Event Details

This document is a 'Fact Witness Travel Request' submitted to the SDNY Victim/Witness Unit on November 19, 2021, regarding the case United States v. Ghislaine Maxwell. It requests travel arrangements for a domestic witness who is explicitly identified as a 'Victim-Witness' to appear for trial and trial preparation. The witness's identity and specific travel dates are redacted, but the form confirms they reside within the continental United States and require a hotel.

This document is the final page (18 of 18) of a Protective Order filed on August 4, 2020, in case 1:19-cr-00333-AJN (associated with the Ghislaine Maxwell prosecution). It stipulates that the order does not restrict the use of confidential information during the actual trial and that the Court reserves the right to modify the order. The document bears a Bates stamp DOJ-OGR-00002400.

This document is the Table of Contents for a legal filing (Document 397) in Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on October 29, 2021. The filing argues for the admissibility of testimony from expert witness Dr. Lisa Rocchio regarding abuse dynamics and from 'Minor Victim-3.' It also argues for the admission of evidence from an October 11, 2021 Government letter and co-conspirator statements at trial.

This is page 38 of a heavily redacted court filing from Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on October 29, 2021. The text argues for the admissibility of certain exhibits as direct evidence of the defendant's intent, motive, and charged crimes, or alternatively under Rule 404(b)(2). Footnotes reference a Government letter from October 11, 2021, regarding the identification of parties in emails.

This document is the Table of Contents (page 'i') for a legal filing (Document 600) in the case against Ghislaine Maxwell, filed on February 11, 2022. The filing outlines arguments to vacate Maxwell's convictions on Mann Act counts due to variances from the indictment, consolidate conspiracy counts because they are multiplicitous, and dismiss the indictment due to pre-indictment delay. It references specific evidence types including flight records, passenger manifests, and financial documents.

This is the final page (16) of a court order issued by US District Judge Martha Vazquez on February 6, 2021. The order grants Mr. Robertson's motion for immediate release (Doc 274) to allow him to prepare for an upcoming trial with his defense team, citing the need for preparation time and potential quarantine at 'La Pasada.' The judge simultaneously denies the government's emergency motion to stay the release order.

This is a page from a legal filing (likely a renewed bail application) for Ghislaine Maxwell, dated February 23, 2021. The defense argues that new bond conditions secure her assets to prevent flight, cites twelve pretrial motions filed by January 25 that challenge the government's case, and claims she has been unfairly demonized by the media as a 'substitute replacement' for Jeffrey Epstein. The document asserts Maxwell's determination to face her accusers at trial.

This document is the 'Conclusion' section of a legal filing (likely an appeal brief) dated April 19, 2021, arguing for the release of Ghislaine Maxwell. The defense contends that Maxwell is not a flight risk, that the government's case is weak and based on 'old, anonymous accusations,' and that she cannot prepare for trial under her current 'appalling' prison conditions. The text heavily criticizes the government for relying on the specter of Jeffrey Epstein to justify her detention without a proper adversarial hearing.

This document is page 21 of a legal opinion from Case 22-1426 (United States v. Maxwell), dated September 17, 2024. The text discusses the legal concept of 'constructive amendment' regarding the indictment, specifically analyzing 'Jane's testimony' and a 'jury note' related to Count Four. The appellate court agrees with the District Court's handling of the jury instructions and determines that the core of criminality was properly maintained.

This is a page from a legal filing (Case 1:20-cr-00330-AJN) dated March 23, 2021, arguing for the release of Ghislaine Maxwell on bail. The text argues that Maxwell's offer to renounce her French and British citizenship negates the flight risk concerns regarding extradition protection in France. It cites a Mr. Julié to interpret French Article 696-4, asserting that one who loses French nationality is not protected from extradition.

This document is page 22 of a legal filing (Case 1:20-cr-00330-PAE) dated October 29, 2021, likely from the prosecution in the Ghislaine Maxwell trial. It argues for the admissibility of expert testimony by Dr. Rocchio regarding 'coercion and attachment in abusive relationships' and 'grooming,' refuting defense arguments based on Rule 403 and the 'Burns' case precedent. The text asserts that such testimony aids the jury in understanding psychological factors without being prejudicial.

