Relationship Details

This document is a Public Policy Law360 email newsletter dated July 20, 2021, summarizing various legal and policy news stories. Crucially, it includes a report that Ghislaine Maxwell owes the New York State Tax Department nearly $1.6 million, identifying her as a former associate of Jeffrey Epstein. Other topics include the confirmation of Tiffany Cunningham as a Federal Circuit judge, a potential $30M fine for Robinhood, and various other legislative and judicial updates.

This document is an email dated June 25, 2020, from an Assistant United States Attorney in the Southern District of New York to a redacted recipient. The email discusses the imminent presentation of an indictment against Ghislaine Maxwell to a grand jury in White Plains on the following Monday. The sender apologizes for the short notice regarding the review of the indictment document.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Carolyn by Ms. Comey. The testimony focuses on the logistics of scheduling massage appointments at Jeffrey Epstein's house. Carolyn testifies that for the first year or two, Ghislaine Maxwell would call to schedule appointments, after which Sarah Kellen or Carolyn herself would handle the scheduling. Carolyn also notes that even after Sarah took over scheduling, Maxwell was still seen at Epstein's house, specifically in an office area off the kitchen.

FBI FD-302 notes from a July 2019 interview with a victim who met Jeffrey Epstein at age 17 through her sister. She details traveling with Epstein to New York, Florida, New Mexico, Paris, and the Virgin Islands, describing a 'mind control' environment where Epstein paid for her life while subjecting her to sexual assaults, including rape. The document includes descriptions of numerous photographs provided by the victim showing Epstein in various locations with different individuals, including Ghislaine Maxwell and Jean Luc.

This document is a Grand Jury Presentation from June 2020 in the case US v. Ghislaine Maxwell. It compiles evidence including photographs of Epstein's properties, flight logs from 1994-1998 showing Maxwell and others traveling with Epstein, records of a donation to Interlochen Arts Camp, and excerpts from Maxwell's 2016 deposition where she denies knowledge of underage recruitment or sexual misconduct. The flight logs notably list prominent figures such as Senator George Mitchell and Bill Richardson.

This document is an email chain from December 2020 between Sigrid McCawley (Boies Schiller Flexner) and an Assistant US Attorney (likely Maureen Comey) regarding the filing of a victim impact statement. The chain includes the full text of the statement from an unnamed victim opposing Ghislaine Maxwell's release on bail, describing Maxwell as a 'psychopath' who groomed and abused the victim as a child and procured victims for Jeffrey Epstein. The correspondence coordinates the formatting and timing of filing this statement as an exhibit to the government's opposition to bail.

This document is a subpoena issued by Ghislaine Maxwell's defense team in November 2021, commanding the production of records from the Epstein Victims' Compensation Program (EVCP). The subpoena seeks all materials submitted by accusers, communications between the EVCP and accusers, records of payments, and executed releases. Attached to the subpoena is the 'Protocol' for the EVCP dated May 29, 2020, which outlines the independent program's purpose, eligibility requirements, claims administration process, and confidentiality rules for compensating victims of Jeffrey Epstein.

An internal Department of Justice email dated November 9, 2021, from the Deputy Chief of the Child Exploitation and Obscenity Section to colleagues (including USANYS). The email forwards 'citizen correspondence' referencing Jeffrey Epstein and Ghislaine Maxwell for consideration, noting that the sender will advise the citizen to contact the FBI.

An email dated August 15, 2019, from a Public Affairs officer at the U.S. Attorney's Office for the Southern District of New York (SDNY) to a redacted recipient. The email, with the subject 'Found her!', shares a New York Post article reporting that Ghislaine Maxwell was spotted at an In-N-Out Burger shortly after Jeffrey Epstein's death.

This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that due to 'tsunami' of negative pretrial publicity surrounding Maxwell and Jeffrey Epstein (including books, podcasts, and documentaries), standard jury selection is insufficient. They request the Court allow individual sequestered voir dire and limited attorney-conducted questioning to identify and remove biased jurors.

A sworn statement dated November 25, 2020, by a former UK Special Forces security consultant who provided protection for Ghislaine Maxwell from July 2019 until her arrest. The document details the events of the arrest on July 2, 2020, in Bradford, NH, from the perspective of the on-site security operative, who initially mistook FBI agents for the press. The consultant affirms their company's intent to post a $1 million bond for Maxwell's bail, expressing confidence she will not flee.

A witness statement dated November 25, 2020, from the head of Sparta Security Services (likely Matt Hellyer based on context/signature) supporting Ghislaine Maxwell's bail application. The document details the security protocols in place and narrates the events of Maxwell's arrest on July 2, 2020, in Bradford, NH, from the perspective of the on-site security operative who initially mistook the FBI raid for press intrusion. Sparta Security Services pledges a $1 million bond, citing confidence that Maxwell will not flee.

This document is a discovery request letter from Ghislaine Maxwell's defense counsel, Cohen & Gresser LLP, to the US Attorney's Office for the Southern District of New York, dated October 13, 2020. The defense requests a wide range of materials including exculpatory Brady evidence, information on Minor Victims 1-3, communications regarding Jeffrey Epstein's 2007 Non-Prosecution Agreement, and records of coordination between the government and civil attorneys representing Epstein's accusers. The letter also requests specific FBI files, unredacted reports, and evidence related to the credibility and potential financial motives of government witnesses.

Memorandum Opinion & Order by Judge Alison J. Nathan in U.S. v. Ghislaine Maxwell, dated July 30, 2020. The Court ruled in favor of the Government regarding a protective order, denying Maxwell's request to publicly name victims who had previously spoken to the media and denying her request to restrict witnesses from using discovery materials for purposes other than trial preparation.

This document is an email chain between SDNY prosecutors and FBI support staff (DocLab) regarding the digitization of physical evidence files for the Jeffrey Epstein investigation. The correspondence spans from June 2019 to October 2020, covering the shipment of approximately 23 boxes of evidence (Case files 72-MM-113327 and 31E-MM-108062) for scanning. Key details include the refusal to scan 'pornographic images of young girls' due to FBI protocols, the retrieval of missing evidence items ('1As') from digital backups, and a 2020 follow-up ensuring all materials were correctly processed for discovery in the Ghislaine Maxwell case.

This document is page 12 of a legal filing (dated Dec 14, 2020) arguing for Ghislaine Maxwell's release on bail. The text argues that Maxwell has been subjected to unprecedented negative media coverage (more than Weinstein or El Chapo) but remains committed to fighting the charges in the US rather than fleeing. It emphasizes her strong ties to her spouse (whose name is redacted) and argues that continued detention under 'oppressive conditions' impairs her ability to prepare her defense.

This document is a court docket sheet from late July 2020 detailing filings in the case of USA v. Ghislaine Maxwell. It records a dispute regarding a protective order, where the defense sought to allow Maxwell to publicly name victims who had already spoken publicly about her or Jeffrey Epstein. Judge Alison Nathan ruled in favor of the Government, adopting their proposed protective order to restrict Maxwell from disseminating the identities of alleged victims or witnesses to protect their privacy.

This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 21, 2020. It outlines the production of various evidentiary materials, including Boies Schiller documents, emails, search warrant photos, Jeffrey Epstein's deposition recordings (2010), travel records, and SORNA records. The letter explicitly notes that 'highly confidential' materials containing sexualized images are being provided only to counsel, not the defendant, and refuses to produce a separate FBI obstruction file regarding a redacted former employee of Epstein deemed irrelevant to the case.

This document is a compilation of 'SDNY News Clips' from March 9, 2020, summarizing major legal news relevant to the Southern District of New York. Key stories include Prince Andrew's refusal to cooperate in the Epstein investigation, the transfer of the MCC jail captain following Epstein's suicide, a massive horse racing doping indictment involving high-profile trainers, the hung jury in the Joshua Schulte CIA leak trial, and internal DOJ conflicts between U.S. Attorney Geoffrey Berman and Attorney General William Barr. It also touches on Harvey Weinstein's injury in jail and new court restrictions due to the emerging Coronavirus outbreak. No flight logs were present in the document.

This document is an email thread dated October 13, 2020, forwarding a daily press clipping report from the Southern District of New York (SDNY). The report lists various news articles, highlighting a section specifically for 'MAXWELL' which includes links to stories about Ghislaine Maxwell's legal case, photos, and Jeffrey Epstein's financial activities and associations (including Leon Black). The email sender flags these articles for the recipient's interest.

This document is a chain of emails between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office regarding discovery disputes. Key issues include the logistics of providing electronic discovery to Maxwell in prison (MDC) because she cannot use disks, missing email attachments, and metadata discrepancies for thousands of files and photos recovered from Epstein's devices and residences. The prosecution explains that 'carved' or deleted files lack original metadata and that certain photos came from seized CDs rather than devices processed by the FBI's CART unit.

This document contains a chain of email correspondence between Ghislaine Maxwell's defense team (Menninger, Everdell) and the US Attorney's Office (SDNY) regarding the logistics of reviewing evidence for case 20 Cr. 330. The discussions focus on scheduling physical evidence reviews at an FBI warehouse in the Bronx and electronic evidence reviews at the 500 Pearl Street courthouse. Key evidence items discussed include massage tables, plaster busts, cash, shredded paper, and thousands of 'highly confidential' nude or partially nude images seized from Jeffrey Epstein's devices and residences.

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.

Judge Loretta Preska denied Ghislaine Maxwell's request to reconsider the unsealing of her deposition transcripts, ruling that her recent arrest was not a valid new ground for reconsideration as she had failed to raise it during the weeks prior to the court's original decision. The court noted that the potential for criminal charges had already been weighed in the original unsealing order. A short stay was granted until August 3, 2020, to allow Maxwell to appeal to the Court of Appeals before the documents are released.

This document is an email chain from July/August 2020 discussing the unsealing of Ghislaine Maxwell's deposition in litigation overseen by Judge Preska. The participants discuss ongoing legal disputes ('fighting') with attorney Boies and concerns regarding victim confidentiality, specifically noting that a redacted individual (who had previously spoken to the press about being approached by Epstein and Maxwell) is named in the documents.

This document is a legal response filed on June 24, 2020, by Intervenors Julie Brown and the Miami Herald Media Co. arguing against Ghislaine Maxwell's objections to unsealing specific court documents (Dkt. Entries 143, 164, 172, 199, and 230). The Intervenors argue that Maxwell's privacy claims are unsubstantiated and do not outweigh the public interest in disclosure, particularly regarding allegations of sex trafficking and abuse of minors. The filing explicitly mentions that the documents in question include a 'Flight Log Summary Chart' and 'flight logs', police reports, and deposition transcripts, arguing that these should be made public.

This document is an internal email chain from June 2020 involving an Assistant US Attorney in the SDNY preparing for a Grand Jury presentation. The attorney requests the creation of presentation slides featuring specific excerpts from Ghislaine Maxwell's deposition transcripts (denying knowledge of underage recruitment and massages) and specific flight records from dates between 1994 and 1998.

This document is a letter motion dated November 25, 2020, from Ghislaine Maxwell's defense counsel (Cohen & Gresser LLP) to Judge Alison J. Nathan. The defense requests an in camera conference and permission to file a renewed bail motion under seal to protect the identities of family and friends acting as sureties, citing severe harassment and death threats (including social media examples). The letter mentions a financial report by Macalvins Limited. Judge Nathan endorsed the letter on the same day, stating she saw no basis for sealing the letter itself and ordered the defense to justify the sealing request by December 2, 2020.

This document is a legal memorandum filed by Ghislaine Maxwell's defense team arguing against the government's motion for detention and requesting release on bail. The defense argues that the COVID-19 pandemic poses a severe health risk and impedes defense preparation, and asserts that Maxwell is not a flight risk, citing her presence in the U.S. since Epstein's arrest. They propose a $5 million bond secured by UK property and strict conditions including home confinement and GPS monitoring.

Memorandum Opinion & Order in United States v. Ghislaine Maxwell (20-CR-330) dated July 30, 2020. Judge Alison J. Nathan ruled on a dispute regarding a protective order, siding with the Government to restrict Maxwell from publicly referencing alleged victims/witnesses who haven't spoken on the record in this specific case, and denying Maxwell's request to restrict witnesses from using discovery materials for other purposes.

This document is a legal memorandum submitted on February 23, 2021, supporting Ghislaine Maxwell's third motion for release on bail in the SDNY. Maxwell proposes two new conditions to assure her appearance: formally renouncing her French and British citizenships to prevent flight to those countries, and placing all assets (except legal fees and living expenses) into a new account monitored by retired Judge William S. Duffey, Jr. The defense argues these unprecedented conditions, combined with her strong ties to the US, negate flight risk and claims she is being unfairly treated as a substitute for Jeffrey Epstein.

This document is an email chain from July and August 2021 between the US Attorney's Office (SDNY) and the FedEx Legal Department. The US Attorney's Office is requesting shipping records and a records custodian to testify for the upcoming trial of Ghislaine Maxwell. FedEx confirms they provided a spreadsheet of shipments from 2007-2020 but notes their IT team cannot retrieve data prior to 2007.

This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on December 18, 2020, in support of her renewed motion for bail. The defense argues that the government lacks significant documentary evidence, relies solely on witness testimony from decades ago, and that Maxwell has strong ties to the U.S. through her spouse (whose name is redacted) and friends who have pledged assets. The document also addresses flight risk concerns, arguing that extradition from France or the UK is possible or unlikely to be needed due to waivers, and cites a COVID-19 surge at the detention center as further justification for release.

A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team responding to a discovery request. The Government declines to produce broad FOIA-related documents citing lack of legal basis under Rule 16, but provides specific materials related to Radar Online and FBI-NY's involvement in the SDFL investigation as a courtesy. The letter also corrects a defense assertion regarding the FBI Florida office's role in the prosecution team.

This document is a FedEx invoice dated October 27, 2003, billed to Jeffrey E. Epstein for a total of $594.99. It details various shipments made between October 14 and October 23, 2003. Key individuals involved include Ghislaine Maxwell (sending and receiving packages, specifically at the Peninsula Hotel), Larry Visoski (sending a package), and Henry Rosovsky (receiving a package). A significant entry involves a third-party shipment referencing Epstein's aircraft, tail number N908JE, sent between aviation service companies in Florida.

This document contains an email chain from July 27, 2020, between the prosecution (Southern District of New York) and the defense team in the case United States v. Maxwell. The correspondence concerns scheduling a 'meet and confer' regarding a protective order, specifically addressing the Government's concerns about the defendant potentially naming victims of Jeffrey Epstein or Ghislaine Maxwell in public filings. The Government also requests a 1 terabyte hard drive from the defense to facilitate the production of discovery materials.

This document is an 11-page Government Exhibit Index from the United States v. Ghislaine Maxwell trial, dated November 23, 2021. It lists hundreds of exhibits including physical evidence (massage tables, hard drives), photographs of victims and properties (Palm Beach, NY, Zorro Ranch, Little St. James), financial records (JPMC), and school records. Notably, the index lists two flight logbooks (GX-661 and GX-662) covering 1991 to 2013, though the specific flight details are not contained within this index document itself.

This document contains handwritten FBI/law enforcement interview notes from a witness (likely a former assistant/scheduler) and photocopies of phone message pads found at Epstein's properties. The witness describes the daily routine of scheduling massages, recruiting girls (including a specific code '2x8' for teenage girls from Jean-Luc), travel logistics to various properties (NY, Palm Beach, Virgin Islands), and specific interactions with high-profile individuals like Prince Andrew and Alan Dershowitz. The notes detail the witness's observations of sexual acts, payment procedures involving cash, the presence of guns, and Ghislaine Maxwell's role in managing the household and recruiting.

This document is an email chain between the US Attorney's Office (SDNY) and a CBP Task Force Officer regarding the retrieval of travel records for the Maxwell/Epstein case. The correspondence, dated late 2021, details specific inbound travel dates for Jeffrey Epstein and Ghislaine Maxwell between 1997 and 2000, noting that outbound records were not recorded during that era. It also includes a request for travel records for an unidentified French woman.

This document is a corrected motion for joinder in a legal case, filed on January 2, 2015, by Jane Doe #3 and Jane Doe #4, seeking to join an existing lawsuit against the United States. The motion details allegations of sexual abuse and sex trafficking by Jeffrey Epstein and Ghislaine Maxwell against Jane Doe #3, including forced sexual relations with Alan Dershowitz, and argues that the new victims' circumstances are relevant to the court's assessment of their joinder.

This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 12, 2021. It serves as notice that the Government intends to introduce evidence showing Maxwell provided other men with access to women, in addition to her conduct with Epstein. The letter also discloses a redacted witness who worked for Epstein in 2005-2006 and will testify about scheduling sexualized massages with underage girls.

An email from an Assistant U.S. Attorney in the Southern District of New York to Ghislaine Maxwell's defense team (Everdell, Cohen, Pagliuca, Menninger) dated July 27, 2020. The prosecution requests a 'meet and confer' to discuss a protective order, specifically challenging the defense's desire to name victims in public filings rather than using pseudonyms. The email also requests a 1 terabyte hard drive to facilitate the production of discovery materials.

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.

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.

This document is a page from a government legal filing in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated February 25, 2022. The text argues against the defense's claims regarding missing witnesses (Sally Markham, Fontanilla) and disputes the origin of the 'household manual' (Gov Ex 606), citing email evidence (Gov Ex 424) that proves Maxwell was involved in its creation alongside Markham, rather than it being solely the work of 'the Countess.' The prosecution asserts that the absence of these witnesses did not prejudice the defendant's ability to defend herself or impact the facts of the abuse.

This document is page 2 of a Daily Beast article from July 2010 detailing the operations of Jeffrey Epstein's sex trafficking ring. It discusses the complicity of his staff (Kellen, Ross, Groff, Marcinkova, and Maxwell), the settlements paid to victims, and the testimony of house manager Alfredo Rodriguez regarding police corruption and the daily operations of the abuse. It also highlights Epstein's financial ties to the Palm Beach Police Department and his alleged racketeering partnership with modeling agent Jean Luc Brunel.

This document is a Plaintiff's Notice of Serving Second Amended Answers to Interrogatories in a 2009 civil case against Jeffrey Epstein in the Southern District of Florida. The plaintiff, whose name is redacted, details her residence history and her interactions with Epstein between 2002 and 2003, stating she visited his Florida home roughly twice a week to provide massages after being introduced by a friend. The document reveals she recruited other females for Epstein in exchange for payment, used drugs (Morning Glory, Angel Trumpets, cocaine, marijuana) during the relevant period, and lists various legal counsel and law enforcement entities involved in the investigation.

Email correspondence from September 30, 2020, between defense attorney Christian Everdell and the US Attorney's Office (SDNY). Everdell requests access to roughly 40,000 non-nude images seized from Jeffrey Epstein's residences in New York and the Virgin Islands for his client, Ghislaine Maxwell, to review at the MDC. The AUSA responds that they are coordinating with the FBI to transport a laptop with the files to the detention center, though the large volume of files requires a few days for processing.

This document is a Government Exhibit Index from the trial United States v. Ghislaine Maxwell, dated October 28, 2021. It lists hundreds of exhibits including physical evidence (massage tables, contact books), photographs of victims and properties (Palm Beach, NY, Island), flight logs, financial records, and emails. The index organizes these exhibits by series numbers, providing descriptions, Bates ranges, and production dates for each item.

This document is an email from Geoffrey Berman (USANYS) dated January 8, 2020. It contains a quote from one of Epstein's victims stating that Ghislaine Maxwell and another redacted individual coached her on how to sexually please Jeffrey Epstein.

This document contains an email chain between Ghislaine Maxwell's attorney, Bobbi Sternheim, and BOP/MDC officials from January 2021. Sternheim asserts that Maxwell is being targeted, physically mistreated (specifically alleging a guard squeezed her breast during a search), and denied proper food (receiving rotting fruit and meat despite a non-flesh diet). The correspondence references Jeffrey Epstein's death in custody as a reason for heightened concern regarding Maxwell's safety and requests the removal of the current guard team.

This document is a Bloomberg newsletter from July 7, 2020. It covers various news items including PPP loan controversies, COVID-19 updates, and market news. Significantly, it reports that Ghislaine Maxwell, described as a former Jeffrey Epstein associate, has arrived in New York and is scheduled for a plea hearing on July 14 via videoconference.

This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The Government argues for the entry of its proposed protective order regarding discovery materials, specifically opposing the defendant's request to publicly name victims who have previously spoken to the media and opposing restrictions on the Government's use of its own investigative materials. The document includes the full text of the proposed protective order, detailing how 'Confidential' and 'Highly Confidential' information (including sexualized imagery) must be handled by the defense.

A hostile letter from Jeffrey Epstein to Vanity Fair journalist Vicky Ward, responding to her inquiries for an article. Epstein disputes ownership of a specific property (#11), addresses transfer taxes for another (#9), and aggressively attempts to discredit a female accuser (name redacted) who stayed at his Ohio property in 1996. He alleges the accuser committed financial misdeeds and theft, citing a State Trooper as a witness, and argues her claims of feeling 'uncomfortable' are a cover for her misconduct.

This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 8, 2020, refuting claims that the government failed to meet discovery obligations. The letter details technical efforts to ensure Maxwell can review digital evidence at the MDC, including the provision of a secure laptop to review 43,500 images seized from Jeffrey Epstein's properties (3,500 of which contain nudity). It also addresses conditions of confinement, confirming Maxwell remains in an isolation cell for safety, undergoes weekly body scans, and has access to commissary food items.

This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 8, 2020. The government asserts it has met its discovery obligations despite technical issues at the MDC, detailing efforts to reformat files and provide IT support. The letter also addresses Maxwell's conditions of confinement, confirming she must sleep in an isolation cell and undergo weekly body scans, while noting she has access to commissary food, mail, and 13 hours of discovery review time per day. It mentions the FBI possesses 43,500 images from Epstein's residences (3,500 containing nudity) which will be made available for review via a secure laptop brought to the MDC.

