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 |
EFTA00019849.pdf
An email dated September 23, 2020, from Nicole Simmons of HMF Law (Haddon, Morgan and Foreman) to the US Court of Appeals for the Second Circuit. The email submits an unredacted version of a legal filing regarding the consolidation of cases related to Ghislaine Maxwell (Civil case 20-2413 and Criminal case 20-3061).
EFTA00016944.pdf
This document is an email chain from October 18-19, 2021, regarding the filing of Motions in Limine in the case U.S. v. Maxwell (Case No. 20 Cr. 330). Defense attorney Nicole Simmons submits the motions to Judge Nathan's chambers on behalf of Jeffrey Pagliuca. Subsequent internal emails among USANYS staff discuss accessing the files, revealing an internal DOJ file path labeled 'USvEpstein-2018R01618'.
EFTA00016508.pdf
This document is an email chain from November 2021 regarding legal proceedings. Laura Menninger of Haddon, Morgan & Foreman, P.C. sends a supplemental letter to USANYS counsel regarding the anticipated testimony of a redacted individual (Mr. [Redacted]). The forwarding email references 'Flatley and their rebuttal expert,' suggesting the correspondence concerns expert witness testimony or rebuttal.
EFTA00016267.pdf
This document is an email thread from November 2021 regarding 'U.S. v. Maxwell'. Nicole Simmons of Haddon, Morgan and Foreman, P.C. sent 'Ms. Maxwell's Rule 16(b)(1)(C) Disclosures' to USANYS counsel at the request of Jeffrey Pagliuca. The email was subsequently forwarded internally within the US Attorney's Office.
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.
EFTA00014984.pdf
This document is an email chain from November 2021 regarding the case U.S. v. Maxwell. Nicole Simmons of the defense firm Haddon, Morgan and Foreman sent Rule 16 disclosures to the US Attorney's Office (USANYS) at the request of Jeff Pagliuca. The email was subsequently forwarded internally within the USANYS office with a note regarding a brief due on November 15th assigned to Ryan Hall.
EFTA00014710.pdf
This document is an email chain from November 2021 regarding *U.S. v. Maxwell*. Defense attorneys Bobbi Sternheim and Nicole Simmons communicate with Judge Nathan's chambers about submitting Ghislaine Maxwell's response to motions to quash a subpoena issued to the Epstein Victims' Compensation Program (EVCP). The correspondence confirms that the response was submitted under temporary seal and that the government and moving parties were subsequently served after redactions were handled.
EFTA00014699.pdf
This document is an email chain from November 22, 2021, regarding the legal case U.S. v. Maxwell. Defense attorneys (Sternheim and Simmons) communicate with Judge Nathan's chambers regarding the submission of Maxwell's response to motions to quash a subpoena issued to the Epstein Victims' Compensation Program (EVCP). The correspondence confirms that the EVCP has been served and discusses protocols for redactions and serving the moving parties.
EFTA00011164.pdf
This document is an email chain from October 2021 regarding the filing of 13 motions in limine by the defense in the case U.S. v. Maxwell (Case No. 20 Cr. 330). Nicole Simmons of Haddon, Morgan and Foreman, P.C. submitted the motions to Judge Nathan's chambers on behalf of Jeffrey Pagliuca. Subsequent internal emails among USANYS staff discuss accessing these files via a shared DOJ drive path (referencing 'StAndrews' and 'USvEpstein') or via email attachment.
EFTA00010217.pdf
This document is an email from Nicole Simmons (Haddon, Morgan and Foreman, P.C.) to Judge Nathan's chambers in the U.S. v. Maxwell case, dated November 13, 2021. It serves as a transmittal for filing Ghislaine Maxwell's response to the government's motion to preclude the expert testimony of Dr. Park Dietz and Dr. Elizabeth Loftus. The filing was submitted under temporary seal to allow for potential redactions by the government.
EFTA00010184.pdf
This document is an email chain from November 2021 related to the U.S. v. Maxwell trial (Case No. 20 Cr. 330). Defense attorney Nicole Simmons forwards a response to the government's motion to preclude the testimony of expert witnesses Dr. Park Dietz and Dr. Elizabeth Loftus to Judge Nathan's chambers. The documents were submitted under temporary seal to allow the government to review for necessary redactions.
DOJ-OGR-00001771.jpg
This document is a Certificate of Service for case 1:20-cr-00330-AJN, filed on September 4, 2020. In it, Nicole Simmons certifies that on September 3, 2020, she filed a Notice of Appeal with the Clerk of Court and served it via email to all parties of record.
DOJ-OGR-00001557.jpg
This document is a Certificate of Service filed on July 8, 2020, in Case 1:20-cr-00330-AJN. Nicole Simmons certifies the electronic service of the 'Declaration of Jeffrey S. Pagliuca in Support of Motion for Admission Pro Hac Vice' to three attorneys at the U.S. Attorney's Office in the Southern District of New York: Alex Rossmiller, Alison Moe, and Maurene Comey.
