Event Details

This is a Protective Order filed on March 18, 2016, in the case of [Redacted] v. Ghislaine Maxwell (Case 1:15-cv-07433-RWS). The order, signed by Judge Robert W. Sweet, establishes protocols for handling confidential discovery materials, defining who may access such information and outlining procedures for sealing documents and handling depositions. It specifies that confidential information may only be used for the preparation and trial of this specific case.

This document is a Waiver of the Service of Summons filed on November 27, 2019, in the Southern District of New York for Case 1:19-cv-10577-LGS (Jane Doe 1000 v. Darren K. Indyke et al). Attorney Bennet Moskowitz of Troutman Sanders LLP signs on behalf of defendants Darren K. Indyke and Richard D. Kahn (executors of the Epstein estate), acknowledging receipt of the complaint and agreeing to waive formal service. The waiver is addressed to plaintiff's attorney David Boies.

This document is a Waiver of the Service of Summons filed on November 27, 2019, in the case of Maria Farmer v. Darren K. Indyke et al (Case No. 1:19-cv-10474-NRB) in the Southern District of New York. Attorney Bennet Moskowitz of Troutman Sanders LLP signed the waiver on November 25, 2019, on behalf of defendants Darren K. Indyke and Richard D. Kahn, agreeing to waive formal service and respond to the complaint within 60 days. The waiver is addressed to plaintiff's attorney David Boies.

A Waiver of the Service of Summons filed in the US District Court for the Southern District of New York on November 27, 2019, in the case of Teresa Helm v. Darren K. Indyke et al. Attorney Bennet Moskowitz of Troutman Sanders LLP signed the waiver on November 25, 2019, on behalf of defendants Darren K. Indyke and Richard D. Kahn, acknowledging receipt of the complaint from plaintiff's attorney David Boies.

A court order from the Southern District of New York in the case of VE v. Nine East 71st Street Corporation (an Epstein-affiliated entity). Judge Alison J. Nathan directs the court clerk to clear specific docket numbers (4 and 24) which were resolved by a previous docket entry.

This document is the first page of a declaration by Stephen Gillers, a legal ethics professor at NYU, filed on April 6, 2012, in the case United States v. Paul M. Daugerdas. Gillers outlines his qualifications and states he was asked to address whether attorneys for the firm Brune & Richard met their ethical obligations regarding the disclosure of a 'July 21 letter' and an investigation into 'Juror No. 1.' The document appears to be part of a larger Department of Justice release (DOJ-OGR stamp), though the specific text on this page relates to the Daugerdas tax fraud case rather than explicitly mentioning Epstein.

This document is page 12 of a defense filing arguing for Jeffrey Epstein's pretrial release. The defense argues that Epstein's 'tier-one' sex offender status in the U.S. Virgin Islands indicates low risk, and cites legal precedents (Sabhnani, Hansen) where wealthy defendants with foreign ties were granted bail. A significant footnote asserts Epstein is solely a U.S. citizen, his only foreign residence is in France (which has an extradition treaty), and the majority of his assets are in the U.S.

This document is a Stipulation of Dismissal with Prejudice for Case No. 1:19-cv-09610-PAE-DCF in the Southern District of New York, filed on October 8, 2020. Plaintiff Jane Doe 17 voluntarily dismisses her action against the Estate of Jeffrey Epstein and various associated corporate entities without costs. The document is signed by attorneys David H. Brodie (for the Plaintiff) and Bennet J. Moskowitz (for the Defendants).

This document is a Notice of Appearance (Form AO 458) filed in the United States District Court for the Southern District of New York on November 20, 2019. Attorney Jason E. Foy officially enters his appearance as counsel for Tova Noel in Case Number 19 Crim 830. The document includes the attorney's contact information in Hackensack, New Jersey.