This document contains a series of email exchanges between Ghislaine Maxwell's defense team (led by Laura Menninger) and the US Attorney's Office regarding the logistics of reviewing discovery evidence in March and April 2021. The correspondence details disputes over the location of the review (FBI Bronx Warehouse vs. 500 Pearl Street courthouse), specifically concerning 'bulky' items such as massage tables, plaster busts, and framed art which the government refused to transport. Significant discussion focuses on the protocols for reviewing 'Highly Confidential' materials, including approximately 2,100 nude or obscene electronic images seized from Jeffrey Epstein's devices, which required specific viewing conditions on non-networked laptops due to their nature.

A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated October 20, 2020, serving as a cover letter for a discovery production. The production includes various materials such as FBI documents from Florida and NY, PBPD materials, and videos, listed with Bates numbers. The letter also addresses the status of data extracted from electronic devices seized from Jeffrey Epstein's properties, noting that privilege reviews are ongoing and that the Epstein Estate has not waived privilege.

This document is a discovery production letter from the DOJ to Ghislaine Maxwell's defense team, dated August 5, 2021. It lists materials being turned over, including files recovered from discs seized at Jeffrey Epstein's New York residence, images from his electronic devices, Missouri records, a JPMorgan Chase return, and a 1995 Oxford letter. The letter also clarifies confidentiality designations under the Protective Order.

This document is an email chain between the FBI (Child Exploitation/Human Trafficking division) and the FAA's Law Enforcement Assistance Program (LEAP) regarding an investigation into Ghislaine Maxwell. The FBI requested flight and registration information for several aircraft associated with Maxwell and Jeffrey Epstein, specifically noting helicopters she piloted (nicknamed 'Air Ghislaine 1' and '2') and jets she flew on as a passenger. The FAA agent provided attached flight plans (Excel files, not visible in text) and detailed registration histories for aircraft N722JE and N331JE, along with ownership details involving Hyperion Air LLC.

A 2020 travel questionnaire for an AUSA from the Southern District of New York requesting travel to Stockholm, Sweden. The purpose was to interview a Swedish witness ('Jane Doe') regarding the ongoing and sensitive investigation into Jeffrey Epstein and Ghislaine Maxwell. The traveler was accompanied by three other AUSAs and one FBI Special Agent.

This is an email from former prosecutor Peter Brightbill to a redacted recipient (likely a federal prosecutor), dated July 2, 2020. Brightbill congratulates the team on Ghislaine Maxwell's indictment but warns that the MCC is insecure, explicitly stating his belief that Jeffrey Epstein's death was a homicide. He urges the prosecution to ensure Maxwell is monitored 24/7 by Federal Marshals to prevent a similar outcome.

This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser LLP) and the US Attorney's Office (USANYS). The defense raises several technical discovery issues, including the inability of Maxwell to read discovery disks on the prison computer, missing email attachments, and corrupted metadata on files extracted from Jeffrey Epstein's devices (showing 2020 dates instead of original dates). The prosecution forwards these issues to their contractor (PAE) to address.

This document is an email chain from July 2020 between the U.S. Attorney's Office for the Southern District of New York (USANYS) and the Office of the Deputy Attorney General (ODAG). The Chief of the Public Corruption Unit at USANYS reached out to the Associate Deputy Attorney General to discuss document and discovery requests related to the Southern District of Florida (SDFL) investigation and the Non-Prosecution Agreement (NPA), specifically in light of the recent charges against Ghislaine Maxwell. The ODAG official advised contacting SDFL directly as CVRA litigation had concluded and noted that the Office of Professional Responsibility (OPR) had conducted a significant document collection the previous year.

This document is a Reply Memorandum filed by Ghislaine Maxwell in the United States District Court, Southern District of New York, requesting the suppression of evidence obtained from a government subpoena to Boies Schiller and dismissal of counts five and six. It includes a Table of Contents, Table of Authorities citing various legal cases and rules, and a Table of Exhibits detailing communications and notes related to the case from 2016 to 2021, many involving AUSAs and individuals like Peter Skinner, Stan Pottinger, Brad Edwards, and Sigrid McCawley. The memorandum argues that the government misled the court and that the evidence should be suppressed due to due process violations.

This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts 1-4 of the superseding indictment. The defense argues that the indictment lacks specificity regarding names, dates, and details of the allegations, preventing Maxwell from preparing an adequate defense. The filing criticizes the government for using vague categories like 'Minor Victims' and 'multiple minor girls' without clarification and cites legal precedents to argue that the lack of specificity violates due process.

This document is an email thread from February 10, 2020, between Assistant U.S. Attorneys regarding the Epstein/Maxwell investigation. The discussion focuses on managing concerns from witnesses' counsel regarding confidentiality following public comments made about Prince Andrew on January 27. The emails mention that two potential witnesses who worked for Maxwell/Epstein have expressed willingness to be interviewed, while another witness has already met with prosecutors multiple times. There is also a reference to reviewing depositions related to Ghislaine Maxwell.

This document is a 5-page U.S. Customs and Border Protection TECS Person Encounter List for Ghislaine Maxwell, generated on January 16, 2020. It details 58 travel encounters between December 1990 and December 1999, primarily listing arrivals into the United States at airports including JFK, Miami, and Newark, as well as the U.S. Virgin Islands (Cyril E King Airport). The records include commercial flights (British Airways, Air France, American Airlines) and private aviation, specifically noting a flight on August 14, 1999, with carrier code 'PV' and number '908JE', corresponding to Jeffrey Epstein's aircraft N908JE.

This document is a legal memorandum filed by Ghislaine Maxwell's defense team on January 25, 2021, seeking to suppress evidence obtained via subpoena from the law firm Boies Schiller Flexner. The defense argues that the government made false representations to Judge McMahon to bypass a civil protective order and obtain confidential deposition transcripts, alleging collusion between the civil plaintiff's lawyers (Boies Schiller) and federal prosecutors. The document details the history of the civil defamation case, specific deposition questions regarding sexual acts and Epstein, and the procedural history of the protective order modification.

This document is an email chain from September 2019 between an Assistant US Attorney (SDNY) and another party regarding the Epstein investigation. They discuss logistics for an upcoming interview on October 11th, checking seized photos for date stamps, and ensuring specific individuals are in the Victim Notification System (VNS). Significantly, there is a request for a summary analysis of Ghislaine Maxwell's flight records to check for overlaps, with the AUSA noting that available manifests from the 'previous case' might only cover international flights and may not extend back to the 1990s.

This document is a formal response from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 22 specific discovery requests made on October 13, 2020. The government addresses requests for Epstein's diary, the 'Billionaires Playboy Club' manuscript, flight logs (implied in broader requests but not itemized), and the identities of minor victims, often denying immediate production based on Rule 16 restrictions or asserting that materials have already been produced. The letter also discusses the handling of potential 'Brady' and 'Giglio' materials, stating that impeachment evidence will be produced closer to trial.

This document is an email chain between the US Attorney's Office (SDNY) and Ghislaine Maxwell's defense counsel (Cohen & Gresser LLP) regarding discovery disputes in early 2021. The correspondence details logistical issues with providing Maxwell access to 4TB hard drives at the MDC, disputes over unredacted FBI reports from 2006 found on Jeffrey Epstein's devices, and missing metadata/Bates ranges. The defense specifically notes missing 'flight logs' from a redacted provider and questions the unsealing of a search warrant affidavit referenced in a Daily Beast article. No actual flight data is contained in the document, only a reference to missing logs.

An internal email chain from July 2, 2020, involving an Assistant U.S. Attorney from the Southern District of New York (SDNY). The email discusses the media breaking the story of Ghislaine Maxwell's arrest, specifically noting that reporter Tom Winter 'per usual' has a 'great source at FBI'. A link to an NBC New York article confirming the arrest is included.

This document is page 17 of a defense sentencing memorandum filed on June 15, 2022, in the case against Ghislaine Maxwell. The defense argues against the application of sentencing guideline § 4B1.5 ('Repeat and Dangerous' sex offenders), asserting that Maxwell has not committed crimes in nearly 20 years, is not attracted to minors, and acted only as a facilitator for Epstein's impulses rather than having them herself. The text contrasts her behavior with case law examples of violent repeat offenders and highlights her subsequent crime-free life involved with partners who had children.

An email chain from September 17, 2020, likely between government officials or legal counsel. One party asks about a rumor from a reporter that Ghislaine Maxwell possesses videos of Alan Dershowitz and other high-profile figures recorded by Epstein to use as leverage in negotiations. The recipient responds sarcastically, dismissing the claim by joking they also have videos of Clinton in 'the Library,' to which the original sender replies with amusement.

This document is an email chain between an Assistant United States Attorney (SDNY) and a DOJ Attaché at the U.S. Embassy in Paris. The correspondence spans from July 2020 to December 2020 and concerns the prosecution of Ghislaine Maxwell, specifically addressing her renewed bail application and legal questions regarding the extradition of dual US/French citizens from France.

This document contains court testimony from a witness named Kate regarding an encounter with Jeffrey Epstein and Ghislaine Maxwell at Maxwell's house. Kate describes massaging Epstein's shoulders, receiving approval from him, and overhearing a conversation about a music producer before Epstein received a phone call. Following the interruption, Maxwell ushered Kate out of the house, and the witness confirms that she heard from Maxwell again after this event.

This document contains notes from a conference call on November 25, 2020, between the US Attorney's Office (SDNY) and Ghislaine Maxwell's defense counsel (Sternheim and Everdell). The discussion focuses on Maxwell's conditions of confinement at the MDC, specifically complaints regarding excessive surveillance (cameras, sleep checks every 15 minutes), invasive strip searches, and isolation compared to General Population inmates. Defense counsel explicitly links the extreme surveillance measures to the government's fear of a repeat of the Jeffrey Epstein suicide incident.

This document is an email chain from August 2020 between the SDNY, FBI, and NYPD regarding the discovery process for the Ghislaine Maxwell case. The correspondence details requests for specific evidence, including 'trash pulls', message pad scans, FBI Sentinel files, CART reports, and search warrant returns from New York, the Virgin Islands, and New Hampshire. The FBI notes they are actively working to segregate and log nude/semi-nude images from the seized digital evidence before production.

An email chain between redacted USANYS officials from February 11, 2021, discussing media inquiries (specifically from Bloomberg) regarding a Law360 article titled '3 Names To Watch As Biden Mulls Next SDNY Top Prosecutor'. The forwarded article discusses potential successors to U.S. Attorney Audrey Strauss, explicitly mentioning her office's prosecution of Jeffrey Epstein associate Ghislaine Maxwell as a significant recent high-profile case. The article profiles candidates Damian Williams, Katherine Goldstein, and Anjan Sahni.

This document is an email sent on December 6, 2019, by a Detective from the NYPD/FBI Child Exploitation Human Trafficking Task Force. The email shares a link to a New York Post article titled 'Scott Borgerson denies he's dating Jeffrey Epstein pal Ghislaine Maxwell.' The sender and recipient names and contact details are redacted.

This document is an email chain from February and March 2020 between the SDNY Assistant United States Attorney and the NYPD/FBI Child Exploitation Human Trafficking Task Force regarding the investigation into Ghislaine Maxwell ('GM'). The AUSA requests specific actions, including reviewing message pads seized from Jeffrey Epstein's residence, tracing financial transfers from Epstein to Maxwell since 2005, verifying her UK and French citizenship, and checking for property ownership. The Task Force responds with updates on TECS border system alerts (noting she hit the system three times in the past month) and negative results from property searches.

This document is an email chain from February and March 2020 between the SDNY US Attorney's Office and the NYPD/FBI Child Exploitation Human Trafficking Task Force regarding the Ghislaine Maxwell investigation. The correspondence coordinates investigative steps, including reviewing seized message pads from Epstein's residence, tracing financial transfers from Epstein to Maxwell since 2005, and verifying her citizenship and assets. It also discusses operational security regarding the TECS border system, noting that running Maxwell's name triggers alerts at JFK and that she had 'hit' the system three times in the preceding month.

This document is an email chain detailing the ongoing review of image and video files from Jeffrey Epstein's devices by FBI and USAO teams in October 2020. It outlines the review protocol, device assignments, and the need for reviewers to access case materials, including a warrant, affidavit, and the Maxwell indictment. The emails also coordinate calls and set a deadline for completing the review of ten assigned devices.

This document is an email chain between investigators discussing aircraft associated with Ghislaine Maxwell and Jeffrey Epstein. It details the registration history, ownership changes, and specifications for several aircraft, specifically helicopters N722JE ('Air Ghislaine 2') and N331JE, and mentions jets N212JE, N120JE, N909JE, and N908JE. The correspondence confirms Maxwell personally piloted the helicopters and was a frequent passenger on Epstein's jets, and investigators are seeking passenger manifests and inquiring about a potential pilot named Van Heurck.

This document contains a chain of emails from October 2020 between FBI and USAO personnel regarding the forensic review of image and video files extracted from Jeffrey Epstein's electronic devices. The correspondence outlines a review protocol, assigns specific device IDs (e.g., NYC024363) to team members via the CAIR system, and references the Ghislaine Maxwell indictment. The most recent email confirms that the review of two specific Windows devices yielded negative results for images and videos.

This document is an email chain from October 2020 coordinating a joint FBI and USAO review of image and video files found on ten digital devices belonging to Jeffrey Epstein. The emails discuss setting up access to the CAIR system, distributing specific devices (labeled with codes such as NYC024363 and categorized by source like 'Safe' or 'MAC') to the FBI team, and reviewing protocols, warrants, and the Ghislaine Maxwell indictment. A deadline for the review was set for the following Friday.

This document contains an email thread and a Notice of Electronic Filing from June 2024 regarding the case Radar Online LLC v. Federal Bureau of Investigation. The correspondence confirms that Judge Paul G. Gardephe granted the FBI's motion for summary judgment, allowing the FBI to withhold Jeffrey Epstein's investigative file under FOIA Exemption 7(A) due to the ongoing Ghislaine Maxwell prosecution. The case was subsequently closed.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely United States v. Ghislaine Maxwell) filed on August 10, 2022. Defense attorney Mr. Everdell argues against the admissibility or weight of photographs taken during a 2005 walk-through of an Epstein residence, noting that witness Juan Alessi left in 2002 and witness 'Jane' only gave general descriptions of art, not specific identifications of the photos in question. The defense contends there is no testimony placing specific photos on the wall during the time relevant to the case.

This document contains a series of invoices and handwritten notes from a house manager (likely named Paula) for Jeffrey Epstein's West Palm Beach property between 2003 and 2005. The records detail hours worked, payments received (including cash from Ghislaine Maxwell), and coordination of maintenance, staff, and guests. Notable details include instructions to schedule repairs when Epstein and Maxwell are not present, ground transport to Jet Aviation, and specific mentions of Maxwell's desk and requirements.

This legal document, page 7 of a court filing, argues against the disclosure of Ghislaine Maxwell's grand jury materials. The author contends that the current 'immense public interest' in the Epstein and Maxwell cases is mere public curiosity about an ongoing case and does not meet the standard of historical importance that justified disclosure in past cases like the Hiss espionage case or the 'In re Biaggi' case. The document distinguishes the current request from precedents where materials were released decades later, after witnesses had died, or when the subject of the testimony themselves requested the release.

This document is a court transcript from a direct examination of a witness named Rodgers, filed on August 10, 2022. The testimony focuses on two flights, 573 and 574, that occurred in 1994. The witness confirms that Jeffrey Epstein was a passenger on flight 573, and that both Jeffrey Epstein and Ghislaine Maxwell were passengers on flight 574 from Traverse City, Michigan, to Teterboro, New Jersey, on August 20, 1994.

This document is page 4 of a legal filing (Document 134 in Case 1:20-cr-00330-AJN), filed on February 4, 2021. The page is a table of authorities, citing two newspaper articles, a federal rule of civil procedure, and a constitutional amendment. The articles reference a 1980 piece by Norman Mailer and a 2020 report that Manhattan federal prosecutors declined to pursue a case against Jeffrey Epstein and Ghislaine Maxwell in 2016.

This document is page 10 of a legal filing related to the case against Ghislaine Maxwell, dated April 12, 2021. It details Judge Nathan's findings that Maxwell remains a significant flight risk due to her extraordinary financial resources, multiple foreign citizenships, and lack of employment. The text notes that despite letters of support and offers to waive extradition rights, the court found the risk of flight fundamentally unchanged and the case against her strong.

This document is an evidence photo showing a handwritten letter addressed to Ghislaine [Maxwell] and two photographs of Jeffrey Epstein and Ghislaine Maxwell. The letter, from a redacted sender, discusses a 'birthday letter' written for Jeffrey and provides photos of the Parachute Jump and Wonder Wheel (Coney Island) for inclusion in a book Ghislaine was apparently compiling about Jeffrey's life. The sender alludes to Jeffrey's childhood neighborhood and the 'many different people' he has encountered.

A photograph (Bates stamp EFTA00003848) depicting Jeffrey Epstein, Jean-Luc Brunel, and Ghislaine Maxwell socializing inside the cabin of a private aircraft. Epstein is dressed casually in a hoodie, while Brunel wears a yellow sweater and patterned pants.

A photograph showing a man (likely Jeffrey Epstein) and a woman (likely Ghislaine Maxwell) from behind, standing on a cobblestone street. They are watching a marching band in red and blue uniforms playing drums. The location is clearly identifiable as 'Le Gorille' cafe, likely in Saint-Tropez, France, supported by the 'Vilebrequin' brand label on the man's shirt, a brand associated with that location. The document bears the Bates stamp EFTA00003187.

This document is a Plaintiff's response to interrogatories in a civil case against the Estate of Jeffrey Epstein. It lists specific interactions Jane Doe had with Epstein's associates between 1994 and 1999, identifying Ghislaine Maxwell, Juan Alessi, Darren Indyke, Adam Perry Lang, Lesley Groff, Mark Epstein, and Sarah Kellen. The response details roles these individuals played, ranging from facilitating abuse and meetings to providing transportation and making threatening financial demands.

The document consists of two versions of the same photograph (one clear, one pixelated) bearing Bates stamps EFTA00003571 and EFTA00003572. The image depicts Ghislaine Maxwell and Jeffrey Epstein seated at an outdoor dining table, likely on Little St. James, with a third unidentified person partially visible.

This document is a Palm Beach Police evidence file (Case #05-368) containing a 'Green Folder' seized from Jeffrey Epstein's residence. The contents include a detailed household manual listing staff, contractors, vehicle procedures, and standing orders for aircraft (N909JE, N908JE, and Maxwell's plane). It also contains financial records from late 2004 to early 2005, including bank statements from Colonial Bank showing large incoming wire transfers ($10,000 each) and significant cash withdrawals by Epstein and staff. Handwritten notes detail household repairs, a purchase of a shed, and personal requests such as delivering roses to a high school.

This document collection from September 19-20, 2005, includes correspondence regarding real estate in Cambridge, MA, and NYC, as well as a significant fax from JPMorgan Chase advising Epstein that a 'deal is not going to work' and to move his money. It also contains various handwritten notes on Epstein and Maxwell stationery referencing flight logistics ('Jet A', 'Lauderdale'), a 'Clinton Guest List', 'gun holsters', and scheduling for 'Sandy Berger'. The documents establish Epstein's presence in Palm Beach at the time while managing affairs in Boston and New York.

This document is a Grand Jury exhibit (GX-2) from the US v. Ghislaine Maxwell case, dated June 29, 2020. It compiles evidence including photos of Epstein properties, extensive flight logs from 1994-1998 documenting travel by Epstein, Maxwell, and various associates (including 'Space', Glen Dubin, and Clair Hazell) on aircraft N908JE and N988JE. It includes correspondence regarding a $200,000 donation to Interlochen Arts Camp and transcripts from Maxwell's 2016 deposition where she denies knowledge of underage recruitment, sex toys, or giving massages.

This document is a page from the SDNY court docket for the case USA v. Ghislaine Maxwell, dated April 16, 2021. It lists filings including the Government's opposition to various defense motions to dismiss and suppress evidence, an order by Judge Alison J. Nathan regarding the unsealing of reply briefs, and a defense reply memorandum. The document also references the underlying indictment charging Maxwell with facilitating Jeffrey Epstein's sexual abuse of minors between 1994 and 1997.

Transcript of a Grand Jury proceeding on July 8, 2020, in the Southern District of New York. The Assistant U.S. Attorney presented a superseding indictment against Ghislaine Maxwell to correct clerical errors in perjury counts (Counts 5 and 6), specifically fixing the docket number of a civil case from 15 Civ. 7344 to 15 Civ. 7433. The proceeding included voir dire of jurors regarding their knowledge of Maxwell and Epstein, but no new evidence or witnesses were presented.

A photograph depicting Ghislaine Maxwell and Jeffrey Epstein sitting at a polished wooden table in an interior setting with heavy gold curtains. Maxwell is in the foreground wearing a bright floral jacket and looking down, while Epstein sits in the background wearing a silver patterned shirt. A tube of Bengay cream is visible standing on the table in the foreground.

An email chain from July 2020 in which a citizen named Caolan Hogeweide writes to the US Attorney's Office (USANYS) expressing fear that Ghislaine Maxwell will be killed in jail to prevent her from talking, similar to Jeffrey Epstein. The email suggests involvement by intelligence agencies or powerful individuals and urges 24-hour supervision. The email was then forwarded internally within the USANYS office.

This document is page 7 of a defense motion filed on July 10, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a danger to the community (unlike Epstein), that COVID-19 poses a severe health risk in detention hindering her defense, and that she is not a flight risk due to her U.S. citizenship and lack of criminal record. It asserts she stayed in the U.S. and maintained contact with the government after Epstein's arrest rather than fleeing.