This document is page 64 of a legal filing (Document 382) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. The defense argues against government motions to exclude evidence regarding Maxwell's 'charitable works' and 'family history,' suggesting these may become relevant if the government opens those topics. Section X argues strongly against the government's request to preview the defense's evidence, using the metaphor of having 'hands tied behind their back and their mouths duct-taped,' while noting that accusers are testifying under anonymity.

This is page 3 of a Government legal filing (Case 1:20-cr-00330-AJN) dated October 20, 2020. The Government argues that certain materials requested by the defense are not relevant under Rule 16 because the charges are strictly limited to conduct between 1994 and 1997, and do not allege Maxwell acted as a 'madam' generally. The Government proposes disclosing the disputed materials (approx. 40 pages) eight weeks prior to trial, citing 'United States v. Coppa' to support that immediate disclosure is not required for 'Brady' material.

This page is from a court order in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court addresses discovery disputes, specifically ruling that the Government's agreement to produce 'Giglio' and 'Jencks Act' materials six weeks prior to trial is sufficient for Maxwell to prepare, noting the Court lacks authority to force earlier disclosure of Jencks material. The Court also denies Maxwell's request for a pretrial hearing regarding the admissibility of co-conspirator statements, opting instead for conditional admission at trial.

This document is the conclusion page of a legal motion filed on March 16, 2021, requesting bail for Ghislaine Maxwell. It lists her defense team (Sternheim, Everdell, Pagliuca, Menninger) and includes a significant footnote detailing complaints about her confinement at the MDC. Specifically, the footnote alleges violations of attorney-client privilege during video conferences due to guard proximity and audio recording, as well as a denial of legal calls regarding pretrial motions.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely US v. Ghislaine Maxwell) featuring the direct examination of a witness named Brune. The testimony details the composition of the legal defense team, identifying specific partners and associates (Edelstein, Hollander, Kim, Stapp) and their respective office locations (San Francisco and New York). It also mentions communications regarding issues during jury selection.

This document is a court ruling from April 1, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court rejects the Defendant's argument that 'Juror 50' was biased for failing to follow instructions during the jury questionnaire phase. The Court accepts Juror 50's testimony that while he was distracted (thinking about his ex) during the questionnaire, he was fully attentive and compliant during voir dire and the actual trial.

This document is Page 5 of a Protective Order filed on July 30, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It outlines strict protocols prohibiting the Defense team and potential witnesses from publicly disclosing the identities of victims or witnesses found in discovery materials, mandating that such references in court filings be made under seal.

This document is the Table of Contents for a legal filing (Document 384) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The filing outlines the Defense's arguments that the Government failed to identify co-conspirator statements and overwhelmed the defense with document dumps, violating court orders. The Defense argues this hinders cross-examination and requests the preclusion of these purported statements as a remedy.

This document is a page from a Government legal filing (dated Oct 29, 2021) in the case against Ghislaine Maxwell. The Government rebuts defense accusations regarding discovery violations, stating they provided co-conspirator statements 'unusually early' (seven weeks before trial). Additionally, the Government argues against suppressing the identification of the defendant by 'Minor Victim-4,' asserting that the victim knew the defendant personally for decades.

This document is a concordance (word index) page from a court transcript dated February 15, 2012, for the case 'United States of America v. Paul M. Daugerdas, et al.' (Case 1:20-cv-03088-PAE, Document 646-20). While filed within a docket often associated with Ghislaine Maxwell (1:20-cv-03088 is Giuffre v. Maxwell), the document itself pertains to the Daugerdas tax fraud case, likely serving as a legal precedent or exhibit. The index lists occurrences of words starting with 'T' (testify, Theresa, Trzaskoma, trial, truth, etc.) and their corresponding page/line numbers in the full transcript.

This document is page 54 of a Government sentencing submission in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on June 22, 2022. The text argues for the imposition of a maximum $750,000 fine, notes that no forfeiture is sought due to a lack of identified property owned by the defendant used in the offense, and states that no restitution is sought because the six identified victims (Jane, Annie, Kate, Carolyn, Virginia, and Melissa) have already been compensated via the Epstein Victim Compensation Fund or civil settlements.