A 'Consent to Proceed by Videoconference' form filed in the Southern District of New York on September 10, 2020, for Case 1:19-cr-00830-AT. Defendant Michael Thomas (implicated in the falsification of records regarding Jeffrey Epstein's detention) and his attorney Montell Figgins signed the document on September 8, 2020, consenting to have a 'Status and/or Scheduling Conference' conducted via video. The document was approved by District Judge Analisa Torres.

This document is a 'Nolle Prosequi' filed in the Southern District of New York, formally dismissing criminal charges against Tova Noel and Michael Thomas. The defendants, who were the guards on duty when Jeffrey Epstein died, had previously entered into a deferred prosecution agreement on May 20, 2021. Following their successful completion of community service and good behavior over a six-month period ending November 20, 2021, the U.S. Attorney's Office moved to drop the case.

This document is page 31 of 35 from a court filing (Document 367) in Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on October 22, 2021. It is a blank Declaration form for a Jury Questionnaire, requiring a juror to verify their answers under penalty of perjury and confirm they received no assistance. The document bears the Bates stamp DOJ-OGR-00005353.

This is the signature page (page 2 of 2) of a legal document filed on April 5, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The document is submitted by attorney Laura A. Menninger to Judge Alison J. Nathan. It references a date of April 19, 2021, and bears the Bates stamp DOJ-OGR-00002889.

This is page 10 of a legal filing from July 10, 2020, in the case United States v. Ghislaine Maxwell. The text argues for release or specific detention conditions based on the high risk of COVID-19 in prisons, citing statistics and prior court rulings. It specifically notes that Maxwell was transferred to the Metropolitan Detention Center (MDC) by the BOP on July 6, 2020.

This document is page 18 of a Government filing (Document 295) in the case against Ghislaine Maxwell, filed on May 25, 2021. The Government argues that Maxwell's motion to dismiss charges based on pre-indictment delay should be denied because she failed to prove prejudice or improper tactical motives by the prosecution. The text specifically addresses the 'S2 Indictment,' noting that new charges involving 'Minor Victim-4' were added based on new evidence unavailable previously, refuting claims of bad faith delay.

This is a page from a government legal filing opposing bail for Ghislaine Maxwell, filed on December 18, 2020. The prosecution argues that despite a lack of specific documentary evidence for every abusive act, the case remains strong due to victim testimony and corroborating documents linking her to Epstein. It further argues for continued detention based on her 'significant foreign ties,' 'millions of dollars in cash' transferred to her spouse, and a 'sophisticated ability to live in hiding.'

This document is page 3 of a court order (Case 1:19-cr-00830-AT) filed on December 16, 2019. It outlines protocols for handling 'Protected Materials' during discovery, specifically defining authorized personnel (legal staff, experts, jury consultants) who may access the data. It also establishes rules for showing materials to 'Fact Witnesses' without providing them copies, and mandates the destruction or return of materials to the Government upon the case's conclusion.

This document is page 2 of a legal letter addressed to Judge Alison J. Nathan dated December 27, 2021, regarding the trial of Ms. Maxwell. It argues that without specific jury instructions, there is a risk of 'constructive amendment' or 'prejudicial variance' from the S2 Indictment, citing case law (Gross, D'Amelio, Wozniak) to define the constitutional protections against convicting a defendant on charges not specified in the indictment.

This document is page 16 of a court order filed on April 29, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The page details the Court's denial of the Defendant's Rule 29 motion for a judgment of acquittal, citing various legal precedents regarding the sufficiency of evidence required to sustain a conviction. The text outlines the legal standard that evidence must be viewed in the light most favorable to the government.

This page from a government filing (Case 1:20-cr-00330-AJN) argues against bail for Ghislaine Maxwell. The prosecution asserts that despite a lack of specific documents naming Maxwell for every instance, the combination of victim testimony and corroborating evidence regarding Epstein makes a strong case. It also highlights Maxwell's flight risk factors, including significant foreign ties, millions in cash transferred to her spouse, and a sophisticated ability to live in hiding.