This document is a legal filing in the civil case Jane Doe 1000 v. Indyke & Kahn. It includes a letter from Plaintiff's counsel arguing that the Epstein Estate executors are improperly limiting discovery to a 4-year period and refusing to produce documents regarding Epstein's broader sex-trafficking conspiracy. Attached as Exhibit A are the Defendants' supplemental responses to interrogatories, which list specific employees (including Ghislaine Maxwell, Sarah Kellen, and pilots like Larry Visoski), email accounts used by Epstein (specifically noting 'jeevacation@gmail.com' and 'jeeproject@yahoo.com'), and numerous phone numbers associated with his properties in New York, Palm Beach, New Mexico, and the Virgin Islands.

This document is a page from a court transcript (SA-455), likely from Ghislaine Maxwell's sentencing hearing, filed as part of an appeal in June 2023. The speaker (Maxwell) addresses the court and the victims, stating that Jeffrey Epstein should have been the one facing justice for his crimes in 2005, 2009, and 2019. She apologizes to the victims for their pain and expresses hope that her conviction and 'harsh and unusual incarceration' will provide them with closure and peace.

This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.

This document is a letter from Alan Dershowitz's legal counsel to Judge Naomi Reice Buchwald requesting a pre-motion conference to intervene in the civil case 'Maria Farmer v. Estate of Jeffrey Epstein'. Dershowitz seeks to strike paragraph 39 of Farmer's complaint, which alleges she saw him at Epstein's New York mansion going upstairs with young girls brought by Ghislaine Maxwell. Dershowitz argues this allegation is demonstrably false based on chronology (claiming he didn't meet Epstein until after Farmer left) and is legally irrelevant to the estate case, serving only to defame him.

This document is a legal filing from May 2020 in the case of Teresa Helm v. The Estate of Jeffrey Epstein. It contains a letter from the Plaintiff's counsel arguing that the Estate Executors are obstructing discovery by limiting it to a narrow time window in 2002 and refusing to answer questions fully. The attached Exhibit A contains the Defendants' supplemental responses to interrogatories, in which they identify specific staff members (including Ghislaine Maxwell, Sarah Kellen, and Lesley Groff) who worked at Epstein's New York home during late 2002, list various email accounts and phone numbers associated with Epstein, and identify Shoppers Travel, Inc. as his travel agency. No specific flight logs or aircraft manifests are included in the document.

This document is a Plaintiff's Response to Defendant Jeffrey Epstein's Motion to Quash Service of Process. The plaintiff, M.J., argues that service was properly effected on October 8, 2010, when a private investigator handed the papers to an employee named 'Mark' at Epstein's New York mansion. The filing accuses Epstein and his associate Richard Barnett of fraud and perjury for submitting an affidavit claiming service never occurred, and details a pattern of obstruction by Epstein and his associates (including Ghislaine Maxwell and Jean Luc Brunel) in similar civil cases.

This affidavit by attorney Bradley Edwards details difficulties in discovery for a civil case against Jeffrey Epstein (Case 10-81111). It alleges that key witnesses Ghislaine Maxwell and Jean Luc Brunel evaded depositions by falsely claiming to be out of the country. Crucially, it lists specific individuals for whom Epstein paid legal fees to prevent them from testifying against him, explicitly labeling Sarah Kellen as a 'procurer of girls' and Nadia Marcinkova as a 'live-in sex slave', while also identifying his personal pilots and household staff.

This Palm Beach Police incident report from 2006 details an investigation into aggressive surveillance by private investigators hired by Jeffrey Epstein or his legal team. It documents a specific incident where a subject was run off the road by a PI in a green Chevy. The report also analyzes phone records showing a pattern where an individual (suspect) called a victim for intimidation purposes, and immediately afterward communicated with Epstein's assistant and a corporate number registered to Epstein's business address at 457 Madison Ave.

This document is a Government Memorandum filed on July 29, 2025, in the Southern District of New York, responding to Court Orders regarding the unsealing of grand jury transcripts in the Jeffrey Epstein and Ghislaine Maxwell cases. The Government supports the disclosure of these transcripts due to significant public interest, noting that Epstein is deceased and Maxwell is incarcerated, but requests redactions to protect victim identities. The memo analyzes the 'In re Craig' factors for unsealing grand jury records and confirms that the key law enforcement witnesses are still active.

This document is a compilation of legal filings from late 2020 to early 2021 concerning Ghislaine Maxwell's repeated attempts to secure release on bail pending her trial for sex trafficking conspiracy. It includes the Government's opposition detailing her flight risk, wealth, and foreign ties (specifically to France and the UK), a victim statement from Annie Farmer, correspondence from the French Ministry of Justice confirming they do not extradite nationals, and Judge Nathan's orders denying bail. The documents highlight Maxwell's offer to renounce her foreign citizenships and pledge significant assets, all of which the Court found insufficient to assure her appearance.

This document is a heavily redacted version of Jeffrey Epstein's 'Black Book' (contact list) from approximately 2004-2005. It contains an alphabetical listing of high-profile individuals, politicians, celebrities, and business associates, along with sections for specific locations (Palm Beach, NY, Paris, etc.) and services (Massage, Medical, Aviation). The final page contains significant handwritten notes identifying key witnesses, staff members (chefs, drivers), and specific allegations regarding the procurement of women ('Scout for young females') and interactions with underage girls.

This document is a transcript of a proffer interview with Ghislaine Maxwell conducted by the DOJ and FBI on July 25, 2025. Maxwell discusses her relationship with Jeffrey Epstein, denies participating in or witnessing sexual abuse of minors, and details her interactions with high-profile figures like Bill Clinton and Elon Musk. She addresses financial transactions, flight logs, and specific allegations regarding recruitment of women for Epstein.

This document is an email dated June 22, 2020, with the subject 'GM in Paris?'. The body contains a single link to an article from The Sun regarding Ghislaine Maxwell potentially hiding in a flat in Paris. The sender and recipients of the email have been redacted.

This document is an email thread from July 3, 2020, involving a US DOJ Attaché in London. The emails discuss the UK media reaction to the arrest of Ghislaine Maxwell, specifically focusing on the implications for Prince Andrew. The sender notes it is 'weird' that a redacted individual reached out to them right before the arrest occurred.

This document is an email chain from October 2020 between FBI and USAO personnel coordinating the forensic review of image and video files from Jeffrey Epstein's electronic devices. The correspondence outlines the 'Epstein Image/Video File Review Protocol,' assigns specific device IDs (e.g., NYC024334, NYC024355) to reviewers, and sets a deadline for completion. It references attachments including search warrants and the Ghislaine Maxwell superseding indictment.

This document is an excerpt from a book (likely by James Patterson, based on the header) describing journalist Vicky Ward's experience covering Jeffrey Epstein for Vanity Fair in October 2002. It details how Epstein mobilized high-profile friends like Jimmy Cayne (Bear Stearns) and Les Wexner to call Ward, and how Epstein personally tried to charm her with a tour of his Manhattan mansion. The text also notes Ghislaine Maxwell's role in teaching Epstein social etiquette.

This document is an internal email thread among Assistant United States Attorneys for the Southern District of New York (SDNY) dated October 18, 2021, regarding the Ghislaine Maxwell trial. The prosecutors discuss revisions to Motions in Limine (MILs) and letters to Judge Nathan, specifically strategizing on how to address a witness's prior limited media comments about Epstein versus their expected court testimony, and the need to seal claims of 'Maxwell abuse' to prevent tainting the jury pool.

This document is an internal email from the U.S. Attorney's Office for the Southern District of New York (Public Affairs) dated January 2, 2020. The sender flags a Page Six article and mentions an NBC rumor that Ghislaine Maxwell is hiding in Colorado with wealthy ex-associates of Jeffrey Epstein.

An email chain between legal professionals discussing ongoing litigation involving Jeffrey Epstein and Ghislaine Maxwell. The correspondence references a meeting held on February 29, 2016, where documents including a defamation complaint against Maxwell, CVRA case filings, and a 'redacted 302' (FBI interview) were shared. A later email in the chain from March 8, 2016, highlights a NY Post article about Epstein's continued relationships with young women.

This document is an email chain from October 2021 involving an FBI Forensic Accountant and USANYS personnel. They discuss the compilation and upload of financial documents related to Jeffrey Epstein, specifically focusing on accounts where Ghislaine Maxwell was a signer (Hyperion Air, JEGE, NES LLC) and memos requesting her removal from these accounts.

This document is a calendar entry record for a conference call scheduled for July 23, 2020. The subject of the meeting was 'Call on Epstein/Maxwell Documents,' indicating a discussion regarding records related to Jeffrey Epstein and Ghislaine Maxwell. The attendee's name has been redacted.

This document is a legal letter dated December 27, 2021, from defense attorney Christian R. Everdell to Judge Alison J. Nathan during the trial of United States v. Ghislaine Maxwell. The defense requests additional jury instructions to clarify 'apparent errors' in the jury's understanding of Count Four, specifically regarding whether aiding in a return flight (rather than the flight to the location of sexual activity, such as New Mexico) constitutes guilt. The letter references a specific jury note (Court Exhibit #15) and cites the indictment regarding transportation from Florida to New York for sexual acts with Jeffrey Epstein.

This document is an internal DOJ/FBI email thread from July 31, 2020, discussing a media inquiry from the Daily Mail. The journalist is seeking comment on allegations found in newly unsealed court documents that Prince Andrew and Alan Dershowitz pressured the DOJ to grant Jeffrey Epstein a favorable plea deal in 2007. DOJ officials note internally that they do not possess the specific civil filing referenced and mention that 'Main' (Main Justice) is asking about it.

This document is a page from a legal filing (Defense Motion) dated December 14, 2020, arguing that Ghislaine Maxwell is not a flight risk. It cites a letter from her spouse (whose name is redacted) describing their quiet domestic life in the U.S. and her character as 'wonderful and loving.' The text argues against the government's claim that she lived a 'transient' lifestyle and notes the impact of Jeffrey Epstein's 2019 arrest and death on her family.

This Reuters news article, dated January 5, 2022, reports on the jury deliberations in the Ghislaine Maxwell sex abuse trial. A juror, Scotty David, revealed that some jurors initially doubted the credibility of two accusers, Jane and Carolyn. David explained that he shared his own experience of childhood sexual abuse to help the other jurors understand the nature of memory and trauma, which ultimately swayed them and led to a unanimous guilty verdict on December 29, 2021.

This document is an email chain from October 19, 2020, between the Southern District of New York (USAO) and likely the FBI. The emails discuss the distribution of a review protocol for image and video files retrieved from Jeffrey Epstein's electronic devices. Ten specific device identification numbers (starting with NYC) are listed for immediate FBI review. The correspondence also mentions the attachment of the Maxwell indictment and plans for a conference call once document copies are processed.

This document is an email chain from October 2021 between an FBI Forensic Accountant and likely a prosecutor from the US Attorney's Office (USANYS). The correspondence concerns the compilation and review of documents related to Jeffrey Epstein's financial accounts, specifically noting that Ghislaine Maxwell was a signer on these accounts. The requestor asks for subsequent account statements to analyze balances.

This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office. Defense attorney Christian Everdell outlines seven specific technical issues regarding discovery production, including the inability of Maxwell to view files on prison computers, missing email attachments, and corrupted metadata on over 110,000 documents extracted from Jeffrey Epstein's devices. The prosecution team discusses internally setting up a call with their vendor, PAE, to address these errors.

This document is a media advisory from the U.S. Attorney's Office for the Southern District of New York dated July 1, 2020. It announces a press conference to be held that day regarding charges against Ghislaine Maxwell for her involvement in Jeffrey Epstein's sexual exploitation of minors. The advisory lists speakers including Acting U.S. Attorney Audrey Strauss and an FBI official whose name is redacted, noting that COVID-19 protocols will be in place.

Defense counsel Christian Everdell writes to Judge Alison Nathan opposing the government's request to delay the disclosure of evidence (photographs and documents) regarding alleged victims of Jeffrey Epstein. The defense argues these materials are exculpatory under Brady because they relate to post-1997 allegations where witnesses do not implicate Maxwell, thereby supporting her defense against perjury charges that she was unaware of Epstein's abuse. The letter also argues the government has failed to show 'good cause' under Rule 16 to delay this discovery.

This document is an email chain from October 2020 detailing the forensic review protocol for digital devices seized in the Jeffrey Epstein investigation. The correspondence involves FBI and USAO teams coordinating the review of 10 specific devices (labeled with NYC prefixes) for images and video files, using a system referred to as CAIR. The most recent email confirms that two specific devices (NYC027908 and a Siemens image) were reviewed and found to be 'negative' for images and videos. The chain also references the Ghislaine Maxwell indictment.

This document is an email chain from February 2021 between the US Attorney's Office (SDNY) and the FBI/NYPD Child Exploitation Human Trafficking Task Force regarding the Ghislaine Maxwell investigation. The correspondence details the limitations of obtaining historical records from Victoria's Secret (limited to 2 years) and FedEx (1-5 years). Additionally, the emails discuss a search for specific photos and a request to coordinate with ALAT (Legal Attaché) to obtain UK travel records for both Maxwell and Jeffrey Epstein.

This document consists of two slides from a Department of Justice/FBI presentation titled 'U.S. v. Ghislaine Maxwell'. The slides serve as a public outreach tool seeking potential victims, listing the locations where alleged abuse occurred (New York, Florida, New Mexico, London) and displaying photos of Epstein's properties. It provides the FBI hotline number for individuals who recognize Maxwell or Epstein and believe they may be victims.

Internal FBI email chain from March and August 2020 discussing the investigation into Deutsche Bank's relationship with Jeffrey Epstein. Agents discuss the engagement and upcoming proffer of Paul Morris (Epstein's relationship manager), alleging the bank knew Epstein was moving money for women but justified it by claiming ignorance of their ages. The emails also mention plans to interview Epstein's attorney regarding structured transactions designed to avoid Suspicious Activity Reports (SARs) and potential questioning of Ghislaine Maxwell.

This document is a transcript of a direct examination of a witness named Rodgers. The witness confirms that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts, along with one other passenger, were on two flights: one from Luton, England to Bangor, Maine, and another on March 11, 2001, from Bangor, Maine to Teterboro, New Jersey. The transcript also references a record entry for an unnamed female on March 8, 2001.

An email chain involving US Attorney Geoffrey Berman dated April 15, 2020, discussing a New York Times 'The Daily' podcast transcript. The transcript details an account by a victim describing how Ghislaine Maxwell pressured her into a massage, exposed her breasts, and massaged her chest, while the victim felt Jeffrey Epstein was watching nearby.

An internal email chain within the US Attorney's Office for the Southern District of New York (USANYS) dated November 4, 2021. An employee forwards a Law360 news alert to a colleague with the comment 'Seriously?'. The news alert details a letter from Ghislaine Maxwell's attorney comparing her prison conditions to those of the fictional character Hannibal Lecter in 'Silence of the Lambs'.

This legal filing (Page 14 of a defense motion) argues against joining 'Perjury Counts' with 'Mann Act Counts' in the trial of Ghislaine Maxwell. The defense asserts that joining the charges would cause prejudice by introducing uncharged allegations from 1999-2002 involving Virginia Giuffre. The document emphasizes that a previous Palm Beach Police investigation interviewed over 30 victims who did not implicate Maxwell, and notes that the 2019 indictment charged Epstein alone.

This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) dated July 28, 2020, addressed to Judge Alison J. Nathan. The Government argues against the defense counsel's request to publicly name victims who have self-identified in the media or public fora, contrasting this with the narrower 'Epstein protective order.' The Government asserts that victims of Ghislaine Maxwell and Jeffrey Epstein should be protected from having their identities broadcast by the defense, citing the Crime Victims' Rights Act and privacy concerns.

This document is a page from the court testimony of a witness named Alessi (likely Juan Alessi) filed in August 2022. The testimony focuses on the year 1994 at Jeffrey Epstein's Palm Beach house, detailing the presence of 'Jane' (a guest), Ghislaine Maxwell, Emmy Tayler, and Gwendolyn Beck. The witness describes a routine where Epstein, Maxwell, Emmy Tayler, and guests would go to the movies almost every night.

This document is a flight log for February and March 2002, primarily for the Boeing 727 with tail number N908JE, which was associated with Jeffrey Epstein. The log, signed by pilot David Rodgers, details numerous domestic and international flights with a variety of high-profile passengers, including Bill Clinton, Naomi Campbell, Glen Dubin, Jeffrey Epstein, and Ghislaine Maxwell. The log also includes records of several simulator training sessions for the pilots.

This document is an email from the US Attorney's Office (SDNY) circulating a Rolling Stone article from July 2019 detailing Ghislaine Maxwell's background and connection to Jeffrey Epstein following his arrest. The article outlines her history as Robert Maxwell's daughter, her role in New York society, and specific allegations from victims (names redacted) regarding her role in procuring underage girls for Epstein and facilitating abuse involving figures like Alan Dershowitz. It mentions her presence at Mar-a-Lago and Chelsea Clinton's wedding, as well as her denial of all allegations.

This document consists of two slides from the U.S. v. Ghislaine Maxwell case, likely used for victim outreach or public information. It outlines the charges against Maxwell regarding the facilitation of sexual abuse for Jeffrey Epstein and lists the specific locations where the alleged conduct occurred: New York, Palm Beach, Santa Fe, and London. It provides photos of Epstein's properties in these locations and includes a call to action for potential victims to contact the FBI.

This Palm Beach Police Department incident report from April 20, 2006, details two interviews related to an investigation of Jeffrey Epstein. The first interview is with a woman named Eaton, who describes an uncomfortable massage experience where Epstein entered the room and applied pressure to her back. The second part, dated January 31, 2006, documents a telephone interview with Christina Venero, a licensed massage therapist employed by Epstein for three years, who discusses her professional relationship with Epstein and his associate Ghislaine Maxwell, her payment, and her observations of the other women at his house.

This document is an email sent on March 18, 2020, containing a link to a New York Times article titled 'Jeffrey Epstein’s Ex, Ghislaine Maxwell, Sues His Estate for Legal Fees'. The sender and recipient identities are redacted. The email appears to be a forwarded news alert or information sharing regarding ongoing litigation involving Maxwell and the Epstein estate.

This document is a page from a court transcript dated February 28, 2023, likely from the appeal of Ghislaine Maxwell (Case 22-1426). Defense counsel (Mr. Everdell) argues that evidence of money moving to buy a helicopter does not prove the defendant's continued criminal involvement, comparing it to pilot Larry Visoski holding assets for Epstein without being a co-conspirator. The prosecution (Ms. Moe) counters that the financial evidence was introduced to refute the claim that the defendant had 'moved on' from her association with Epstein.

An email chain from August 29, 2019, involving detectives from the NYPD/FBI Child Exploitation Human Trafficking Task Force. The correspondence discusses 'Epstein related Safetnets' and specifically lists Ghislaine Maxwell alongside redacted numbers or identifiers.

This document is a handwritten flight log page for a Gulfstream II (N908JE) covering the period from August 13, 1995, to September 21, 1995. The log details 19 flights piloted by David Rodgers (and occasionally Jim Worden), primarily shuttling between West Palm Beach (PBI), Teterboro (TEB), Martha's Vineyard (MVY), Columbus (CMH), and Aspen (ASE). A notable entry on August 13, 1995, lists Donald Trump and Eric Trump as passengers traveling with Jeffrey Epstein (JE) and Ghislaine Maxwell (GM) from PBI to TEB.

This document is an internal email chain within the U.S. Attorney's Office for the Southern District of New York (SDNY) dated August 13, 2020. It discusses a filing deadline regarding a defense motion to move Ghislaine Maxwell to general population or improve her detention conditions. The Chief Public Information Officer highlights that 'Main (OPA)' is keenly interested in the filing because of the Attorney General's previous response to Jeffrey Epstein's suicide and current pressure from Congressional Republicans regarding Maxwell's safety.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness named Meder. During the testimony, a prosecutor, Ms. Comey, introduces a photograph (Government Exhibit 320) which the witness identifies as depicting Jeffrey Epstein and Ghislaine Maxwell, stating it came from a CD reviewed during the "Epstein and Maxwell investigation." The court admits the photograph into evidence.

This document is an AT&T Wireless billing statement for Jeffrey E. Epstein & Co. dated August 14, 2003, covering the period of July 13 to August 12, 2003. The bill notably includes a line item for 'G. Maxwell' (Ghislaine Maxwell), indicating she was on Epstein's phone plan. The detailed call logs track extensive international travel during this month, placing the phone user(s) in Great Britain, France, Italy, and St. Thomas (USVI), as well as domestic locations including New York, Palm Beach, and Bangor, Maine.

This document is a legal filing by the Government opposing defense motions in the case against Ghislaine Maxwell. It primarily addresses Count Six (perjury), arguing that Maxwell's answers in a July 2016 deposition regarding 'sexual activities,' 'sex toys,' and 'massages' were false and not fundamentally ambiguous. The document also addresses and rejects defense requests for discovery regarding a victim's personal diary from 1996 and broad subpoenas for defendant's records.

Defense counsel for Ghislaine Maxwell requests the Court to order the government to disclose the identities of three alleged victims referenced in the indictment to allow for effective investigation of allegations from 25 years ago. Additionally, the defense requests that Maxwell be moved to the general population at the MDC and given increased computer access to review discovery, arguing her current isolation and surveillance are punitive reactions to Jeffrey Epstein's suicide in BOP custody.

This document is a formal discovery letter from the US Attorney's Office (SDNY) to the defense counsel for Ghislaine Maxwell, dated August 5, 2020. It lists a comprehensive index of evidence provided to the defense, including financial records from multiple banks (Citibank, Chase, TD Bank, etc.), travel records (flight manifests and airline records), email account records (Oath, Microsoft, Google), and corporate filings (USVI, Delaware). While the document *lists* the existence of flight manifests and financial records, it is an index only and does not contain the specific content (flight paths, transaction amounts) within the document itself.