DOJ-OGR-00001552.jpg
This document is a Certificate of Service filed on July 8, 2020, in Case 1:20-cr-00330-AJN (related to Ghislaine Maxwell). Nicole Simmons certifies that she electronically served a Declaration by attorney Jeffrey S. Pagliuca, regarding his admission Pro Hac Vice, to Assistant US Attorneys Alex Rossmiller, Alison Moe, and Maurene Comey at the SDNY.
DOJ-OGR-00001550.jpg
This document is a Certificate of Service filed in case 1:20-cr-00330-AJN on July 8, 2020. In it, Nicole Simmons certifies that she electronically served a 'Motion for Admission Pro Hac Vice' to Alex Rossmiller, Alison Moe, and Maurene Comey at the U.S. Attorney's Office for the Southern District of New York (SDNY).
DOJ-OGR-00002318.jpg
This document is a Certificate of Service from the legal case 1:20-cr-00330-AJN, filed on January 25, 2021. Signed by Nicole Simmons, it certifies that a memorandum supporting Ghislaine Maxwell's motion to dismiss several counts of her indictment was electronically filed with the Clerk of Court. The certificate confirms that notification of this filing was sent to four individuals at the U.S. Attorney's Office for the Southern District of New York.
DOJ-OGR-00002308.jpg
This document is a Certificate of Service from the legal case 1:20-cr-00330-AJN, filed on January 25, 2021. Nicole Simmons certifies the electronic filing of a memorandum on behalf of Ghislaine Maxwell and confirms that notification was sent to four individuals at the U.S. Attorney's Office in New York: Alison Moe, Maurene Comey, Andrew Rohrbach, and Lara Pomerantz.
DOJ-OGR-00002308(1).jpg
This document is a Certificate of Service from a legal case, dated January 25, 2021. It certifies that Nicole Simmons electronically filed a memorandum on behalf of Ghislaine Maxwell and that notification was sent to four individuals at the U.S. Attorney's Office for the Southern District of New York.
DOJ-OGR-00019606.jpg
This document is the signature page (page 15 of 15, internal page 14) of a legal response filed on September 28, 2020, in Case 20-3061. Attorneys Adam Mueller and Ty Gee of Haddon, Morgan and Foreman, P.C. submit the filing on behalf of Defendant-Appellant Ghislaine Maxwell. The document includes a Certificate of Compliance regarding word count and a Certificate of Service confirming the filing of 'Ms. Maxwell’s Response to the Government’s Motion to Dismiss Appeal'.
DOJ-OGR-00019590.jpg
This document is page 6 of a court filing (Case 20-3061) dated September 24, 2020. It contains a Certificate of Compliance signed by Adam Mueller confirming the motion meets word count limitations, and a Certificate of Service signed by Nicole Simmons confirming the filing of an 'Unopposed Motion for Leave to File under Seal' regarding Appendix Volume 2 via CM/ECF.
DOJ-OGR-00019582.jpg
This document is a Certificate of Service filed on September 4, 2020 (referencing a September 3 action), in case 1:20-cv-00330-AJN. Nicole Simmons certifies that she filed a Notice of Appeal with the Clerk of Court by mail and served all parties of record by email. The document bears a Department of Justice Bates stamp (DOJ-OGR-00019582).
DOJ-OGR-00019439.jpg
This legal document from Case 20-3061, dated September 24, 2020, contains two certifications related to a court filing. Adam Mueller certifies that a brief complies with federal court rules regarding word count (7,343 words) and formatting, while Nicole Simmons certifies that she filed 'Ms. Maxwell’s Opening Brief' with the court and served it to all counsel of record via the CM/ECF system.
DOJ-OGR-00019399.jpg
This legal document from Case 20-3061, dated September 23, 2020, contains two certifications related to a court filing for Ghislaine Maxwell. Counsel Adam Mueller certifies that the response brief complies with the court's word count rules, and Nicole Simmons certifies that she has filed "Ghislaine Maxwell's Response to Opposition to Motion to Consolidate" with the court and served it to all counsel of record.
DOJ-OGR-00019301.jpg
This document is a Certificate of Service dated September 10, 2020, signed by Nicole Simmons. It certifies that Ghislaine Maxwell's Motion to Consolidate Appeal was filed with the Court via CM/ECF and a copy was emailed to all counsel of record on that date. The document confirms the proper legal service of the motion.
DOJ-OGR-00019286.jpg
This document is a Certificate of Service from Case 20-3061, dated September 10, 2020. In it, Nicole Simmons certifies that she filed an 'Unopposed Motion to File Motion to Consolidate under Seal' with the Court via the CM/ECF system and also emailed a copy of the motion to all counsel of record on the same day.
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 Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c) subpoena to the Epstein Victims' Compensation Program under temporary seal.
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.
[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.
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.
[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.
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.
[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.
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.
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 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.
Service of Ghislaine Maxwell’s Motion in Limine
Notification of filing regarding Motion to Exclude Government Exhibit 52
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.
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