December 14, 2020
Filing of Document 97 in Case 1:20-cr-00330-AJN
| Name | Type | Mentions | |
|---|---|---|---|
| The Court | organization | 2003 | View Entity |
| Defense team | organization | 34 | View Entity |
| Defense counsel | person | 578 | View Entity |
| court | location | 177 | View Entity |
DOJ-OGR-00002043.jpg
A character reference letter submitted to the court (Case 1:20-cr-00330-AJN) in support of Ghislaine Maxwell, likely for a bail application. The redacted author attests to Maxwell's appropriate behavior around children, expresses belief in her innocence regarding sex trafficking charges, and asserts confidence that she will not flee and will attend her trial to clear her name.
DOJ-OGR-00001977.jpg
This document is page 'iv' (page 5 of the PDF) from a legal filing dated December 14, 2020, in case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It serves as a Table of Authorities, citing 18 U.S.C. § 3142 (relating to release or detention of a defendant pending trial) and Rule 5(F) of the Federal Rules of Criminal Procedure. The page bears a Department of Justice discovery stamp (DOJ-OGR-00001977).
DOJ-OGR-00002111.jpg
This document is a separator page titled 'Annex A' from a court filing in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 14, 2020. It serves as a cover page for an attachment within the legal filing and bears the Bates number DOJ-OGR-00002111.
DOJ-OGR-00002006.jpg
This document is page 34 of a legal filing from December 14, 2020, in the case against Ghislaine Maxwell. It details expert opinions from Mr. Perry (UK law) and William Julié (French law), both arguing that Maxwell would be unable to resist extradition to the US from either the UK or France, and would be unlikely to receive bail in the UK if she absconded there. These arguments appear designed to support a request for bail in the US by minimizing her flight risk.
DOJ-OGR-00002098.jpg
This document is page 3 of 29 from a court filing (Document 97-21) in the case against Ghislaine Maxwell, filed on December 14, 2020. The text asserts that it is highly unlikely Maxwell could successfully resist extradition to the United States regarding charges from the July 7, 2020 superseding indictment.
DOJ-OGR-00002024.jpg
This document is a redacted character reference letter filed on December 14, 2020, in support of Ghislaine Maxwell's bail application. The unnamed author attests to trusting Maxwell implicitly with their children, citing a specific instance where their teenage son visited Maxwell in New York alone. The letter also highlights Maxwell's loving relationship with her husband and mentions an aggressive encounter with paparazzi.
DOJ-OGR-00002031.jpg
This document is a redacted character reference letter filed on December 14, 2020, in support of Ghislaine Maxwell's bail application (Case 1:20-cr-00330-AJN). The unnamed author argues that Maxwell has strong ties to the US, including her husband, and expresses distress over her incarceration conditions, specifically citing over 150 days of solitary confinement. The author pledges to stay in contact and provide support if Maxwell is granted bail to help her prepare for trial.
DOJ-OGR-00002115.jpg
This document is page 20 of a legal filing (Document 97-21) in the case United States v. Ghislaine Maxwell (indicated by case number 1:20-cr-00330-AJN). It details the 'Practical Experience' of a legal expert named Mr. Perry, specifically focusing on his history with high-profile extradition cases involving the US, UK, and Russia. The document lists specific case citations where Mr. Perry represented various parties, including the US Government, the Governor of the Cayman Islands, and individual defendants resisting extradition.
DOJ-OGR-00001995.jpg
This document is a page from a legal filing (Case 1:20-cr-00330-AJN) dated December 14, 2020, filed by Ghislaine Maxwell's defense. It references a 'Macalvins report' used to refute government claims that Maxwell's finances are opaque, asserting that she and her spouse have fully disclosed assets totaling approximately $22.5 million, which is offered as the bond amount. A footnote contains redactions regarding the name of a specific bank to protect privacy or security.
DOJ-OGR-00002125.jpg
This document is a cover page for 'Exhibit V', filed on December 14, 2020, as part of case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It contains a Bates stamp identifier DOJ-OGR-00002125.