This document is an internal email from the U.S. Attorney's Office (USANYS) dated October 27, 2020, discussing discovery materials for the Ghislaine Maxwell ('GM') case. The email proposes disclosing a specific statement from a 2005 Palm Beach PD interview with 'Witness-1' (represented by Rita Glavin), who stated Epstein paid her to recruit girls for massages, preferring them 'younger the better' and rejecting a girl over 18 as 'too old'.

This page from a legal filing dated July 21, 2020, addressed to Judge Alison J. Nathan, argues that government officials (Ms. Strauss and FBI Agent William Sweeney) and private attorneys (David Boies, Sigrid McCawley, and Bradley Edwards) made prohibited, prejudicial public statements regarding Ghislaine Maxwell. The document cites specific quotes comparing Maxwell to a 'snake' and 'villain,' as well as speculation about her potential cooperation with prosecutors to implicate other 'wealthy and influential people.' The filing asserts these comments violate Local Rule 23.1.

This document is a chain of emails between Ghislaine Maxwell's defense counsel, Laura Menninger, and the US Attorney's Office (SDNY) regarding the logistics of reviewing physical and electronic evidence. The discussion focuses on arranging a secure location (500 Pearl Street) for Maxwell and her team to review 'highly confidential' materials, including thousands of images seized from Jeffrey Epstein's devices and residences, as well as physical evidence stored in an FBI warehouse. The defense raises concerns about access to laptops, the ability to compare physical and electronic evidence, and the specific handling of sensitive materials.

This document is a court transcript from a hearing on August 10, 2022, related to case 1:20-cr-00330-PAE. During the direct examination of a witness named Meder, a photograph showing Ghislaine Maxwell and Jeffrey Epstein is identified and admitted into evidence as Exhibit GX-342. The photo originated from a CD logged as '1B63' from the 'Epstein and Maxwell investigation'.

This document is a transcript of a conversation between Ghislaine Maxwell and Todd Blanche. Maxwell discusses her observations of Jeffrey Epstein's masseuses, stating she never saw anyone unhappy, and Blanche connects this to the 'blackmail issue.' They also discuss Epstein's clients, with President Clinton being mentioned in that context, though Maxwell denies explicitly stating he was a client.

This document is an email chain between Ghislaine Maxwell's defense team and the US Attorney's Office (SDNY) regarding the logistics of reviewing discovery evidence in March and April 2021. The discussions concern protocols for viewing 'highly confidential' materials, including nude images and physical evidence (such as massage tables and plaster busts) seized from Jeffrey Epstein's properties. The parties negotiate the location of the review (FBI Bronx warehouse vs. 500 Pearl Street courthouse), the presence of the defendant, and the use of electronic devices by defense counsel during the review.

A photograph taken inside a private aircraft showing three individuals. In the foreground, a woman strongly resembling Ghislaine Maxwell is conversing with a man strongly resembling Jean-Luc Brunel. Jeffrey Epstein is visible in the background seat. The document is marked with the ID EFTA00003846.

This document is a series of emails between the US Attorney's Office (SDNY) and the FBI/NYPD Child Exploitation Human Trafficking Task Force regarding the discovery process for the Ghislaine Maxwell case in August 2020. The correspondence details requests for specific evidence, including Grand Jury transcripts, search warrant returns (NH premises), FBI Sentinel files, and scans of message pads (both with and without post-it notes). The FBI agent confirms the availability of files from New York, Virgin Islands, and Florida, and discusses the logistical challenge of filtering out nude/semi-nude images from seized digital devices before turning them over to the defense.

This document is an email chain initiated by Bobbi C. Sternheim, counsel for Ghislaine Maxwell, addressed to prison officials (MDC) and forwarded to the US Attorney's Office (USANYS). Sternheim alleges that Maxwell was physically mistreated during a body search, specifically claiming a guard groped her breast, while another threatened her with assault charges. The letter explicitly links the BOP's handling of Maxwell to the negligence surrounding Jeffrey Epstein's death in the MCC.

This document is an internal DOJ/US Attorney's Office email chain from June 2021 discussing a data security incident ('spill') related to the Ghislaine Maxwell prosecution. A contractor (employed by CACI) improperly uploaded 5.5 GB of discovery material, which included under-age victim names and other PII from the Jeffrey Epstein case, to Sharefile.com instead of the secure USAfx system. The correspondence confirms the data contained sensitive victim information, discusses the lack of disciplinary action for one individual, and notes that a involved contractor was leaving CACI for unrelated reasons.

This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues for individual sequestered voir dire (jury selection questioning) and permission for attorneys to conduct limited questioning of jurors, citing 'tsunami' levels of negative pretrial publicity and the inflammatory nature of the sexual abuse charges. The motion lists numerous documentaries, podcasts, and books as evidence of prejudicial media coverage that allegedly demonizes Maxwell and links her inextricably to Jeffrey Epstein's crimes.

This document is a Notice of Filing containing a transcript of a telephone interview conducted by attorneys Bradley Edwards and Jack Scarola with a former employee/victim of Jeffrey Epstein. The witness details Epstein flying in 12-year-old girls from France for his birthday, his claims that powerful people 'owed him,' and an attempt by Epstein and his lawyers to silence her in 2007 with offers to be 'looked after.' The witness also describes a 'sick proposition' where Epstein offered to pay her to bear a child that he and Ghislaine Maxwell would raise, before she eventually escaped his control by marrying a man she met in Thailand in 2002.

A page from a spiral-bound phone message book containing four message slips dated January 25, 2005. Messages for Jeffrey Epstein include an inquiry about a 'Texico' investment from Georgia Son, a request to call Ghislaine Maxwell back, and a redacted caller asking about 'working today'. One slip is crossed out, and handwritten text across the page instructs to send the logs back to Palm Beach.

A photograph depicting Jeffrey Epstein seated alongside retail tycoon Les Wexner and Ghislaine Maxwell at an outdoor event under a tent. The only textual information present is the identification number EFTA00003434 in the bottom right corner.

This document is page 15 of a court filing in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It outlines Maxwell's requests for documents related to her motions to dismiss the indictment (based on Epstein's Non-Prosecution Agreement) and to suppress evidence obtained via a subpoena to a redacted party. The document asserts Maxwell was unaware of this subpoena and seeks its production to determine grounds for challenge, while also initiating a motion for the immediate disclosure of exculpatory (Brady) and impeachment (Giglio) material.

An evidentiary photograph labeled EFTA00003495 showing Jeffrey Epstein and Ghislaine Maxwell standing inside a rustic barn or storage building with stone walls. They are accompanied by an unidentified female with long wavy hair. The room is cluttered with construction materials, including stacked tiles, old doors, pipes, and a wheeled metal chassis.

This legal document, dated July 21, 2020, is page 4 of a filing to Judge Alison J. Nathan. It argues that public statements made by FBI Special Agent William Sweeney and attorneys for witnesses (David Boies, Sigrid McCawley, Bradley Edwards) are prejudicial against Ghislaine Maxwell and violate local court rules. The document quotes these individuals characterizing Maxwell as a villain, speculating on her cooperation, and defining her role as the primary facilitator for Jeffrey Epstein's crimes.

This document is a court docket log from the SDNY case against Ghislaine Maxwell, dated November 19, 2021. It details orders by Judge Alison J. Nathan regarding a motion in limine to exclude evidence from 'Accuser-3' (Witness-3), ultimately ruling that testimony regarding Maxwell introducing the witness to Epstein and facilitating sexualized massages is admissible as evidence of Mann Act counts. It also mentions a letter from the prosecution team and procedural orders regarding the sealing and redaction of documents.

This document is a printed Daily Mail article filed as a court exhibit (Case 1:20-cr-00330-AJN). It covers two main topics: an interview with a juror named 'Scotty' detailing the deliberations and voting splits in the Ghislaine Maxwell sex trafficking trial, and a separate legal hearing where Judge Kaplan appeared dismissive of Prince Andrew's lawyer's attempts to use a 2009 Epstein settlement to dismiss a civil suit by Virginia Roberts. The document highlights specific vote counts for the Maxwell charges and Judge Kaplan's skepticism toward Prince Andrew's defense arguments.

This legal document, dated July 29, 2020, is a letter from Ghislaine Maxwell's defense counsel to Judge Alison J. Nathan. The defense argues against the government's proposed restrictive protective order, asserting their right to publicly reference alleged victims who have already identified themselves in media, other lawsuits, and public forums related to both Maxwell and Jeffrey Epstein. They contrast their broader proposed language with the government's version, which they claim would unfairly limit them to referencing only one person who spoke at Maxwell's bail hearing.

An email dated February 17, 2021, outlining investigative follow-up steps. The sender instructs the recipient to contact Victoria's Secret and FedEx regarding their document retention policies, review images for a redacted individual, and follow up with ALAT (likely Assistant Legal Attaché) to obtain UK travel records for Ghislaine Maxwell and Jeffrey Epstein.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It features the direct examination of a witness named Alessi (likely Juan Alessi), who is discussing household management protocols, specifically the use of checklists to ensure tasks are completed for Mr. Epstein, Ms. Maxwell, and their guests. The page contains Bates number DOJ-OGR-00018022.

This document is an email chain from May 2020 between USANYS officials, including Geoffrey Berman, discussing and sharing a clip of Ghislaine Maxwell's testimony. The email contains a transcript excerpt where Maxwell explicitly denies ever giving massages to Jeffrey Epstein or anyone else at his properties.

This document is an internal email from July 19, 2021, sent by a USANYS official, circulating a Daily Mail article. The article reports on allegations from a new book that Jeffrey Epstein and Ghislaine Maxwell befriended a 13-year-old victim at the Interlochen Center for the Arts in Michigan.

This document appears to be a character reference or personal statement written by an unnamed associate describing the relationship between Jeffrey Epstein and Ghislaine Maxwell. The text emphasizes their closeness, stating they have been a couple for 11 years and are rarely apart. It details Ghislaine's skills and interests, including flying helicopters, photography, and languages, and portrays their relationship as mutually complimentary and intellectual.

This document appears to be a page (labeled 88) from an address book, likely Jeffrey Epstein's 'Black Book'. It lists contacts under the headings 'KENYA' and 'KINNERTON' (referring to Kinnerton Street, London). Significant entries include Ghislaine Maxwell, the Muthaiga Club, various high-end London businesses (Harrods, Harvey Nichols, Holland & Holland), and service providers like 'Massage - UK' and 'Drivers'. All specific contact details (phone numbers/addresses) have been redacted.

This document is an internal FBI email chain from July 2019 triggered by a media inquiry from CNN journalist Mirna Alsharif. CNN sought verification of a claim that a victim had reported a sexual assault by Jeffrey Epstein to the FBI in 1996. FBI agents discuss the inquiry, checking if the victim exists in their 'Sentinel' database and noting that the Miami field office ('MM') may have interviewed her during the 2006-2007 investigation.

This document is an email chain from October 2020 between the FBI and the US Attorney's Office (USAO) coordinating the forensic review of image and video files from ten electronic devices seized in the Jeffrey Epstein investigation. The emails distribute review protocols, warrants, and the Ghislaine Maxwell indictment to the review team, assign specific device IDs (e.g., NYC024363, NYC024355) to investigators using the CAIR system, and set a deadline for completion. The communication reflects the post-indictment phase of the investigation involving Maxwell.

This document is an urgent internal Department of Justice email dated October 16, 2020. It contains a request from the Acting United States Attorney of the SDNY to the EOUSA for retroactive approval of travel for an Assistant United States Attorney (AUSA) to the United Kingdom from October 12-17, 2020. The purpose of the trip was to conduct an essential in-person interview with a victim of Jeffrey Epstein for the case against Ghislaine Maxwell, as the victim refused to speak otherwise.

This document consists of two slides from a Department of Justice/FBI presentation regarding the case U.S. v. Ghislaine Maxwell. It serves as a victim outreach notice, detailing the charges against Maxwell for facilitating sexual abuse by Jeffrey Epstein and listing specific locations where the abuse occurred (New York, Palm Beach, Santa Fe, London). It includes photos of the defendants and Epstein's properties, urging potential victims to contact the FBI.

An email chain involving Geoffrey Berman (USANYS) dated May 27, 2020, discussing video clips of testimony (likely Ghislaine Maxwell's deposition). The email includes a transcript excerpt where the deponent denies ever giving massages to Jeffrey Epstein, the redacted individual, or anyone else.

This document is an email chain from July 2, 2020, between the Chief of the Criminal Division at the US Attorney's Office (SDNY) and a recipient named 'Ed'. The correspondence confirms the arrest of Ghislaine Maxwell in New Hampshire on charges of facilitating Jeffrey Epstein's abuse of minors. It discusses procedural details, including that her presentment will not be in SDNY that day and that any appeal on the bail argument would go to Judge Nathan.

This document is an internal email digest titled 'SDNY Press Clips' dated July 28, 2020. It compiles links to news articles concerning Attorney General William Barr's testimony, Michael Cohen, and ongoing developments in the Ghislaine Maxwell/Jeffrey Epstein case, specifically regarding privacy over nude images and new accusers. It also includes general interest stories involving New Jersey politics and Homeland Security actions in Portland.

This document is a court transcript from the trial of Ghislaine Maxwell, filed on August 10, 2022. It captures a portion of the defense's argument, delivered by Ms. Sternheim, who emphasizes the government's burden to prove guilt beyond a reasonable doubt and reminds the jury of the presumption of innocence. After Ms. Sternheim concludes by contrasting Maxwell's presence with Jeffrey Epstein's absence, the judge calls for a 10-minute break before the government presents its first witness.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It details the direct examination of a witness named Meder by Ms. Comey, focused on the identification and admission of Government Exhibit 347. The exhibit is described as a photograph from a CD (logged as 1B19) showing Jeffrey Epstein and Ghislaine Maxwell together.

This document is an email dated October 4, 2021, from an FBI Forensic Accountant in the New York Field Office. The email transmits attached PDF documents related to Jeffrey Epstein's accounts, specifically highlighting accounts where Ghislaine Maxwell was a designated signer.

This document is a Reply Brief filed by the Government of the U.S. Virgin Islands supporting its motion to intervene in Ghislaine Maxwell's lawsuit against the Epstein Estate. The Government argues it must intervene to prevent the dissipation of Estate assets, which Maxwell seeks for her legal defense, because those assets are needed to satisfy potential judgments in the Government's separate 'CICO' (racketeering) enforcement action against the Estate. The brief reveals that the Estate is actively paying legal fees for other associates, including an immigration attorney suspected of obtaining visas for trafficking victims.

A Tatler magazine article (marked with House Oversight ID) profiling the relationship between Ghislaine Maxwell, Jeffrey Epstein, and Prince Andrew. It details the frequent travel between Maxwell and Prince Andrew in 2000-2001, often accompanied by Epstein, and investigates Maxwell's financial dependence on Epstein via companies like Ghislaine Corp and New York Strategy Group. The text also highlights a 2003 lawsuit by artist Nelson Shanks involving unpaid fees from Leslie Wexner, in which Epstein and Maxwell were named.

This document is page 6 of a legal filing dated July 29, 2025, in which the Government argues for the unsealing of grand jury transcripts related to the Epstein and Maxwell cases. Citing the 'magnitude and abhorrence of Epstein's crimes' and a July 6, 2025 Memorandum, the Government asserts that public interest warrants disclosure, subject to redactions protecting victims. The document details that the Epstein grand jury met in June/July 2019, and the Maxwell grand jury met in June/July 2020 and March 2021.

This document is a page from a court docket (Case 21-58) covering entries between July 27 and July 30, 2020, regarding *United States v. Ghislaine Maxwell*. Key entries include a dispute over the terms of a Protective Order, specifically regarding Maxwell's ability to publicly reference alleged victims who have previously spoken publicly about her or Jeffrey Epstein. Judge Alison J. Nathan issued a Memorandum Opinion & Order siding with the Government to restrict Maxwell from publicly referencing these victims/witnesses to protect their privacy and safety.

This document is an internal email chain from July 2, 2020, involving the Chief of the Criminal Division at the US Attorney's Office (SDNY). The correspondence confirms the unsealing of an indictment against Ghislaine Maxwell and her arrest in New Hampshire that morning. The emails discuss the logistics of the announcement occurring before a holiday weekend during the pandemic.

This document is an internal SDNY email dated December 29, 2020, providing a digest of press clippings. It specifically highlights news regarding Ghislaine Maxwell, including a judge's rejection of her $28.5 million bail package and a story linking her to Epstein's suicide at MCC. The 'Matters of Interest' section covers broader political news involving Donald Trump, Hunter Biden, Rudy Giuliani, and others.

This legal document, part of a financial condition report, estimates Ghislaine Maxwell and her spouse's net worth at approximately $22.5 million as of October 31, 2020, noting this figure includes $7.67 million in advance legal fees. The report, covering 2015-2020, found no significant cash transfers outside of their control but contrasts this with a prior period (2007-2011) where over $20 million was transferred between Maxwell and Jeffrey Epstein. The analysis was limited by the unavailability of complete bank statements.

This document is a compilation of FBI internal memos, administrative forms, and news clippings related to the investigation of Jeffrey Epstein between 2006 and 2011. It covers the FBI's monitoring of the state case, the controversial Non-Prosecution Agreement, victim notification procedures, and the prosecution of Epstein's butler, Alfredo Rodriguez, for obstruction of justice. Significant portions include news articles detailing allegations by Virginia Roberts regarding Prince Andrew and the operations of the MC2 modeling agency.

This document contains FBI administrative records and a significant collection of newspaper clippings regarding the 2005-2006 Palm Beach Police investigation into Jeffrey Epstein. It includes an FBI request to open a child prostitution case in July 2006, a redacted probable cause affidavit mentioning a houseman's testimony, and subpoenas for a Grand Jury. The bulk of the content comes from Palm Beach Post articles detailing the friction between the police and the State Attorney's office, the recruitment of underage girls by Haley Robson, and Epstein's high-profile connections.

This page is a transcript of the direct examination of Mrs. Hesse, a former employee of Epstein and Maxwell. She testifies about the protocol for taking phone messages when Epstein and Maxwell were away, specifically describing a blue spiral notebook kept in the kitchen for this purpose. The prosecutor, Ms. Moe, then introduces Government Exhibits 1, 2, and 3 to the witness.

A page from a court transcript (likely the sentencing hearing in US v. Maxwell, filed in the 2023 appeal) debating sentencing enhancements. The prosecution (Ms. Moe) argues that testimony from pilots proves Maxwell had supervisory authority over Sarah Kellen within the conspiracy. Defense attorney Everdell rebuts that Maxwell's presence while Kellen scheduled 'massage appointments' does not constitute supervision. The defense also mentions a 'five-point enhancement for repeated and dangerous sex offenders.'

This document contains four phone message slips from a spiral-bound logbook addressed to 'JE' (Jeffrey Epstein) and 'Gh' (Ghislaine Maxwell) dating from early 2003. Notable communications include a message from 'Amanda' asking if she can bring her friend 'Holly' over that night, and a message from 'Banu' marked as 'very important'. Ghislaine Maxwell appears to be acting in a secretarial capacity, signing off on a message for Epstein with her initials 'GM'.

This page from a legal filing (Case 1:20-cr-00330-AJN) argues that Ghislaine Maxwell has been subjected to intense media harassment and threats following Jeffrey Epstein's arrest and death. It includes a graph showing a spike in media mentions between 2015 and 2020, specifically highlighting the Miami Herald 'Perversion of Justice' series, Epstein's arrest/death, and a bounty offered by The Sun. The text details abusive social media messages received by Maxwell, citing terms like 'pedophile' and 'pimp,' while noting she was not charged in the original Epstein indictment.

This document is a transcript of testimony or a deposition involving Ghislaine Maxwell, Todd Blanche, and David Markus, discussing Jeffrey Epstein's alleged habits, relationships, and associates. Maxwell describes her observations of Epstein with masseuses and discusses whether their interactions were consensual, while also addressing a list of individuals, including politicians and businessmen, who were potentially connected to Epstein in the 1990s and early 2000s, denying some connections and confirming others.

This document is a letter from Sigrid S. McCawley, counsel for Annie Farmer, to Judge Alison J. Nathan, dated June 22, 2022. It provides Annie Farmer's victim impact statement regarding the crimes committed by Ghislaine Maxwell and Jeffrey Epstein, and requests permission for Ms. Farmer to make an oral statement at Maxwell's sentencing. The statement details the profound and ongoing psychological and emotional impact of the abuse on Annie Farmer.

This document is an AT&T Wireless phone bill for 'Jeffrey E Epstein & Co' dated October 14, 2003, covering the period from September 13 to October 12, 2003. The bill explicitly lists 'G. Maxwell' (Ghislaine Maxwell) as one of the individual line users, linking her financially to Epstein's company. The itemized call logs reveal extensive travel and international communication, with significant roaming charges incurred in the US Virgin Islands (late September), Great Britain (early October), and calls involving France, Italy, Austria, and Ecuador.

This document consists of 9 pages of photo contact sheets from a digital forensics file (EFTA00005486-5494). The first few pages show miscellaneous images, including architectural models of a coastal property and heavily redacted personal photos. The latter pages (6-9) are labeled 'JE 50 B-day' and contain thumbnails from Jeffrey Epstein's 50th birthday party (approx. Jan 2003), showing a dinner setting and guests, including a clear visual identification of Ghislaine Maxwell. File paths reference a 'Macintosh HD'.

