Ms. Maxwell at the request of Jeffrey Pagliuca.
Memorandum of Ghislaine Maxwell’s Motion to Suppress Iden...
Nicole Simmons certifies that she electronically filed a motion on behalf of Ghislaine Maxwell and that the CM/ECF system would send notification to four individuals at the U.S. Attorney's Office.
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