This document is page 23 (filed page 30) of a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), dated February 24, 2022. The text presents legal arguments regarding juror misconduct during voir dire, citing precedents to argue that a false answer by a juror—whether intentional or inadvertent—that hides bias constitutes structural error requiring a new trial. It references key cases such as United States v. Barnes, United States v. Stewart, and McDonough.

This document is page 30 of a defense filing (Document 197) in the case against Ghislaine Maxwell, dated December 14, 2020. The defense argues that despite the government's initial claims of 'strong' evidence backed by flight logs and diaries, the discovery produced (over 1.2 million documents) contains 'no meaningful documentary corroboration' of the allegations for the indictment period of 1994-1997. The text notes that the majority of evidence produced relates to the 2000s and 2010s, and mentions electronic devices seized from Jeffrey Epstein's residences in 2019.

This document is page 11 of a court filing (Case 4:17-cr-02949-MV) dated February 3, 2021. It argues for the pretrial release of a defendant named Mr. Robertson under 18 U.S.C. § 3142(i) to allow him to prepare for his trial scheduled for April 5, 2021. The text cites various legal precedents regarding temporary release for defense preparation. Note: While the user requested an 'Epstein-related' analysis, this specific page pertains to a 'Mr. Robertson' and does not contain direct text references to Jeffrey Epstein.

This document is a letter dated February 9, 2022, from the law firm Winston & Strawn LLP to Judge Alison J. Nathan regarding the case United States v. Maxwell. Writing on behalf of the National Association of Criminal Defense Lawyers (NACDL), the firm requests permission to file an amicus curiae brief addressing post-trial revelations about Juror # 50 and the potential impact on the defendant's right to a fair trial. The letter outlines the specific legal issues NACDL intends to address, including voir dire in high-profile cases and juror bias.

This document is a court order (Form AO 199B) filed on November 19, 2019, outlining additional conditions of release for a defendant involved in Case 1:19-cr-00830-AT. The conditions mandate pretrial supervision, the surrender of passports, travel restrictions limited to NY, NJ, and Eastern PA, a prohibition on firearms, and a requirement for mental health evaluation and treatment.

This document is page 4 of a legal filing (Motion in Limine) in the case of United States v. Ghislaine Maxwell, filed on October 29, 2021. The defense argues that the Government should be precluded from introducing certain evidence under Federal Rule of Evidence 404(b) because the prosecution failed to provide particularized notice and reasoning as required by the December 2020 amendments to the rule. The text outlines the specific requirements of the amended rule regarding notice in criminal cases.

This document page is from a legal filing in the case United States v. Ghislaine Maxwell (1:20-cr-00330). The text presents a legal argument distinguishing the current case from *United States v. Oshatz*, specifically regarding the enforceability of subpoenas for deposition transcripts and protective orders. It cites Chief Judge McMahon's finding that the Government demonstrated 'extraordinary circumstances' justifying the modification of a protective order, unlike in *Oshatz* where the government was characterzied as 'trolling for evidence'.

This page is from a government filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), arguing against the defendant's motion to dismiss based on the statute of limitations. The text asserts that the Ex Post Facto Clause is not violated because the limitations period had not expired for Counts One through Four when it was extended in 2003. Footnotes address the specific ages of Minor Victims 1, 2, and 3 in relation to the 2003 extension and discuss the 'Landgraf' Supreme Court precedent regarding legislative retroactivity.

This document is page 2 of a legal filing by attorney Bobbi C. Sternheim regarding the detention conditions of Ghislaine Maxwell at the MDC East Building. The text details unsanitary conditions involving mold and vermin, inadequate facilities for legal counsel meetings (described as a 'fishbowl' and 'death trap'), and Maxwell's deteriorating health due to lack of fresh air and sunlight over eight months. It also notes that a request for a legal call regarding pretrial motions was denied.