This document is a page from a court transcript (summation by Ms. Moe) filed on August 10, 2022. The prosecutor argues that photographs show a sexual partnership between Ghislaine Maxwell and Jeffrey Epstein, specifically describing an image of Maxwell massaging Epstein's foot with her breasts. The text details the luxury lifestyle Maxwell enjoyed via Epstein's properties (NY, NM, Palm Beach, Paris, USVI) and cites testimony from house manager Juan Alessi establishing Maxwell as the 'lady of the house' starting in the early 1990s.

This is page 3 of a legal filing (Document 28) dated July 27, 2020, addressed to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The text argues for a specific provision in a protective order regarding victim/witness identities. Maxwell's defense contends that they should be permitted to reference alleged victims who have already voluntarily disclosed their identities in public records or media, arguing that the government's proposed restrictions are overly broad and hinder the defense's ability to investigate and advocate.

A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense counsel dated December 18, 2020. The letter corrects Bates stamping errors in prior discovery productions and provides replacement copies of Deutsche Bank materials relating to Jeffrey Epstein and a UBS subpoena return. It confirms ongoing discovery obligations and mentions physical evidence in FBI custody.

This document contains a page from a spiral-bound message book with four handwritten 'Important Message' slips addressed to Jeffrey Epstein (or J.E.). The slips date from April 9 and April 10, 2005. Messages include a call request from Ghislaine [Maxwell], a redacted caller, and two notes regarding 'Dana' reporting that 'She went running' and went 'back to the gym'.

This document is an excerpt from a legal transcript, likely a deposition, focusing on the origins and discovery of an 'Epstein list'. Ghislaine Maxwell is being questioned about her awareness of the list and the timeline of events, including Brad Edwards' involvement, Alfredo Rodriguez providing evidence, and Ted Waitt being asked for $10 million to keep Maxwell out of Epstein's civil suits in 2009. The document also touches upon Epstein's non-prosecution agreement in 2007-2008 and the subsequent prosecution of Rothstein and Alfredo Rodriguez.

This document is a printout of a Daily Beast article from July 2010 detailing the environment at Jeffrey Epstein's Palm Beach home. It describes the items found during the police raid (sex toys, photos), the role of Epstein's female staff (Kellen, Ross, Groff, Marcinkova, Maxwell) in recruiting girls, and the Non-Prosecution Agreement that protected them. The article specifically focuses on former house manager Alfredo Rodriguez, who was sentenced to more prison time than Epstein for obstruction after trying to sell evidence ('golden nugget') to an undercover officer, and his testimony regarding cash payments to recruiters like Haley Robson.

This document is a Law360 email alert dated July 24, 2020, summarizing recent legal developments. The main story reports that Ghislaine Maxwell failed to secure gag orders against prosecutors and lawyers (specifically Boies) and failed to prevent the unsealing of documents in a defamation suit. A secondary article mentions sanctions against copyright lawyer Richard Liebowitz.

This document is page 8 of a legal defense filing (Document 342) from October 13, 2021, in the case against Ghislaine Maxwell. The text argues that a robust jury questionnaire and individual voir dire are necessary because the jury pool has been tainted by 'pervasive, vitriolic, and extreme' negative media coverage. The defense compares Maxwell's situation to other high-profile New York sex scandals (citing politicians and media figures) to illustrate the hostile environment and potential for juror bias.

This document is a page from a legal defense filing (Case 1:20-cr-00330-AJN) arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell was not evading law enforcement but rather the press, evidenced by her use of a trackable cellphone. It further argues she is not a flight risk to France or the UK because she has irrevocably waived extradition rights and chose to remain in the US following Jeffrey Epstein's arrest and death.

This document is page 5 of a legal filing (Document 342) from the case United States v. Ghislaine Maxwell, filed on October 13, 2021. The defense argues for 'individual voir dire' during jury selection, citing the 'tsunami' of negative pretrial publicity surrounding Maxwell and Jeffrey Epstein since Epstein's arrest in July 2019 and death in August 2019. The text references Supreme Court precedent regarding the necessity of questioning jurors individually to avoid bias in high-profile cases.

In this transcript, Virginia Roberts details the end of her time with Jeffrey Epstein, specifically describing a disturbing proposition where Epstein offered her a mansion and income to bear a child that would belong to him and Ghislaine Maxwell. She recounts being sent to Thailand in September 2002 because she was 'aging out' (at 19), where she met her husband Rob, married him within a week, and called Epstein to tell him she was never returning to the US.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It contains defense arguments asserting that Ghislaine Maxwell did not 'entice' a victim known as 'Jane' to travel for illegal purposes, arguing that return trips to Palm Beach do not constitute enticement to commit crimes in New York. The defense emphasizes testimony stating that Jeffrey Epstein's office typically handled travel arrangements, with Maxwell only occasionally assisting.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on July 22, 2022, concerning United States v. Ghislaine Maxwell. The text, likely spoken by a prosecutor during sentencing arguments, characterizes Maxwell as Jeffrey Epstein's 'right hand' and a 'partner in crime' who preyed on children and viewed people as either 'disposable' or 'mattered.' It highlights that she received millions of dollars from Epstein to fund a luxurious lifestyle and emphasizes the lasting trauma inflicted on the victims.

This document is page 2843 of a court transcript (Case 1:20-cr-00330-PAE) containing the closing summation by prosecutor Ms. Moe. The text focuses on an essay written by Ghislaine Maxwell where she describes her close, 11-year relationship with Jeffrey Epstein as partners and a couple. The prosecutor argues this evidence proves Maxwell was not a mere assistant but a crucial participant in the scheme, using her respectable appearance to legitimize Epstein's predatory behavior toward underage girls.

This is a letter from the U.S. Department of Justice to Judge Alison Nathan regarding the case *United States v. Ghislaine Maxwell*. The Government refutes defense accusations of abandoning discovery deadlines, noting they have already produced 350,000 pages and are preparing to release 1.2 million documents from devices seized from Jeffrey Epstein's residences. The letter also addresses complaints regarding the Metropolitan Detention Center (MDC) and asserts compliance with the Court's July 15, 2020 scheduling order.

This document is an excerpt from a Miami Herald article detailing allegations against Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew, and Alan Dershowitz, primarily from Virginia Roberts' affidavit. It covers alleged sexual encounters, denials from those accused, legal actions including defamation lawsuits and settlements, and a brief mention of Epstein's sentencing hearing. The article highlights the controversy surrounding the allegations and the legal aftermath.

This document is a page from a household staff manual dated February 14, 2005. It outlines specific cleaning and organizational protocols for the 'Interior' of a residence, specifically the Living Room, Ms. Maxwell's Desk, and the Kitchen. The instructions demonstrate a high level of attention to detail, including specific rules for discarding old magazines, the precise placement of 'JE & GM' (Jeffrey Epstein and Ghislaine Maxwell) telephone directories, and tissue box maintenance.

This document is a page from a court transcript (Document 761, filed Aug 10, 2022) featuring the direct testimony of a witness named Espinosa. The witness describes their role in assisting Ghislaine Maxwell with the management of Jeffrey Epstein's properties, specifically noting a massive, never-ending project to get 'the island' up and running. The testimony highlights that Maxwell worked hard, managed contractors (landscapers, designers), and traveled to various properties on a weekly basis.

Page 206 of a legal transcript featuring an exchange between Todd Blanche and Ghislaine Maxwell. Blanche questions Maxwell on whether she believes outside actors arranged for Epstein's death in prison to silence him regarding 'people he knew.' Maxwell denies this theory, stating she does not believe in the blackmail theories or that there was a 'hit' on him, suggesting instead that if it was murder, it was an 'internal situation' within the prison system.

This document is an excerpt from a deposition or transcript where Ghislaine Maxwell is being questioned by Todd Blanche and Diego Pestana. Maxwell discusses Jeffrey Epstein's actions, her memory regarding Mr. Trump, and the involvement of Ehud Barak in the later 2000s, attributing her interest in Israel and connections to it to her father's love for the country.

This document is a Memorandum Opinion & Order filed on July 30, 2020, in the case of United States v. Ghislaine Maxwell in the Southern District of New York. Judge Alison J. Nathan addresses a dispute over a protective order, ultimately adopting the Government's proposed version over Maxwell's requests to publicly reference alleged victims and restrict Government witnesses' use of discovery materials. The document cites legal standards for protective orders under Federal Rule of Criminal Procedure 16(d)(1).

This is page 4 of a legal filing dated August 10, 2020, addressed to Judge Alison J. Nathan. The defense argues for the disclosure of the identities of Victims 1-3 and protests the harsh confinement conditions of Ghislaine Maxwell at the MDC. The document explicitly claims Maxwell's treatment (isolation, 24-hour surveillance, suicide watch protocols) is a direct reaction by the BOP to the suicide of Jeffrey Epstein at the MCC in 2019.

This document is a court filing summarizing the proof presented at Ghislaine Maxwell's trial, detailing her conviction on multiple counts related to the sexual abuse of minors between 1994 and 2004. It describes her close relationship with Jeffrey Epstein, noting she acted as his girlfriend and partner, facilitating the grooming of girls as young as 14 at various international properties. The document also notes the government's intent to dismiss severed perjury charges to spare victims further trauma.

This document is page 45 of a court transcript filed on August 10, 2022, from the trial related to Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It features the direct examination of a witness named Kate by Ms. Pomerantz. The testimony details an incident where Ghislaine Maxwell gave the witness massage oil and closed the door to a small, dimly lit room where Jeffrey Epstein was standing naked, after which the witness gave him a massage.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It details the direct examination of a witness named Meder by prosecutor Ms. Comey regarding the admission of evidence. Specifically, the witness identifies Government Exhibit 307 as a photograph of Jeffrey Epstein and Ghislaine Maxwell retrieved from an investigation CD logged as '1B26'.

This document is a page from a defense sentencing memorandum for Ghislaine Maxwell, filed in June 2022. The defense argues against applying 2004 sentencing guidelines, asserting that Maxwell had ceased participation in the conspiracy by 2002/2003 and was 'replaced' by Sarah Kellen for scheduling duties at the Palm Beach residence. The text cites testimony from Cimberly Espinosa, Juan Alessi, and a witness named Carolyn to support the claim that Maxwell had moved on to a relationship with Ted Waitt and was not involved in Epstein's conduct in late 2004.

This document is a page from a legal transcript where Ghislaine Maxwell is being questioned by Todd Blanche. Maxwell discusses spending time with a 'former President' and 'Doug and his team,' and recalls traveling with Jeffrey Epstein, including trips to Europe and Africa. She mentions an instance where Epstein decided not to continue a trip, leaving her to complete it without him or his plane, and suggests that the purpose of some trips was related to AIDS.

This document is a page from a defense sentencing memorandum filed on June 15, 2022, arguing that Ghislaine Maxwell should receive sentencing credits for harsh pretrial detention conditions. The text portrays Maxwell as a hardworking humanitarian who helped launch the Clinton Global Initiative and founded TerraMar, while characterizing her relationship with Jeffrey Epstein as a singular mistake resulting from vulnerability caused by her father's death.

This document is a page from a Government legal filing in the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), arguing that certain evidence (depositions from April and July 2016) would have been 'inevitably discovered' regardless of protective order modifications. A significant footnote details Judge Preska's refusal in the related civil case to keep Maxwell's testimony sealed, specifically highlighting testimony where Maxwell denied giving massages to Jeffrey Epstein or 'Minor Victim-2,' which forms the basis of perjury charges (Count Six).

This legal document, a letter from the law office of Bobbi C. Sternheim, argues that their client, Ghislaine Maxwell, is being subjected to "draconian" and punitive pretrial detention conditions. The letter posits that these harsh measures are not related to Maxwell's own conduct but are a direct result of the government's attempt to repair its reputation following the suicide of Jeffrey Epstein in federal custody. The attorney details failed attempts to resolve these issues through internal prison channels and claims the conditions are impeding Maxwell's ability to prepare her legal defense.

This document is a juror questionnaire from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on October 22, 2021. The form is designed to screen potential jurors by assessing their pre-existing knowledge, opinions, and potential biases regarding the case, Ghislaine Maxwell, and her associate Jeffrey Epstein. It also inquires about their media consumption and any prior discussions or involvement in surveys or focus groups related to the case.

This document is a transcript of a conversation or testimony involving Ghislaine Maxwell and Todd Blanche, discussing Jeffrey Epstein's early business dealings and his relationship with client Les Wexner. Maxwell describes how Epstein's business may have started through a woman who introduced him to a billionaire's daughter whose money was stolen. She also details Epstein's comprehensive financial management for Les Wexner, including restructuring The Limited and handling personal finances, and mentions traveling with Epstein and Wexner to business meetings on a plane. The conversation also touches upon Epstein's compensation structure, suggesting he was paid a percentage of funds saved for clients.

This document is a page from a court transcript of a summation given by Ms. Moe. She discusses a 'household manual' belonging to Jeffrey Epstein and Ghislaine Maxwell, describing it as a powerfully incriminating phone directory. She focuses on a specific page from 'Government Exhibit 52-G', titled 'Massage Florida', pointing out the large number of female names as evidence that 'something is off'.

This document is a page from the cross-examination of a witness named Visoski during the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). The testimony establishes that Maxwell spent significant time away from Epstein's Palm Beach residence to attend helicopter training courses in Pompano Beach (lasting 8 months to a year) and annual recurrent training in Dallas, Texas, which Visoski accompanied her to.

This document is a page from a transcript of a deposition or interview involving Ghislaine Maxwell and attorney Todd Blanche. Maxwell explicitly states she does not believe Jeffrey Epstein committed suicide. When asked who might have killed him if the blackmail allegations were untrue, she explains that in prison, a 'hit' can be purchased for as little as $25 worth of commissary.

This document is a legal letter to Judge Alison J. Nathan arguing against a subpoena issued by the Defendant (Ghislaine Maxwell) to the law firm BSF. The author argues that requests for materials related to the Epstein Victim's Compensation Program (EVCP) and communications between BSF and the U.S. Attorney are irrelevant to the charges, protected by work-product privilege, and constitute a 'fishing expedition' intended to support a false narrative of collusion. The document specifically details Requests 1, 3-5, 8, and 12.

This document is a page from a court filing (Case 22-1426) which contains a printout of a Daily Mail article dated January 26, 2022. The page features a photograph entered as 'Government Exhibit 52' showing Ghislaine Maxwell and Jeffrey Epstein standing together in a snowy environment. The caption references Maxwell's sex trafficking charges.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness named Meder. The witness identifies a photograph from a CD (logged as 1B63) from the 'Epstein and Maxwell investigation,' confirming the subjects are Ghislaine Maxwell and Jeffrey Epstein. The court, over an objection from Ms. Menninger, admits the photograph as Plaintiff's Exhibit 342.

This document is page 18 of a court order (filed April 16, 2021) denying Ghislaine Maxwell's motion to dismiss her indictment. The Court rejects arguments regarding missing witnesses, specifically noting that potential testimony from the Palm Beach investigation or Epstein himself would likely not have been credible or exculpatory. The Court also rules that pretrial publicity and delays in prosecution have not caused substantial prejudice to Maxwell's right to a fair trial.

This document is a page from a court transcript (summation) filed on August 10, 2022, in the case USA v. Maxwell. Prosecutor Ms. Moe argues that the case centers on manipulation, money, and memory, highlighting how Maxwell groomed victims for Epstein. The text contrasts the small payments made to victim Carolyn (approx. $100) against the $30 million Maxwell received from Epstein.

This document is page 4 of a legal filing (Case 1:20-cv-00330-AJN) dated December 14, 2020. It displays an exhibit titled 'Bounty On Ms. Maxwell,' which consists of a screenshot from The Sun newspaper dated November 19, 2019. The screenshot details a £10,000 reward offered by the newspaper for information regarding Ghislaine Maxwell and includes a well-known photograph of Prince Andrew, Virginia Giuffre, and Maxwell.

This is page 3 of a government filing dated July 28, 2020, addressed to Judge Alison J. Nathan in the case against Ghislaine Maxwell. The government argues against the defense's request to publicly name victims/witnesses, calling the defense's argument 'absurd' and 'offensive' particularly regarding the suggestion that victims derive a 'benefit' from public identification. The document outlines the proposed protective order which would allow defense counsel to discuss identities privately but prohibits public dissemination to prevent harassment and intimidation.

This document is a court filing (Case 1:20-cr-00330-AJN) containing a printout of a Reuters article dated January 5, 2022. The article details how juror Scotty David swayed fellow jurors during the Ghislaine Maxwell trial by sharing his own history of childhood sexual abuse to validate the imperfect memories of accusers 'Jane' and 'Carolyn.' The document highlights the internal deliberations of the jury that led to Maxwell's conviction on December 29, 2021.

This document page, labeled HOUSE_OVERSIGHT_010481, contains four images related to Jeffrey Epstein. It includes a photo of Epstein with Ghislaine Maxwell at a 2005 charity event, a photo of Epstein with a redacted individual at a magazine launch in 2005, a 2008 booking photo from Palm Beach County, and an aerial photo of 'The Stockade' in West Palm Beach where Epstein served his sentence. The captions provide specific dates, locations, and photographer credits for each image.

This document is a page from a court transcript of the cross-examination of a witness named Rodgers. Rodgers testifies that Jeffrey Epstein voluntarily paid for his daughter's tuition without being asked. He also states that he knew Ghislaine Maxwell for over 15 years, had a positive view of her personality, felt no ill will towards her, and was comfortable with his own daughter being in her presence.

This document is a page from a character reference letter filed in court on June 15, 2022, in support of Ghislaine Maxwell prior to her sentencing. The anonymous author, a family friend of over 60 years, describes the difficult upbringing of the Maxwell children under their 'narcissistic' father, Robert Maxwell, and highlights Ghislaine's intelligence and work ethic at Oxford. The letter appeals to the judge for leniency, noting Ghislaine's regret over meeting Jeffrey Epstein and the harsh conditions she has endured in jail, including sleep deprivation.

This document is page 15 of a legal filing dated August 11, 2025, discussing the Government's motion to unseal grand jury materials related to Ghislaine Maxwell based on 'special circumstances' and public interest in the Epstein investigation. It references a July 6, 2025 Memorandum regarding the Government's review of the investigation and notes that a separate court in the Southern District of Florida recently denied a similar motion on July 23, 2025.

This document is a page from the defense summation by Ms. Menninger in the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). Menninger argues that the prosecution is attempting to punish Maxwell for Jeffrey Epstein's crimes because he is deceased. She highlights that the government seized nearly 38,000 photographs but only presented a small handful showing Maxwell and Epstein together, questioning what was in the remaining 37,960 photos.

This document is a transcript from a legal proceeding, likely a deposition, involving Ghislaine Maxwell and Todd Blanche. The discussion centers on Jeffrey Epstein's activities, particularly his alleged encouragement of massages and interactions with individuals, including male and female masseuses in their 20s and 30s during the 1990s. Maxwell denies personal knowledge of Epstein encouraging inappropriate sexual contact or asking underage individuals for massages, stating she never witnessed or was reported any inappropriate incidents.

This document is the Table of Contents for a legal filing (Document 662) in the case against Ghislaine Maxwell, filed on June 15, 2022. The outline previews arguments against various sentencing enhancements (such as 'Undue Influence' and 'Aggravating Role') and argues that the 2003 sentencing guidelines should apply rather than the 2004 guidelines, proposing a sentence range of 51-63 months.

This document appears to be a draft from Virginia Giuffre's memoir describing an evening in London where she was prepared by Ghislaine Maxwell to meet Prince Andrew. The text details her anxiety, her use of Xanax to cope, and a conversation with Jeffrey Epstein where he explains the controversial history of Ghislaine's father, Robert Maxwell (including his pension fraud and death at sea), to explain Ghislaine's background and loyalty to Epstein. The excerpt concludes with Prince Andrew arriving at the townhouse to take the narrator dancing.

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.

A handwritten staff note from Nicole to Lynn and JoJo regarding household maintenance and mail forwarding. The note details coordinating appointments for cable and shutter repairs on a Thursday, specifically noting that Ghislaine requested the TV repair in the 'Blue Room' and that service providers must call Nicole to ensure neither Jeffrey nor Ghislaine are present before entering. It is written on 'Jeffrey E. Epstein' stationery.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness named Meder by an attorney, Ms. Comey. The witness identifies a photograph, admitted as Government Exhibit 324, as originating from a CD related to the 'Epstein and Maxwell investigation.' The witness confirms the photograph depicts Jeffrey Epstein on the left and Ghislaine Maxwell on the right.

This document contains four handwritten telephone message slips from a spiral-bound logbook, dated January 11, 2005. The messages are addressed to 'Jeffrey' or 'JE'. Callers include Ghislaine (Maxwell), Cecilia, Darren, and one redacted individual whose call Jeffrey apparently returned. The document is marked as Government Exhibit 3-S.

This document appears to be a court exhibit containing excerpts from media interviews (MailOnline, The Independent) with a juror named 'David' following the Ghislaine Maxwell trial. David explains that the jury was swayed by the 'pattern' of grooming established by multiple accusers (Kate, Jane, Annie Farmer, Carolyn), despite the defense's attempts to challenge memories via expert Loftus. He specifically notes that while accuser Kate's testimony could not be used for charges due to UK laws, it was crucial for establishing the grooming methodology.

This document is a court transcript from August 10, 2022, in which an attorney, Ms. Comey, questions a witness, Meder, about a photograph. The witness identifies the subjects of the photo as Ghislaine Maxwell and Jeffrey Epstein and states it came from a CD (1B78) related to their investigation. The court admits the photograph as Government Exhibit 322.