DOJ-OGR-00002062.jpg
This document is the cover page for a 'Financial Condition Report' regarding Ghislaine Maxwell, covering the years 2015 through 2020. It was filed on December 14, 2020, as part of Case 1:20-cr-00330-AJN, and was prepared by Macalvins Limited Chartered Accountants for the law firm Cohen & Gresser LLP.
DOJ-OGR-00001988.jpg
This document is a legal memorandum filed on December 14, 2020, arguing for Ghislaine Maxwell's release on bail (Case 1:20-cr-00330-AJN). It asserts that Maxwell has deep ties to the U.S., specifically through her spouse (whose name is redacted), and is supported by letters from family and friends willing to post significant financial assets as sureties. The defense argues these letters counter the 'cruel caricature' of Maxwell in the press and address the Court's previous concerns regarding her lack of dependents or ties to the country.
DOJ-OGR-00002011.jpg
This document is page 39 of a defense filing (Document 97) dated December 14, 2020, in the case United States v. Ghislaine Maxwell. The defense argues that the government only pursued Maxwell as an 'afterthought' following Jeffrey Epstein's death in custody, noting that subpoenas for her financial records were not issued until August 16, 2019 (six days after his death). The text contends there is a lack of documentary corroboration for the charges, characterizing the case as relying on 25-year-old witness testimony, and urges the court to grant bail.
DOJ-OGR-00002004.jpg
This document is page 32 of a defense filing (Document 97) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The text argues that Maxwell is not a flight risk due to intense media scrutiny, the global pandemic, and her willingness to sign irrevocable extradition waivers for the UK and France. It cites legal precedent (US v. Cirillo) supporting the use of extradition waivers as a condition for release.
DOJ-OGR-00001993.jpg
This document is a page from a legal filing (Motion for Bail) arguing that Ghislaine Maxwell has now provided a thorough review of her finances for the years 2015-2020, addressing previous court concerns. Defense counsel retained UK accounting firm Macalvins to analyze bank statements, tax returns, and FBAR filings for Maxwell and her spouse. This report was further validated by a redacted former IRS Special Agent with 40 years of experience in financial fraud.
DOJ-OGR-00002013.jpg
This document is page 35 (filed as page 41 of 45) of a legal motion arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a flight risk and that her current detention at the MDC amounts to 'de facto solitary confinement' under conditions more severe than supermax prisons or death row, which impedes her ability to prepare her defense. The text cites legal precedent regarding bail standards and claims wardens have never seen such restrictive regulations.
DOJ-OGR-00001999.jpg
This page from a legal filing (Case 1:20-cr-00330-AJN, filed Dec 14, 2020) argues that Ghislaine Maxwell has been subjected to unprecedented pre-trial publicity. It includes a bar graph titled 'All U.S. Media Coverage Comparison' demonstrating that in the 90 days following her July 2020 arrest, Maxwell received more national media mentions (over 6,000 articles) than Harvey Weinstein, Bill Cosby, El Chapo, and Keith Raniere combined. The top portion of the document contains redacted text referencing Ex. A.
Events with shared participants
The Court announced a 15-minute morning break for the jury.
2022-08-10
A discussion took place regarding the order of witnesses for the day's trial proceedings.
2022-08-10 • courthouse
The defense at trial focused on the credibility of victims who testified against the defendant.
Date unknown
The jury selection process where Juror 50 gave answers that corroborated his hearing testimony.
Date unknown
The Government gave on-the-record assurances to the Court regarding investigative files.
2020-07-14
A discussion between attorneys and the court regarding how to respond to a jury note.
2022-08-10 • Courtroom
Filing of Document 172-1 in Case 1:20-cr-00330-AJN
2021-03-23 • US District Court
Defense team investigators compiled dossiers on victims.
Date unknown • Not specified
A status conference originally scheduled for January 14, 2021, was adjourned to March 17, 2021, at 1:00 p.m. The conference is to be conducted remotely via videoconferencing software.
2021-03-17 • Remote (videoconference)
Court proceeding regarding witness strategy in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE).
2022-08-10 • Courtroom
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