This document is a letter of support dated December 1, 2020, addressed to Judge Alison J. Nathan regarding Ghislaine Maxwell's bail application. The anonymous author, a close friend of Maxwell since at least 1991, attests to Maxwell's character, mentions staying with her in New York after her father's death, and defends the operations of the TerraMar charity. The author asserts they have never witnessed unlawful or inappropriate behavior by Maxwell.

This document is the final page (page 8) of a legal filing submitted by attorney Bobbi C. Sternheim on April 15, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The text serves as the conclusion to the filing, formally requesting a trial continuance in the 'interests of justice' prior to an arraignment scheduled for April 23rd. It bears the Bates stamp DOJ-OGR-00002932.

This document appears to be page 22 of a legal filing (likely an opinion or government brief) dated December 2, 2024, related to the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues that there was no prejudicial variance between the evidence presented at trial and the original indictment, citing various legal precedents (Parker, Salmonese, Dove) to support the validity of the conviction under New York law.

This document is a Notice of Motion filed on August 6, 2025, in the U.S. District Court for the Southern District of New York (Case 20 Cr. 330). Attorneys Jeffrey S. Pagliuca and Laura A. Menninger of the firm Haddon, Morgan & Foreman, P.C. are formally requesting a court order to withdraw as co-counsel for the defendant, Ghislaine Maxwell.

This document is page 10 of a legal filing (Case 1:20-cr-00330-PAE) filed on December 2, 2024. It argues that Jeffrey Epstein's Non-Prosecution Agreement (NPA) was limited solely to the Southern District of Florida and does not prevent the USAO-SDNY from prosecuting Ghislaine Maxwell. The text cites the 'Annabi' precedent to support the conclusion that the agreement does not bind other districts.

This document is a handwritten legal motion filed on October 12, 2021, by federal inmate David A. Diehl (Reg. No. 53214018) from USP Coleman II. Diehl argues legal points regarding statutes of limitations, citing 'Stogner v. California' and 18 USC § 3299, to request 'intervenor status' in the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The document serves as a cover letter for an enclosed brief he wishes to file in her case.

This document is Page 2 of a legal filing from the United States v. Ghislaine Maxwell case (1:20-cr-00330), filed on October 18, 2021. The text outlines legal arguments regarding jury selection (*voir dire*), citing Second Circuit precedents to argue that the court, rather than attorneys, should conduct the questioning of potential jurors to ensure impartiality and efficiency. The filing asserts that the defendant (Maxwell) has provided no persuasive reason to deviate from this customary practice.

This document is a page from the court transcript of the United States v. Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). It contains jury instructions regarding the admissibility and limited use of 'similar acts' evidence. The judge instructs the jury that such evidence cannot be used to prove bad character, but may be used to determine intent, lack of mistake, or the existence of a common scheme or plan.

This is a legal document filed on December 30, 2021, in the Southern District of New York (Case 1:19-cr-00830-AT). United States Attorney Damian Williams directs that an order of 'nolle prosequi' (abandonment of prosecution) be filed regarding defendants Tova Noel and Michael Thomas, effectively dropping the charges related to Indictment 19 Cr. 830. The document includes a space for Judge Analisa Torres to order the action.

This page contains court testimony from a witness named Brune regarding the ethics of legal defense. Brune discusses the concept of 'forceful advocacy' and denies raising issues with the Court without believing they had merit. The examination concludes with a transition to questions regarding a former client named David Parse.

This document is page 25 of a legal filing (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) dated April 29, 2022. It discusses the court's jury instructions regarding the Mann Act and the predicate New York Penal Law Section 130.55, which criminalizes sexual contact with individuals under seventeen. The text specifically mentions counts related to the transportation of a victim named 'Jane' and the enticement of minors.

This document is page 7 (filed as page 5 of Document 638) of a jury questionnaire for Case 1:20-cr-00330 (USA v. Ghislaine Maxwell). Filled out by 'Juror ID 50', the form shows the juror checking 'No' to questions regarding scheduling conflicts, English language difficulties, medical/mental conditions affecting service, and medication usage that would affect attention.