This document is a page from a legal filing (likely a government sentencing memorandum) arguing for sentencing enhancements for Ghislaine Maxwell. It details her role as an 'organizer' and 'second in command' who supervised Epstein's staff (including pilots Visoski and Rodgers and house manager Alessi) and directed the activities of Sarah Kellen and victims like Virginia and Carolyn. The text cites trial testimony to establish that Maxwell ran an extensive operation facilitating Epstein's abuse of minors.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022. It details the direct examination of a witness named Meder by prosecutor Ms. Comey regarding Government Exhibits 304 and 306. The witness identifies Jeffrey Epstein and Ghislaine Maxwell in a photograph (Exhibit 304) and identifies Maxwell in another photo (Exhibit 306) retrieved from an investigation CD labeled '1B26'.

This legal document is an affidavit filed on November 6, 2020, by Assistant U.S. Attorney Maurene Comey in the case of U.S. v. Ghislaine Maxwell. Comey certifies that the government attempted to negotiate in good faith with Maxwell's defense counsel for a two-week extension (from November 9 to November 23, 2020) for the production of documents seized from Jeffrey Epstein, but the parties were unable to reach an agreement. The extension was requested to allow an outside vendor to complete bates stamping and downloading of the electronic evidence.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness named Rodgers. The witness confirms details of two flights from January 2001: flight 1444 on Jan 26th from Teterboro, NJ to Palm Beach, FL, and flight 1445 on Jan 29th from Palm Beach to St. Thomas. Rodgers affirms that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were all passengers on flight 1444.

This document is a page from a court order rejecting Ghislaine Maxwell's argument that Jeffrey Epstein's Non-Prosecution Agreement (NPA) protects her from prosecution in the Southern District of New York. Citing the Second Circuit precedent *United States v. Annabi*, the court maintains that plea agreements generally only bind the specific district where they are entered. The court dismisses Maxwell's renewed motion and supplemental authority, affirming that the SDNY is not bound by the agreement made in another district.

This document is a page from a court transcript dated April 1, 2021, featuring a victim impact statement or testimony arguing against granting bond to Ghislaine Maxwell. The anonymous speaker describes Maxwell as a 'predator and a monster' who manipulated them to satisfy Jeffrey Epstein. The speaker reveals a specific incident where they received a late-night phone call threatening the life of their two-year-old child if they testified in a previous civil action.

This document is a pilot logbook page from February and March 1994 detailing flights of aircraft N908JE (HS125-700). The log, signed by pilot David Rodgers, records flights between Teterboro (TGB/TEB), Palm Beach (PBI), Santa Fe (SAF), Boston (BOS), and other locations. Notable passengers traveling with Jeffrey Epstein (JE) include Ghislaine Maxwell (GM), Robert F. Kennedy Jr. (Bobby Kennedy Jr) and his son Bobby Kennedy III, Patricia Kennedy Lawford (Pat Lawford) and Sydney Lawford, and Bear Stearns CEO James Cayne (Jimmy Cayne).

This document is a page from a juror questionnaire (Juror ID 50) filed on February 24, 2022, in the case United States v. Ghislaine Maxwell. The juror acknowledges having heard about the case through CNN.com, specifically noting that Maxwell was Jeffrey Epstein's girlfriend, but indicates they have not formed an opinion regarding her guilt or innocence.

This document is a court transcript (page 112) of the direct examination of a witness named Carolyn. She testifies that when she was 14 years old (almost 15), Ghislaine Maxwell saw her naked approximately three times in the massage room at Jeffrey Epstein's house and touched her breasts on one occasion. Carolyn also confirms that Maxwell continued to schedule massage appointments for Epstein after these incidents and that she was photographed while at Epstein's house.

This document is a page from the prosecution's closing argument (summation) by Ms. Moe in the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The prosecutor rebuts the defense's claim that Maxwell was too busy managing Epstein's life (including tasks like ordering sand for his private island and interviewing staff in limos) to be involved in crimes. Ms. Moe argues that Maxwell participated in the abuse, lived with Epstein, and knew exactly what was happening with the young girls she interacted with.

This document is page 16 of an indictment, filed on July 2, 2020, detailing charges against Ghislaine Maxwell. It includes a charge of perjury (Count Five), stemming from her alleged false testimony during an April 22, 2016, deposition in a civil case where she denied knowledge of Jeffrey Epstein's scheme to recruit underage girls for sexual massages. The document also refers to Maxwell's role in transporting Minor Victim-1 from Florida to New York for sex acts with Epstein.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. Prosecutor Ms. Comey examines a witness named Meder, who identifies Jeffrey Epstein and Ghislaine Maxwell in a photograph marked as Government Exhibit 322. The photo originated from a CD logged as evidence number 1B78 during the investigation, and the exhibit is formally admitted into evidence by the Court.

This document is page 9 of a government filing (Case 1:20-cr-00330-PAE) dated July 29, 2025, regarding the unsealing of Epstein and Maxwell grand jury materials. The Government confirms it has reviewed the transcripts and notified all but one relevant victim (whom they could not reach) about the motion to unseal. Additionally, the Government is submitting indices, transcripts, and proposed redactions to the Court *ex parte* and under seal to protect victim identities.

This document is a Court Order filed on June 4, 2021, by Judge Alison J. Nathan in the case of USA v. Ghislaine Maxwell. The order denies Maxwell's request to subpoena Boies Schiller Flexner LLP for specific items, including a victim's teenage diary, a pair of boots allegedly gifted by Epstein and Maxwell, and original photographs. The judge notes that while the victim's diary describes visiting Epstein in New York, there is no indication Maxwell is mentioned in the journal.

This document is page 8 of a court filing (Document 102) from December 28, 2020, in the case US v. Maxwell. It details the Court's reasoning for denying bail, citing Ghislaine Maxwell as a 'substantial actual risk of flight.' The text highlights her 'significant financial resources,' her failure to provide a full financial accounting, and her 'demonstrated sophistication' in hiding both her assets and herself from the public and the Government.

This document page, stamped HOUSE_OVERSIGHT_010489, features a collage of four photographs related to Jeffrey Epstein's timeline between 2005 and 2008. It documents his social appearances with Ghislaine Maxwell and Adrianna Ross in early 2005, his 2008 booking photo, and an aerial view of the 'Stockade' facility in West Palm Beach where he served his sentence. A caption notes that the police investigation began on the same day Epstein was photographed with Maxwell (March 15, 2005).

This document contains four telephone message slips from January and February 2003. Two messages are addressed to 'JE' (Jeffrey Epstein), one to 'Mr Epstein', and one to 'GM' (Ghislaine Maxwell). Notable content includes a request from a female caller asking if she should bring a redacted friend 'tonight', and a message marked 'very important' from a caller with a 310 area code. Staff members Evelyn, Michelle, and GM signed the messages.

This document contains a numbered list of 14 allegations derived from the 'Jane Doe 102' complaint, detailing sexual abuse facilitated by Ghislaine Maxwell and Jeffrey Epstein. It alleges that the victim was trafficked to high-profile figures including Prince Andrew, Glenn Dubin, Les Wexner, Ehud Barak, and George Mitchell, and mentions Bill Clinton's presence on Little St James. The document also claims secret surveillance existed in Epstein's properties and lists financial benefits Epstein provided to Maxwell.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022. Prosecutor Ms. Comey is examining a witness named Meder regarding photos stored on a CD (evidence number 1B75) gathered during the Epstein and Maxwell investigation. The witness identifies a photograph (Government Exhibit 325) showing Ghislaine Maxwell and Jeffrey Epstein standing together.

This document is a page from a court transcript (filed August 10, 2022) featuring the cross-examination of witness A. Farmer by defense attorney Ms. Menninger. The testimony focuses on an incident in a New Mexico movie theater where Jeffrey Epstein held the witness's hand. The defense establishes that while Ghislaine Maxwell was sitting on the other side of Epstein, the witness does not know if Maxwell saw the contact, and Maxwell did not comment on it afterward.

This document is a page from the court transcript of the trial US v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). A witness identified as 'Jane' testifies that both Ghislaine Maxwell and Jeffrey Epstein gave her instructions during sexualized massages when she was 14 years old. The witness describes Maxwell's demeanor as 'very casual' and 'normal' during these acts, which included touching Epstein's penis.

This document consists of four handwritten phone message slips from June 2004 for Jeffrey Epstein. The messages record calls from Ghislaine Maxwell, Francis Ward, and an individual named Tony. The notes, likely taken by an assistant identified as 'R', detail routine communications, including a non-urgent call from Maxwell, a request for a callback from Ward, and notification of an impending visit from Tony.

This document consists of pages 148-149 from a book (likely James Patterson's 'Filthy Rich') stamped by the House Oversight Committee. It details journalist Vicky Ward's investigation in November 2002, specifically her interviews with a mother and daughters from Phoenix who accused Epstein of attempted seduction, including a 16-year-old. The text also references Epstein's denial of these claims, his association with Bill Clinton, and parties hosted at his townhouse with Ghislaine Maxwell.

A legal letter dated August 5, 2025, from Edwards Henderson (The Crime Victim Law Firm) addressed to Judge Engelmayer and the SDNY Victim and Witness Coordinator regarding the case USA v Maxwell. The firm represents numerous survivors of Epstein and Maxwell and writes to address the DOJ's request to unseal grand jury materials, urging the court to protect victims' rights under the CVRA (18 U.S.C. § 3771). The document emphasizes the victims' reliance on the justice system and argues that their rights to be protected from the accused must be considered regarding any disclosures.

This document is a court transcript from August 10, 2022, where a witness named Rodgers testifies about a flight on November 15, 1996. The witness confirms that Jeffrey Epstein and Ghislaine Maxwell were passengers on this flight from Teterboro, New Jersey, to Columbus, Ohio. The testimony also identifies Juan Alessi as Jeffrey Epstein's house manager in Palm Beach for approximately 12 years.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness, Ms. Meder. The witness identifies Ghislaine Maxwell and Jeffrey Epstein in a photograph, referred to as Government Exhibit 313, which originated from a CD reviewed during the investigation into both individuals. The government attorney, Ms. Comey, then requests that the exhibit be placed under seal to protect a party's privacy, to which there are no objections.

This document is an email chain originating in March 2011 and forwarded by Jeffrey Epstein to Darren Indyke in April 2019. The original 2011 correspondence involves a journalist from The Mail on Sunday, Annette Witheridge, contacting Brett Jaffe regarding an upcoming story about Maxwell, Epstein, and Prince Andrew. The chain shows the legal coordination between Mark Cohen, Ghislaine Maxwell, and Jeffrey Epstein to ignore the press inquiry, as well as a privileged communication sent to Alan Dershowitz.

This is page 5 (filed as page 11 of 45) of a defense motion arguing for Ghislaine Maxwell's release on restrictive bail. The defense argues that the government lacks corroborating documentary evidence, relying instead on old witness testimony, and asserts that Maxwell is suffering under oppressive confinement conditions at the MDC, including isolation and COVID-19 risks. The document also references extradition laws in the UK and France and complaints about discovery failures.

This is a page from a deposition transcript of Ghislaine Maxwell (filed Dec 9, 2021). Maxwell is being questioned about a specific document containing contact information that a redacted individual turned over to the FBI, claiming it came from her computer. Maxwell denies recollection of the document and states she was not responsible for updating or keeping records of individuals Jeffrey Epstein hired.

This is the first page of a Superseding Indictment filed on March 29, 2021, in the SDNY against Ghislaine Maxwell. Count One charges her with Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts. The overview alleges that between 1994 and 2004, Maxwell recruited and groomed victims as young as 14 for Jeffrey Epstein, knowing they were minors.

This page contains a transcript of the prosecution's summation in the Ghislaine Maxwell trial. The prosecutor argues that despite dating Ted Waitt in 2004, Maxwell remained deeply involved with Epstein, citing a 2005 household manual, a 2007 payment of $7.4 million from Epstein to Maxwell, and her presence during police searches. The text also notes the presence of teenage boys and girls at Epstein's properties.

This legal document is a preliminary statement arguing that Ghislaine Maxwell's Sixth Amendment rights were violated. The defense claims the government, rushing to meet a self-imposed July 2, 2020 deadline, improperly used a grand jury from the White Plains Division instead of the Manhattan Division, where the alleged crimes occurred. This resulted in a grand jury pool that significantly underrepresented Black and Hispanic residents, thus denying Maxwell her right to be indicted by a jury drawn from a fair cross-section of the community.

This document is a page from the closing arguments (summations) by Ms. Moe in the trial of Ghislaine Maxwell. The prosecutor argues that Maxwell was essential to Epstein's operation and highlights photographic evidence (specifically Government Exhibits 313 and 342) showing the pair's close, long-term relationship, including photos of them swimming naked together.

This document is page 132 of a court transcript (Case 1:20-cr-00330-PAE) featuring the direct testimony of a witness named Alessi (likely Juan Alessi). The witness describes receiving a degrading, 30-page booklet of checklists and rules from Ghislaine Maxwell around 2001 or 2002 concerning the cleaning and management of Epstein's properties, including Palm Beach. Alessi notes that the workload described was excessive ('enough work for ten people') and contrary to what they were hired to do.

This legal document, dated July 27, 2020, is a filing to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The filing argues in favor of Maxwell's proposed protective order, which would allow her defense team to publicly reference alleged victims or witnesses who have already spoken on the public record regarding Maxwell or Jeffrey Epstein. It contrasts this with the government's more restrictive proposal, arguing the government's position is 'broader than necessary' and would hinder the defense's ability to prepare for trial.

This document is a page from the cross-examination transcript of a witness named Jane (Case 1:20-cr-00330-PAE). The testimony covers Jane's interactions with Jeffrey Epstein and Ghislaine Maxwell, confirming Maxwell's presence during an initial meeting where Epstein offered scholarships and asked for Jane's mother's phone number. The defense also questions inconsistencies regarding whether Jane was alone or with friends on a park bench and establishes that Epstein's office called Jane's mother shortly after she returned to school.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Carolyn by Ms. Comey. Carolyn testifies regarding the scheduling logistics for massages at Jeffrey Epstein's house, stating that initially Ghislaine Maxwell would call to set up times, but later Sarah Kellen or Carolyn herself would make the calls. The witness also confirms seeing Maxwell in an office area off the kitchen at Epstein's house even after Sarah Kellen began handling the scheduling.

This document is a page from a deposition transcript dated August 10, 2022, where a witness, A. Farmer, is being cross-examined. The questioning focuses on the witness's knowledge of a potential trip by Ghislaine Maxwell and Jeffrey Epstein to a ranch in New Mexico in April 1996. The witness denies knowledge of a flight log and has limited memory of staff present at the ranch, such as a chef, and is being shown a 2006 document to refresh their memory.

This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense asserts she is not a flight risk and argues that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions rivaling a Supermax prison, which impairs her ability to prepare her defense. The text cites United States v. Orta regarding bail standards and claims wardens have noted the unprecedented nature of her restrictive regime.

This document is a page from a court transcript dated August 10, 2022, detailing the direct examination of a witness named Rodgers. The testimony confirms that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were all passengers on two flights in 2001. The first flight was on July 8, 2001, from Palm Beach, Florida, to Teterboro, New Jersey, and the second was on July 11, 2001, from Teterboro, New Jersey, to Cahokia, Illinois.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022. Prosecutor Ms. Comey questions a witness named Meder regarding Government Exhibits 317 and 318, which are photographs derived from a CD logged as evidence '1B75'. The witness identifies Ghislaine Maxwell and Jeffrey Epstein in both photographs.

This document is a court docket sheet and memorandum opinion from July 2020 regarding the case against Ghislaine Maxwell. It details the legal dispute over a protective order, specifically regarding Maxwell's ability to publicly name alleged victims and witnesses. Judge Alison J. Nathan ruled in favor of the Government, adopting their proposed protective order to restrict Maxwell from referencing alleged victims, citing the need to protect their privacy and safety despite previous public statements.

This document is a page from a court transcript (summation by Ms. Moe) filed on August 10, 2022. The prosecutor argues that the 'household manual' and testimony from Juan Alessi prove Ghislaine Maxwell was not merely an employee but the 'lady of the house' alongside Jeffrey Epstein. The text highlights that the manual contained specific rules set by Maxwell, including instructions for stationery marked 'Lady Ghislaine,' refuting defense claims that she was unaware of household operations.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the cross-examination of a witness named Swain by Ms. Menninger. The questioning focuses on Swain's phone conversations with Jeffrey Epstein, specifically whether they discussed Ghislaine Maxwell or Epstein's dating life, and details regarding a trip to New Mexico involving individuals named Annie and Maria. Swain explicitly testifies that they never spoke with Ghislaine Maxwell.

This document is a page from a legal filing in the criminal case against Ghislaine Maxwell (1:20-cr-00330-AJN). It includes a transcript excerpt where Maxwell denies giving massages to anyone, specifically including Epstein and '[Minor Victim-2],' and discusses her knowledge of Epstein's sexual activities involving a 'blond and brunette.' The document also references a ruling by Judge Preska in the civil case regarding the unsealing of Maxwell's July 2016 deposition.

This document is a page from a court transcript (United States v. Ghislaine Maxwell) featuring the direct testimony of a witness named Espinosa. Espinosa describes a unique hiring process involving a preliminary interview with Ghislaine Maxwell conducted in the back of a limousine driving around Manhattan. Following this successful 'test,' Espinosa was permitted to meet with Jeffrey Epstein at his office for a final interview and subsequently received a job offer.

This document contains four phone message slips from a spiral-bound book, dated January 20, 2005, which is Jeffrey Epstein's birthday. Messages include a call from Ghislaine Maxwell to Epstein, a message from 'GM' to Sarah instructing her to call 'at home', a birthday wish to 'JE' from a redacted caller, and a significant message regarding a 'girl' referred by a redacted individual who was 'sent home'. The document is marked as Government Exhibit 3-FF-R.

This document is a page from a victim impact statement filed in June 2022 for the sentencing of Ghislaine Maxwell. The survivor describes the trauma of attending the trial in New York, expresses frustration that high-profile "enablers" (politicians and wealthy friends) have not been exposed, and characterizes Maxwell as the "manager" of a massive trafficking conspiracy who lacks human decency.

This document is a FedEx invoice dated November 18, 2002, detailing three shipments charged to Jeffrey Epstein's account. The shipments reveal connections between Epstein/Maxwell and Linda Stone, as well as Henry Rosovsky at Harvard University. Additionally, a package was sent from New York to Ghislaine Maxwell (listed with 'Zorro') at the Palm Beach residence.

This document is page 13 of a court filing (indictment) from July 6, 2020, in the case against Ghislaine Maxwell. It details Count 16 (Conspiracy) and lists 'Overt Acts,' specifically alleging that between 1994 and 1997, Maxwell and Epstein engaged in group sexual encounters with 'Minor Victim-1' in New York and Florida, and that in 1996, the victim was enticed to travel across state lines for sexual abuse.

This is page 30 of a defense filing (likely a bail application) dated December 14, 2020, in the case against Ghislaine Maxwell. The defense argues that despite the government's initial claims of 'strong' evidence backed by flight logs and diaries, the 1.2 million pages of discovery produced so far contain no meaningful corroboration of the charges. The defense emphasizes that the produced documents largely date from the 2000s and 2010s, rather than the 1994-1997 period charged in the indictment.

This document is a page from a government legal filing (Document 204) in the case against Ghislaine Maxwell. It includes excerpts from Maxwell's deposition where she denies interacting with anyone under 18 at Epstein's properties, other than Virginia [Giuffre]. The filing argues against the defense's motion to dismiss perjury charges based on ambiguity, asserting that terms like 'Jeffrey,' 'properties,' and 'interact' were clear in context.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Espinosa. The testimony focuses on Espinosa booking hotels for Ghislaine Maxwell in Miami during the 2000s, establishing that Maxwell did not always stay at Jeffrey Epstein's residence when in Florida. The testimony also identifies Ted Waitt as a man Maxwell dated and eventually became a couple with during that time period.

This document is a page from a court transcript (cross-examination of witness Chapell) filed on August 10, 2022. The testimony focuses on a shipping invoice from 'October' where Ghislaine Maxwell is listed as the sender and Casey Wasserman is the recipient, with Jeffrey Epstein and the address 457 Madison Avenue also listed on the document. The defense specifically establishes that this invoice does not contain any transaction involving a recipient named 'Carolyn'.

This document is a page from the closing arguments (summation) by defense attorney Ms. Menninger in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). Menninger argues against the government's claim that financial transfers to Maxwell were payments for facilitating abuse, stating that transfers like the $7.4 million for a helicopter via 'Air Ghislaine' were standard asset protection strategies used by the wealthy. She draws a parallel to Epstein placing cars in Palm Beach under pilot Larry Visoski's name to show that Epstein frequently put assets in employees' names.

This document is a page from a legal filing (dated April 1, 2021) presenting facts about Ghislaine Maxwell's arrest and detention. It argues that Maxwell, a 59-year-old citizen with no prior criminal history, was subjected to an unnecessary SWAT raid in July 2020 despite being in contact with authorities. The text details her 'nightmarish' prison conditions, comparing them to those of 'Hannibal Lecter,' citing isolation, sleep deprivation, and invasive searches.

This document is page 44 (internal pagination 450) of a court transcript from Case 1:20-cr-00330-PAE (US v. Ghislaine Maxwell). A witness identified as 'Jane' is under cross-examination regarding an initial meeting ('tea') with Jeffrey Epstein attended by Jane and her mother. The questioning highlights that Jane previously told the government (in Oct 2021) that Maxwell was not present at this specific meeting, and that Epstein referred to his philanthropic activities (scholarships/mentoring) using singular pronouns ('he') rather than plural.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022, featuring the cross-examination of a witness named Chapell by attorney Mr. Everdell. The testimony focuses on shipping invoices showing packages sent by G. Maxwell (associated with Jeffrey Epstein's address at 457 Madison Avenue) to Isabel Maxwell and Ron Burckle. The defense counsel specifically establishes that these invoices do not show any packages being sent to a person named 'Carolyn'.

This document is page 16 of an indictment (Case 1:20-cr-00330-AJN) filed on July 8, 2020, detailing 'Count Six' against Ghislaine Maxwell for Perjury. It alleges that on July 22, 2016, during a deposition for a civil case (15 Civ. 7433), Maxwell knowingly gave false testimony regarding her knowledge of sex toys at Jeffrey Epstein's Palm Beach house.

This document is page 8 of a defense filing (Case 1:20-cr-00330-AJN) dated February 4, 2021, arguing that Virginia Giuffre's defamation claims against Ghislaine Maxwell were based on lies and that Giuffre attempted to shift the focus to being 'sexually trafficked' by Epstein to third parties. It details the legal history of Maxwell's depositions and a protective order granted to shield confidential information from a 'media circus.' A footnote references a concurrent lawsuit between Giuffre and Alan Dershowitz, noting Dershowitz filed evidence suggesting Giuffre and her lawyers fabricated stories.

This document is a docket sheet page from the case United States v. Ghislaine Maxwell, covering filings from July 27 to July 30, 2020. It details a dispute over a protective order, specifically regarding Maxwell's ability to publicly name alleged victims who have previously spoken publicly about her or Jeffrey Epstein. Judge Alison J. Nathan issued an order siding with the Government, restricting Maxwell from publicly referencing alleged victims and witnesses to protect their privacy during the criminal proceedings.

This document is a court transcript of the direct examination of a witness named Kate. Kate testifies that Ghislaine Maxwell invited her by phone to her house, complimented her on a previous 'job', and stated that 'He' (implied to be Epstein) wanted her to return. Maxwell then led Kate to a room, opened the door to reveal Jeffrey Epstein standing naked, and told Kate to 'Have a good time.'

This legal document, filed on February 4, 2021, is a request for the production of documents related to defense motions in the case against Ghislaine Maxwell. It seeks all communications concerning the 2007 Non-Prosecution Agreement (NPA) with Jeffrey Epstein, including those between various government agencies and Epstein's lawyers. The request also demands communications from meetings in 2016 and 2018 where attorneys for Epstein's victims urged the U.S. Attorney's Office for the Southern District of New York (SDNY) to launch a criminal investigation into both Epstein and Maxwell.

This document is a page from a court transcript containing the closing argument (summation) by defense attorney Ms. Menninger in the trial of Ghislaine Maxwell. Menninger argues that metadata presented by forensic expert Stephen Flatley does not prove Maxwell wrote specific incriminating documents, as flight logs show she was not in the location ('the house') where the desktop computer was located when those documents were created. The defense suggests multiple people had access to the computer.

This document is a page from the court transcript of Ghislaine Maxwell's sentencing hearing (Case 1:20-cr-00330). In this statement, Maxwell addresses the court, acknowledging the suffering of the victims and admitting her conviction for helping Jeffrey Epstein. She attempts to distance herself by characterizing Epstein as a manipulative man who fooled everyone, while stating that meeting him was the greatest regret of her life.

This document is a page from a court filing containing an excerpt of an interview with a juror named David regarding the Ghislaine Maxwell trial. David explains to 'The Independent' why the jury acquitted Maxwell on 'count two' related to accuser Jane, citing a lack of direct evidence for 'enticement' across state lines despite believing the victim. The text also highlights corroborating evidence such as flight logs and Epstein's 'little black book,' which contained names of victims alongside 'mom' and 'dad,' as well as Palm Beach police officers listed familiarly.

This document appears to be an excerpt (pages 65-66) from Virginia Giuffre's manuscript. It details a trip to St. Tropez in early April, where the group (including Epstein, Maxwell, and 'Emmy') stayed at La Bastide De St. Tropez. The narrative describes attending Naomi Campbell's birthday party at Nikki Beach Club and a yacht, dancing with a 'young prince', and Epstein subsequently directing Giuffre to perform a massage/sexual acts on a hotel owner referred to as 'Rick' (identified as an owner of the Hilton chain).

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It captures the conclusion of an address by defense attorney Ms. Sternheim, who argues that Ghislaine Maxwell should be found not guilty and distinguishes her from Jeffrey Epstein. The page concludes with the Judge (The Court) ordering a 10-minute break before the government calls its first witness, indicating this is likely the end of opening statements.

This document contains pages 27-28 of a manuscript, likely Virginia Giuffre's memoir, describing her early interactions with Jeffrey Epstein and Ghislaine Maxwell while she was a 15-year-old employee at Mar-A-Lago. The text details a payment scene where Epstein gives her cash from a duffel bag held by Maxwell, her internal struggle and shame regarding the abuse, and her return to the Epstein residence the following day where she meets 'Emmy', Maxwell's personal assistant. The document highlights the grooming process, financial inducement, and the narrator's use of the alias 'Jenna'.

This document appears to be a manuscript or deposition draft by Virginia Giuffre. It details a timeline starting with a miscarriage, after which Jeffrey Epstein instructs her to travel to his island to entertain a client, identified as Harvard Professor Stephen Kosslyn. The text describes the narrator drugging herself with Xanax and alcohol before engaging in a sexual encounter with Kosslyn at Epstein's direction.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE, US v. Maxwell) dated August 10, 2022. Witness Juan Alessi is being questioned by Ms. Comey about a staff instruction booklet given to him by Ghislaine Maxwell. The testimony highlights a specific rule requiring staff to 'see nothing, hear nothing, say nothing,' which Alessi interpreted as a warning to remain 'blind, deaf and dumb' regarding the lives of Epstein and Maxwell.

This document is a page from a legal filing (Case 21-58) dated April 1, 2021, detailing Ghislaine Maxwell's attempts to secure bail. It outlines the court's reasons for detaining her—flight risk due to foreign citizenship (France, Britain) and unclear finances—and the defense's counter-arguments, including an offer to renounce her foreign citizenship and the assertion that witness testimony related to Jeffrey Epstein rather than her. The text notes that despite these arguments, the judge denied bail for a second time.

This document is a page from a court transcript filed on August 10, 2022. In it, a witness named Rodgers confirms under direct examination that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were passengers together on two separate flights. One of these flights is identified as taking place on January 30, 2001, from St. Thomas, U.S. Virgin Islands, to Palm Beach, Florida.

This court transcript from August 10, 2022, documents the direct examination of a witness named Meder by an attorney, Ms. Comey. The witness identifies a photograph, admitted as Government Exhibit 348, which was sourced from a CD during the 'Epstein and Maxwell investigation'. The witness confirms the photograph shows Ghislaine Maxwell on the left and Jeffrey Epstein on the right.

This is page 2 of a legal memorandum filed by the defense in the case of United States v. Ghislaine Maxwell. It outlines her background, emphasizing her ties to the US, family support, and citizenship status to argue against flight risk. It counters the government's position that she was 'hiding' and argues that detention is not warranted.

This document is a page from a court transcript (dated April 1, 2021) in the case against Ghislaine Maxwell. The court is addressing a defense argument for release, distinguishing Maxwell's case from 'United States v. Friedman.' The judge notes that while Maxwell stayed in contact with the government, she did not provide her whereabouts and the circumstances of her arrest suggest she may have been hiding, driven by a realization of the severity of the charges and potential sentence.

This 1994 letter from Timothy J. Ambrose of the Interlochen Center for the Arts to Ghislaine Maxwell addresses logistical matters concerning the 'Epstein Lodge'. Ambrose reports finding a lost envelope, confirms a reservation for Jeffrey Epstein's use, and requests verification of an inventory of his personal items. The letter also expresses gratitude for the facility, noting that the center's President Elect will be using it temporarily.

This document is a page from the defense summation by Ms. Menninger in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). Menninger argues that Epstein's spending, including giving land to pilot Larry Visoski and paying employee tuition, appeared generous and educational rather than criminal. She refutes the prosecution's (Ms. Moe) claim that funds were used to buy off sex abuse cases by pointing out that accountant Harry Beller signed the checks and no bank representatives testified to the illicit nature of the funds.

This document contains a scanned page of four pre-printed 'IMPORTANT MESSAGE' slips, two of which are filled out by hand. The first slip informs 'Mr Epstein' that 'Misses Kersti + Liz' have arrived. The second slip informs 'Miss Maxwell' that someone (whose name is redacted) is on the phone. The document is marked as Government Exhibit 2-W from the case S2 20 Cr. 330 (AJN) (United States v. Ghislaine Maxwell).

This document is the first page of the Government's Memorandum in Support of Detention for Ghislaine Maxwell, filed on July 2, 2020, in the Southern District of New York. The prosecution argues that Maxwell poses an extreme flight risk due to her wealth, three passports, foreign citizenship, and lack of ties to the US, and requests she be detained pending trial for her alleged role in partnering with Jeffrey Epstein to exploit minors.

This document is an email chain from September 2015 between Ghislaine Maxwell (using ellmax.com), Jeffrey Epstein (using the alias 'J Jep' and gmail), and Darren Indyke. The conversation begins with Maxwell sharing a Page Six article titled 'ex-teen-prostitute-files-suit-in-billionaire-sex-slave-case'. Subsequent replies between Epstein and Maxwell are redacted under privilege claims. The document bears a House Oversight stamp.

This document is a transcript page from the trial of Ghislaine Maxwell featuring the direct examination of witness Annie Farmer. Farmer testifies about her reluctance to go to New Mexico to see Jeffrey Epstein due to a prior incident in a New York movie theater, stating she only felt comfortable going because her mother told her Maxwell (whom she viewed as Epstein's romantic partner) would be present. The defense attorney, Ms. Menninger, raises a hearsay objection regarding the mother's statement, which the judge overrules with a limiting instruction.

This document is a page from a book (likely by James Patterson) obtained by the House Oversight Committee. It details Ghislaine Maxwell's attempts to rebrand herself as an ocean philanthropist via the TerraMar Project after her association with Jeffrey Epstein, noting her attendance at high-profile events like Chelsea Clinton's wedding. The text also discusses the legal conflict between Maxwell and Virginia Roberts (Giuffre) regarding sexual abuse allegations and introduces a section on Prince Andrew.

This document is a page from the court transcript of the closing arguments (summation) by defense attorney Ms. Menninger in the trial of Ghislaine Maxwell. The defense argues that Maxwell was not Epstein's 'right-hand woman' in all matters and that Epstein actively kept secrets from her, including relationships with other women like Frances Jardine, Celina Midelfart, and Sherry Lewis. The text cites testimony from staff (Mr. Alessi, Cim) and flight logs to demonstrate that Epstein often traveled without Maxwell and removed her photos when other women were present.

This document is page 2 of a court filing (Document 675-2) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE). It appears to be a victim impact statement detailing the grooming and abuse tactics used by Epstein and Maxwell. The victim describes how they exploited her vulnerabilities—specifically her lack of a visa and desire to attend FIT—and accuses Maxwell of physically forcing her into Epstein's room to be raped and verbally abusing her regarding her weight.

This Palm Beach Police Department incident report details a trash pull operation conducted on March 31, 2005, at Jeffrey Epstein's residence at 358 El Brillo Way. The operation, led by Officer La'Mont Lee, recovered evidence including a boarding pass for Janusz Banasiak, Ghislaine Maxwell's notepaper, and messages referencing Peggy Seagal. The report also documents a witness statement regarding a woman receiving a rental car from Epstein to visit him, and concerns about witnesses notifying Epstein of the police investigation.

A manuscript excerpt (pages 69-70) likely written by Virginia Giuffre describing her time on Jeffrey Epstein's island. The text details a friendship with a guest named Alexandria, a near-drowning incident, scuba diving lessons, and a frightening encounter with hammerhead sharks while diving with Epstein, Maxwell, and others. It concludes with Maxwell piloting a helicopter to St. John's Airport and the narrator reflecting on meeting Alexandria later in Palm Beach.

This document is page 5 of a Government filing from July 28, 2020, in the case against Ghislaine Maxwell. The Government argues against a defense proposal that would allow them to publicly name victims and witnesses, stating that such a request is broad, unjustified, and contrary to the Crime Victims' Rights Act. The text highlights the distinction between the previous Epstein protective order and the current case, emphasizing that victims should not fear reprisal or shaming by having their identities broadcast by the defense.

This document consists of four handwritten message slips from June 2004, documenting calls for Jeffrey Epstein. The callers include Ghislaine Maxwell (twice), Francis Ward, and a person named Tony. The messages range from simple notifications of a call to a request for a callback and an announcement of an imminent visit from Tony on June 6, 2004.

This document is a summary of an interview with an individual identified as 'AK' regarding a meeting held on February 29, 2016. The interview covers AK's recollections of discussions about potential charges, the Florida Non-Prosecution Agreement (NPA), and the extensive civil litigation involving Virginia Roberts and others. The notes mention Ghislaine Maxwell was described as a 'head recruiter' in written notes, though AK did not recall the specific attribution during the interview.

This document is a page from a court transcript dated August 10, 2022, detailing the direct examination of a witness named Rodgers. Rodgers testifies about a flight in December 2000 from Palm Beach, Florida, to Teterboro, New Jersey, confirming that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were passengers. The witness also states they remember Virginia Roberts flying on Jeffrey Epstein's private planes 32 times.

This document is a page from a deposition transcript of Ghislaine Maxwell, filed in court on December 9, 2021. Maxwell is questioned about whether she maintained electronic records of names and addresses for Jeffrey Epstein or if she could access such information on a computer. Maxwell denies that keeping track of Epstein's contact numbers was her job or responsibility.

This document contains an email chain from March 7, 2011, in which attorney Jay Lefkowitz forwards a list of interview questions from journalist Alexandra Wolfe to Jeffrey Epstein (using the alias email jeevacation@gmail.com) and his legal team. Wolfe's questions probe Epstein's current status, including his relationship with Ghislaine Maxwell and Bill Clinton, his business valuation ($15 billion), his time in prison, and his reaction to his conviction. Lefkowitz prefaces the exchange by warning the journalist that previous press coverage has been 'defamatory' and requesting factual questions.

This document is a page from a court transcript (Case 1:20-cr-00330-AJN) filed on August 10, 2022, featuring the cross-examination of Dr. Dubin. The questioning focuses on Dubin's personal life in the 1990s (birth of a child in 1997) and pivots to her observations of the relationship between Jeffrey Epstein and Ghislaine Maxwell. Defense attorney Mr. Pagliuca raises objections regarding hearsay and vague time frames, which the Court partially sustains, leading the questioner to narrow the focus to the period between 1994 and 2000.

This document is page 17 of 18 from an indictment (Case 1:20-cr-00330-AJN) filed on July 6, 2020. It outlines Count Six (Perjury) against Ghislaine Maxwell, alleging she knowingly made false material declarations during a deposition on July 22, 2016, related to civil case 15 Civ. 7344. The specific false testimony cited involves her denial of knowledge regarding sex toys or devices at Jeffrey Epstein's Palm Beach house.

This document is page 18 of a draft juror questionnaire filed on October 22, 2021, for the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains questions 13 and 14, which ask potential jurors about their exposure to media regarding Jeffrey Epstein and Ms. Maxwell, and whether they can remain impartial. The document highlights a dispute between the prosecution and defense, visible in sidebar comments, where the Government objects to defense-proposed questions (in green text) regarding jurors' specific reactions to media coverage.

This document is a page from the Government's sentencing memorandum in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on June 22, 2022. The text accuses the defendant of lying to the Court about her guilt, refusing to disclose details about her marriage to the Probation Office, and drastically altering her reported net worth from $22 million (during bail hearings) to almost nothing (during sentencing). The Government argues that Maxwell accepts no responsibility and instead falsely portrays herself as a victim of various entities, including her father, Epstein, and the government.

This document is page 890 of a court transcript (filed Aug 10, 2022) featuring the direct examination of a witness named Alessi. Alessi testifies that Ghislaine Maxwell provided 'exotic oils' from other countries for Jeffrey Epstein's massages, which Alessi stored in Epstein's bathroom. The testimony also details that Alessi was never present during the massages, the doors were always closed, and his role involved entering afterward to clean up and retrieve the massage table from a closet in Epstein's bathroom.

This document is page 81 of a court transcript from August 10, 2022, featuring the opening of the defense summation by Ms. Menninger in the trial of Ghislaine Maxwell. Menninger argues that Maxwell is innocent and that the government's case relies on stories fabricated through 'erroneous memories, manipulation, and money' facilitated by personal injury lawyers. The defense contends the prosecution successfully proved Jeffrey Epstein was a manipulator but failed to connect his crimes to Maxwell.

This article from The Virgin Islands Daily News (originally by Miami Herald) reports on Alan Dershowitz's efforts to limit press access to a 2019 court hearing regarding the unsealing of documents in the Epstein/Maxwell sex trafficking case. It details the history of the defamation suit brought by Virginia Roberts Giuffre against Ghislaine Maxwell, the 2017 settlement, and the involvement of high-profile figures like Alexander Acosta and Sarah Ferguson. The article highlights the legal battle between privacy for the accused and the public's right to know, framed by the 'Perversion of Justice' investigation.

This document is a page from a court transcript (filed August 10, 2022) featuring the direct examination of a witness named Meder by prosecutor Ms. Comey. The witness identifies a CD (logged as 1B78) containing a photograph (Exhibit GX-333) of Jeffrey Epstein and Ghislaine Maxwell standing together. The court admits this exhibit into evidence, and the prosecution proceeds to introduce a second exhibit (GX-337) from a different CD (logged as 1B63).

This document is a transcript of a prosecutor's, Ms. Moe's, summation in the trial of Ghislaine Maxwell. Ms. Moe argues that the case is fundamentally about how Maxwell and her partner, Jeffrey Epstein, used manipulation, money, and their privileged status to groom and exploit vulnerable young girls from struggling families. She contrasts the small amounts of money paid to victims, like Carolyn, with the millions Maxwell received from Epstein to underscore the theme of exploitation.

This legal document, part of a court order filed on July 27, 2020, strictly prohibits the defense team (including the Defendant, counsel, staff, and experts) from publicly disclosing the identities of any victims or witnesses referenced in the case's discovery materials. An exception is made for referencing individuals who have already spoken on the public record concerning Jeffrey Epstein or Ghislaine Maxwell. The order also forbids filing the identities of non-public victims or witnesses unless authorized in writing by the Government or by a court order.

This document is a court docket log from April 16, 2021, detailing significant rulings by Judge Alison J. Nathan in the case against Ghislaine Maxwell. The Judge denied Maxwell's motions to dismiss the indictment based on Epstein's non-prosecution agreement and other grounds, but granted the motion to sever perjury charges for a separate trial. The document also notes the filing of reply memoranda by defense attorney Christian Everdell and establishes deadlines for pretrial disclosures involving Brady and Giglio materials.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the cross-examination of a witness named Rodgers. The testimony establishes that when Epstein first bought a specific property (implied to be the New Mexico ranch), the main house was not built, and Epstein stayed in a trailer while the witness stayed in a bunkhouse at 'Ranch Central.' The questioning then pivots to discuss where Epstein and Ghislaine Maxwell lived in New York starting in 1990.

This document is page 4 of a legal opinion (likely from an appellate court) affirming the conviction and sentencing of Ghislaine Maxwell. The court holds that Jeffrey Epstein's Non-Prosecution Agreement (NPA) with the Southern District of Florida does not prevent the Southern District of New York from prosecuting Maxwell, and confirms that the statute of limitations was not violated. The document also notes Maxwell was fined a total of $750,000 and denied a new trial regarding juror conduct.

This document is a page from a legal filing (Procedural History) dated April 1, 2021, detailing the arrest and bail applications regarding Ghislaine Maxwell. It outlines her arrest on July 2, 2020, the government's allegations that she groomed minors for Jeffrey Epstein, and the subsequent legal motions leading to her detention order following a Zoom hearing where no accusers testified.

This document is the final page of a Miami Herald article filed as a court exhibit in April 2019. It features quotes from retired FBI agent Kenneth Lanning regarding child abuse trauma and statements from a victim advocate named Wild criticizing the government's protection of Epstein. It also references Ghislaine Maxwell's role as an associate and her participation in a TED Talk.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Kate. She testifies about a visit to Ghislaine Maxwell's townhouse where she was introduced to Jeffrey Epstein. Maxwell described Kate's talents and small physical size (95 lbs) to Epstein, then instructed Kate to squeeze Epstein's feet to demonstrate her strength.

This document is page 2 of a court filing (Case 1:20-cr-00330-AJN) dated July 30, 2020. The Court rules in favor of the Government regarding a protective order, restricting Ghislaine Maxwell and her defense team from publicly disclosing the identities of alleged victims and witnesses, even those who may have previously made public statements about Maxwell or Jeffrey Epstein. The judge argues that participating in a criminal investigation warrants privacy protection distinct from previous voluntary public statements.

A Tatler magazine article (page 91) profiling Ghislaine Maxwell following the death of her father, Robert Maxwell. It details her transition to New York, her financial status (£80k/year trust), and her meeting of Jeffrey Epstein, who is described as a wealthy, mysterious financier who paid for her Concorde travel. The document includes significant photos, including the infamous image of Prince Andrew with 17-year-old Virginia Roberts (described as Epstein's 'personal masseuse') and a group shot including Donald Trump and Melania Knauss.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022, related to the Ghislaine Maxwell trial. It details a discussion between the Judge, prosecutor Ms. Comey, and defense attorney Mr. Everdell regarding a specific jury instruction for a witness named Rodgers. The Judge agrees to instruct the jury that alleged physical contact between the witness, Epstein, and Maxwell in New Mexico was not 'illegal sexual activity,' and the parties agree to discuss a separate 'Rule 412' issue at sidebar.

This document contains four handwritten phone message slips addressed to Jeffrey Epstein (or 'JE'). Callers include Ghislaine Maxwell, Sarah (last name redacted), Sophie Biddle, and Manuela. The messages concern scheduling meetings, including a specific 7:30 appointment with Sophie Biddle and a relay message from Manuela apologizing that Sophie missed Epstein in California.

This document is a page from a legal filing (dated April 1, 2021) presenting the 'Facts' from the defense's perspective regarding Ghislaine Maxwell. It details her arrest in New Hampshire in July 2020, characterizing it as unnecessary and 'showy,' and harshly criticizes her confinement conditions, comparing her isolation to that of Hannibal Lecter and alleging sleep deprivation and invasive searches.

This document is a page from a court transcript filed on August 22, 2022, in the case United States v. Ghislaine Maxwell. Prosecutor Ms. Moe argues that Sarah Kellen was a 'criminal participant' subordinate to Maxwell in the conspiracy hierarchy, taking over tasks like scheduling victims so that Maxwell could move higher up in the leadership structure. The Judge questions the specific evidence proving Maxwell's supervision over Kellen.

This document is the first page of a Victim Impact Statement by Elizabeth Stein, filed in June 2022 for the sentencing of Ghislaine Maxwell. Stein details how she met Maxwell while working at Henri Bendel in New York during her senior year at FIT (mid-1990s). Maxwell used a connection to Les Wexner to impress Stein, lured her to the Pierre Hotel under the guise of a product delivery, introduced her to Jeffrey Epstein, and subsequently, both Maxwell and Epstein sexually assaulted her.

This document is a scanned excerpt from the Epilogue of the book 'Filthy Rich' (page 287), stamped as a House Oversight exhibit. It lists a series of direct interview questions prepared for Jeffrey Epstein regarding his criminal conviction, his relationships with high-profile figures like Bill Clinton, Donald Trump, Prince Andrew, and Leslie Wexner, and his predatory behavior toward underage girls. The left page contains fragmented text discussing the setup of the interview and includes a partial quote comparing his crimes to stealing a bagel.

This document is a page from James Patterson's book (likely 'Filthy Rich') stamped as a House Oversight document. It details Detective Recarey's investigation into witness intimidation in the Epstein case around July 2006. Specifically, it describes a private investigator named Ivan Robles harassing the family of a victim named Mary, and an attempt to bribe a victim named Alison to stop cooperating with police. The text also notes Recarey's suspicion that the State Attorney's office (led by Barry Krischer) might be complicit.

This document is a biographical article profiling Jeffrey Epstein (circa 2006), detailing his rise from a blue-collar background to immense wealth and high-society connections. It highlights his relationships with figures like Bill Clinton, Ghislaine Maxwell, and Leslie Wexner, his acquisition of lavish properties in New York, Palm Beach, and New Mexico, and his donations to scientific research and political campaigns. The article also alludes to legal controversies, including a SEC probe, a Citibank loan default, and his association with Ponzi schemer Steven Hoffenberg.

These pages (89-90) appear to be from a manuscript or memoir draft by Virginia Giuffre (indicated by Bates stamp and context). The text details her grooming by Jeffrey Epstein, describing how he transformed her appearance and used her as a 'personal toy' and for 'massages with benefits.' It outlines Epstein's method of entrapment and blackmail involving powerful figures ('members of parliament', 'celebrities') and mentions her time spent at his ranch in Santa Fe as a temporary escape.

This document is page 14 of a transcript from a telephone interview with Virginia Roberts in the case Edwards adv. Epstein. Roberts details the progression of massages into sexual acts and lists frequent passengers on Jeffrey Epstein's private plane, including Ghislaine Maxwell, Emmy, and various famous figures such as Naomi Campbell, Heidi Klum, Bill Clinton, Al Gore, and Matt Groening. She also describes sexual activity occurring on the plane, noting the presence of a bed and specific other women like Sarah and Nadia Bjournik.

This document is a page from a court transcript (Case 1:20-cr-00330-AJN, filed 08/10/22) featuring the direct examination of a witness named Young. The attorney reads portions of a prior report concerning a victim referred to as 'Jane,' confirming that Jane was unsure if she was alone with Epstein and Maxwell, and that she did not recall specific abuse occurring during a trip to New Mexico. The testimony highlights the group dynamic involving Epstein and Maxwell during sexual incidents.

This document is a page from a legal defense filing arguing against the pre-trial detention of Ghislaine Maxwell. It outlines her background, emphasizing her US citizenship since 1991 and strong family ties in the US to counter the government's argument that she is a flight risk. The defense disputes the government's claim that she was 'hiding,' asserting she was in regular contact with authorities through counsel since Epstein's arrest.

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.

This document is a page from a court transcript dated June 29, 2023, likely from an appeal hearing (Case 22-1426). The discussion involves an attorney, Ms. Moe, arguing to the Court that Ghislaine Maxwell held a leadership role over Sarah Kellen within the criminal conspiracy. The argument posits that as the scheme evolved, Kellen was brought in as a subordinate to handle tasks previously performed by Maxwell (such as scheduling massage appointments), thereby elevating Maxwell's status in the hierarchy.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the cross-examination of a pilot named Visoski. The testimony confirms that Visoski accompanied Ghislaine Maxwell as a 'safety pilot' when she flew a helicopter owned and controlled by Jeffrey Epstein. The witness clarifies that Epstein determined the missions and usage of the aircraft, not Ghislaine.

This document is an email thread from March 7, 2011, between Jeffrey Epstein, Jay Lefkowitz, and journalist Alexandra Wolfe. Wolfe submits a list of probing questions to Lefkowitz intended for Epstein, inquiring about his science foundation, business valuation ($15 billion), work during prison, relationship with Ghislaine Maxwell, and charity work with Bill Clinton. Epstein forwards the thread to Lefkowitz with a redacted privileged response.

This document is a page from a court transcript (summation by Ms. Moe) filed in August 2022. It details evidence corroborating the testimony of a witness named Carolyn, specifically linking her to Epstein and Maxwell through FedEx invoices from 2002 and phone messages left at the Palm Beach house in 2004. The prosecutor argues that Maxwell's name on the FedEx invoices proves her involvement in the operation.

This document is a scanned excerpt (page 116) from a book, likely by James Patterson, stamped as evidence for House Oversight. It details the background of Ghislaine Maxwell, including her father Robert Maxwell's fraud and death, her move to NYC, and her evolving relationship with Jeffrey Epstein from lover to procurer. The text also introduces a victim, Nadia Bjorlin (referred to as Nadia B.), who met Epstein while attending school in Michigan.

This document is a page from the direct examination of a witness named Kate in the trial against Ghislaine Maxwell. Kate testifies that Maxwell closed the door to a room where Kate then gave Epstein a massage that escalated into a sex act initiated by Epstein. Kate further testifies that immediately after the encounter, she went downstairs and Maxwell praised her, asking if she had fun and stating that Epstein liked her.

This document is a legal opinion written by French attorney William Julié regarding the extradition of French nationals to the United States. It was requested by Olivier Laude on behalf of Ghislaine Maxwell's defense team to support bail proceedings, arguing that French law permits extradition to the US and that Maxwell intends to waive her rights to fight such extradition in French courts. The document serves to assure US authorities that Maxwell would not be shielded by French non-extradition principles if she were released on bail and fled to France.

A character reference letter filed on December 14, 2020, in support of Ghislaine Maxwell's bail application. The redacted author describes knowing Maxwell since age 6, being entrusted to her care at ages 12, 15, and 19, and interning for her in New York in 2009. The letter attempts to refute negative media portrayals by highlighting Maxwell's support, integrity, and work with an 'Oceans charity'.

This document is a page from a court transcript (filed Dec 10, 2020) detailing the government's efforts to notify victims regarding the case against Ghislaine Maxwell. It outlines specific dates in July 2020 when notifications were sent regarding her arrest, presentment, and bail hearing. It explicitly mentions notifications sent to individuals identifying as victims of both Ghislaine Maxwell and Jeffrey Epstein, even those not named in the indictment.

This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan requesting a two-week extension (until Nov 23, 2020) to produce electronic discovery in the case against Ghislaine Maxwell. The delay is attributed to an outside vendor needing more time to process data from electronic devices seized by the FBI from Jeffrey Epstein's residences in NY and the Virgin Islands in 2019. The letter details the history of the data seizure, privilege reviews requested by Epstein's estate, and mentions that over 350,000 pages of discovery have already been produced.

This document is an excerpt from Chapter 37 of a book (likely 'Filthy Rich'), detailing journalist Vicky Ward's investigation into Jeffrey Epstein for Vanity Fair in October 2002. It describes how Epstein mobilized high-profile friends like Les Wexner and the head of Bear Stearns to pressure Ward, while simultaneously attempting to charm her personally with a tour of his Manhattan mansion. The text also briefly notes Ghislaine Maxwell's role in teaching Epstein social etiquette.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022. It details the direct examination of a witness (likely Meder) by prosecutor Ms. Comey regarding the admission of Government Exhibits 317 and 318. Both exhibits are identified as photographs showing Ghislaine Maxwell and Jeffrey Epstein together, retrieved from a CD logged as evidence number 1B75.

This document contains four phone message slips from a spiral-bound book, dated July 25, 2004, and August 2 (presumably same year). Messages are directed to Jeffrey Epstein and 'Sara'. Key interactions include Ghislaine Maxwell instructing staff (Nicole Hesse) to move framed photos and leaving a message for Epstein demanding he call her. Another message mentions unnamed individuals being 'available all weekend'.

This Reuters article, dated January 5, 2022, reports on the jury deliberations in the Ghislaine Maxwell trial. A juror, Scotty David, revealed that some jurors initially doubted the credibility of two accusers' memories. David, a survivor of childhood sexual abuse himself, shared his personal experience with the jury, which helped them understand trauma's effect on memory and ultimately led to a unanimous guilty verdict against Maxwell on December 29, 2021.

This is a page from a court transcript (Case 1:20-cr-00330-PAE) documenting the direct examination of a witness named Carolyn by Ms. Comey. The testimony covers the identification of Carolyn's mother (Dorothy) and describes phone calls from Ghislaine Maxwell to schedule appointments, during which Maxwell would mention she and Jeffrey Epstein were 'flying in' from out of town.

This document is page 110 of a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Carolyn. She testifies that while she was nude setting up a massage table at Jeffrey Epstein's house, Ghislaine Maxwell entered, touched her breasts, hips, and buttocks, and commented that she had a 'great body for Mr. Epstein and his friends.' The testimony confirms that Epstein entered the room immediately after Maxwell left.

This document is a flight log page (page 95) signed by pilot David Rodgers, covering flights from July 13 to August 28, 2002. It documents significant flights involving Jeffrey Epstein (JE) and Ghislaine Maxwell (GM) traveling with former President Bill Clinton, Doug Band, and Secret Service agents from Morocco to New York. Additionally, it records Virginia Roberts traveling with Epstein and Maxwell from Santa Fe to Teterboro, and then to Palm Beach.

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 page 17 of a federal indictment filed on July 2, 2020, detailing 'Count Six' (Perjury) against Ghislaine Maxwell. It alleges that on July 22, 2016, during a deposition for civil case 15 Civ. 7344 in the SDNY, Maxwell knowingly gave false testimony regarding her knowledge of sex toys at Jeffrey Epstein's Palm Beach house and her interactions with minors.

This is a page from a legal filing (Government's opposition) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The prosecution argues that the defendant's claims of prejudice due to pre-indictment delay—specifically citing dead witnesses, lost Epstein employees, and corrupted memories—are insufficient to warrant dismissal based on established legal precedents. The document cites various case laws (Marion, Snyder, Iannelli, King) to support the position that fading memories or unavailable witnesses are inherent in delays and do not automatically constitute actual prejudice.

This document is a page from a court transcript (Rebuttal by Ms. Comey) filed on August 10, 2022, in the case against Ghislaine Maxwell. The prosecutor argues that the testimonies of victims Jane, Kate, Carolyn, and Annie are credible specifically because they did not exaggerate Maxwell's involvement (e.g., admitting she wasn't always in the room or only touched them in specific ways), contrasting this with 'better lies' they could have told if fabricating the story. The text details specific sexual acts and interactions attributed to Maxwell and Epstein.

This document is a court transcript from a direct examination of a witness named Rodgers. The testimony focuses on two flights from July 2001, confirming that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were passengers on a flight from Santa Fe to Teterboro. It also establishes that Jeffrey Epstein and Virginia Roberts were the only two passengers on a subsequent flight from St. Thomas to Palm Beach.

This document is page 5 of a defense filing (dated June 24, 2022) related to the sentencing of Ghislaine Maxwell. It argues that the definition of 'victim' under the CVRA is narrower than sentencing guidelines and asserts that Maxwell's due process rights must be protected against new allegations in victim impact statements from accusers Annie Farmer and 'Kate' that were not cross-examined at trial. The document also attempts to impeach the credibility of Virginia Giuffre, noting she did not testify and alleging in a footnote that she failed to disclose prior abuse by a man named Ron Eppinger.

This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues she is not a flight risk and that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions more severe than USP Florence ADMAX, hindering her ability to prepare her defense. It claims prison wardens have noted the unprecedented nature of her restrictive regime.

This document is a page from a court transcript (summation by Ms. Moe) filed on August 10, 2022. The prosecutor argues that Ghislaine Maxwell was fully aware of and managed the abuse in Epstein's Palm Beach home, citing a 2002 document authored by 'G. Max' listing massage oils, and testimony from Mr. Alessi regarding the cleaning and storage of sex toys in Maxwell's closet.

This document is a page from the court transcript of the direct examination of witness A. Farmer (Annie Farmer) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE). The testimony details a weekend trip where Farmer, Jeffrey Epstein, and Ghislaine Maxwell left 'the ranch' to go shopping in a nearby town. Specific events include Maxwell purchasing henna hair lightening cream for Farmer at a natural food store, and Epstein purchasing black leather cowboy boots for Farmer at a western wear store.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness named Kate. Kate recounts how she first met Jeffrey Epstein at Ghislaine Maxwell's townhouse, a few weeks after having tea there. Maxwell urgently called Kate, insisting she come over to meet Epstein, who was described as being in his 40s and wearing sweatpants and a hoodie at the time of their meeting.

This document is page 6 of a court filing (Case 1:20-cr-00330-PAE) dated October 13, 2021, filed by Ghislaine Maxwell's defense team. The filing argues that Maxwell has been prejudiced by overwhelming negative media coverage, citing Google search result statistics and a list of specific documentaries, podcasts, and books released about her and Jeffrey Epstein. The defense asserts they have not spoken to the media nor contributed to this publicity.

This document is page 2 (labeled page 6 of 26 in the filing) of a legal defense filing arguing against the detention of Ghislaine Maxwell. It outlines her background, emphasizing her US citizenship, long-term residency, and strong family ties to counter the government's argument that she is a flight risk. It also summarizes the government's position regarding her multiple citizenships and financial means, while refuting the claim that she was 'hiding' from law enforcement.

This Palm Beach Police Department incident report from February 17, 2006, continues the narrative of an interview with an unnamed individual who describes an uncomfortable massage encounter with Jeffrey Epstein. It also contains a separate narrative from January 31, 2006, detailing a police interview with Christina Venero, a licensed massage therapist employed by Epstein for three years, who discusses her professional relationship with Epstein and Ghislaine Maxwell, her rate of pay, and her observations of other women at his residence.

This document is a page from a court transcript filed on August 10, 2022. A witness, identified as Hesse, testifies about being employed around 2003 at the Palm Beach residence of Jeffrey Epstein and Ghislaine Maxwell. The witness states they were hired directly by Ghislaine Maxwell to maintain the home when the owners were not present.

This document is page 18 of a defense motion (filed July 10, 2020) arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell is not a flight risk, citing her decision to stay in the U.S. after Epstein's arrest, and argues that the government overstates the risk posed by the potential length of her sentence. The text cites various legal precedents (Friedman, Sabhnani) to support the claim that a long potential sentence alone is insufficient grounds for detention.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the cross-examination of a witness named Rodgers (likely a pilot). The testimony confirms flight patterns between Teterboro/JFK and Palm Beach, specifically noting that Ghislaine Maxwell was not always present. It specifically identifies a flight on May 4, 2002, from JFK to Palm Beach where the passengers were Jeffrey Epstein and Shelly Lewis.

This is page 2 of a court order filed on June 4, 2021, in the case United States v. Maxwell. The court is addressing Ghislaine Maxwell's request to subpoena the entire journal of 'Minor Victim-2.' The court rejects Maxwell's arguments, characterizing the request as a 'fishing expedition' and noting that impeachment material is generally not obtainable via Rule 17(c) subpoena prior to trial. The document also notes that 'BSF' (likely legal counsel for the victim) has stated the unproduced portions of the journal do not mention Maxwell or Jeffrey Epstein.

This document is a page from a court docket report regarding the case United States v. Ghislaine Maxwell. It details filings from July 2020, specifically focusing on a dispute over a protective order wherein Maxwell sought to publicly reference alleged victims who had previously spoken publicly about her or Jeffrey Epstein. Judge Nathan ruled in favor of the Government, adopting their proposed protective order to protect the privacy and safety of victims and witnesses.

This document is page 21 of a legal indictment (Case 1:20-cr-00330-PAE) filed on March 29, 2021. It details 'Count Eight' against Ghislaine Maxwell for Perjury regarding a deposition she gave on July 22, 2016, in a civil case (15 Civ. 7433). The indictment alleges she knowingly gave false testimony when she denied knowledge of sex toys or devices at Jeffrey Epstein's Palm Beach house.

This document is a legal filing (Page 8 of 77) from June 15, 2022, arguing that Ghislaine Maxwell's pre-sentence detention conditions were punitive and politically motivated to restore DOJ/BOP reputations following Jeffrey Epstein's death. It details a specific incident where a fellow inmate claimed she was offered money to strangle Maxwell in her sleep, highlighting the danger Maxwell faces in general population at the MDC.

This document is a DailyMail article excerpt included in House Oversight evidence (ID 019470). It details Virginia Roberts Giuffre's account of a trip to the Caribbean where Ghislaine Maxwell piloted a helicopter to pick up Bill Clinton. The text highlights Epstein's claim that Clinton 'owed him favours' and describes a dinner involving Clinton, Epstein, Maxwell, and young women flown in from New York.

This document is a court transcript page from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), featuring the direct examination of a witness identified as 'Jane'. Jane testifies about sexual abuse she endured at ages 14, 15, and 16 in the massage room of a New York house (implied to be Jeffrey Epstein's), confirming that Maxwell was present during those years. The testimony includes a detailed description of the massage room, noting it was off the master bathroom, very dark with red lighting, and contained a giant black massage table.

This document is a page from a legal filing (Case 1:20-cr-00330-AJN) arguing for Ghislaine Maxwell's release on bail. The defense argues that she is not a danger to the community, cites the health risks of COVID-19 in prison, and claims she is not a flight risk due to her strong ties to the U.S. (citizenship, 30-year residency, family in NY) and her history of cooperation through counsel since Epstein's arrest.

This document appears to be pages 63-64 from a manuscript by Virginia Giuffre. It details her interactions with Jeffrey Epstein and another woman named Rena in NYC, involving forced sexual acts, bondage, and art. The text concludes with Epstein discarding Rena and preparing the narrator for a trip to France to attend the birthday party of supermodel Naomi Campbell.

This document is a transcript from a legal cross-examination of a witness named Rodgers, filed on August 10, 2022. The questioning focuses on a flight log for 'flight 979' on May 9th from Teterboro to Santa Fe on Jeffrey Epstein's plane. The witness confirms that passengers 'JE' and 'GM' are Jeffrey Epstein and Ghislaine Maxwell, and that a third passenger is listed only by the first name 'Jane', raising questions about her specific identity.

This document is an email chain ending on March 8, 2011, in which Jeffrey Epstein forwards a list of interview questions from journalist Alexandra Wolfe to Mike Sitrick. The questions, originally sent to attorney Jay Lefkowitz, probe Epstein's post-prison life, the status of his $15 billion business, his relationship with Ghislaine Maxwell, and his charitable work with Bill Clinton.

This document appears to be pages 29 and 30 from a manuscript or memoir draft by Virginia Giuffre (indicated by Bates stamps). It details graphic sexual abuse involving Jeffrey Epstein and Ghislaine Maxwell at the El Brillo Way property in Palm Beach. The text describes the grooming dynamic, the specific sexual acts demanded, the involvement of house staff like Juan for payments and transportation, and the narrator's internal distress regarding her exploitation.

This document is page 5 of a Preliminary Statement filed on July 10, 2020, by Ghislaine Maxwell's defense team. It serves as a Memorandum in Opposition to the government's request for detention. The text argues that Maxwell is being unfairly conflated with Jeffrey Epstein, despite having no contact with him for over a decade, and asserts she is not a flight risk as she has lived in the US since 1991 and remained in the country following Epstein's 2019 arrest.

This document is a page from a defense motion filed on December 14, 2020, arguing that Ghislaine Maxwell did not attempt to evade arrest or flee. Defense counsel claims the 'raid' on her New Hampshire home was unnecessary and theatrical, timed to the anniversary of Epstein's arrest. It addresses specific allegations, such as a cell phone wrapped in tin foil, explaining these were security measures against the press, supported by a statement from the (redacted) head of her security team.

This document is a page from a court transcript (United States v. Ghislaine Maxwell) dated August 10, 2022. It features the cross-examination of a witness named 'Jane' by attorney Ms. Menninger regarding Jane's first meeting with Jeffrey Epstein and Ghislaine Maxwell in 1994. The testimony details that Jane was 14 years old, eating ice cream at a picnic table during a break from classes, when she was approached by Maxwell (described as a tall, thin woman with a dog) and subsequently Epstein, who claimed to know Jane's mother.

This document is a 'Find Report' from Shoppers Travel, Inc. listing financial transactions (invoices) from October 30, 2003, to October 1, 2004. It details travel expenses for numerous individuals in Jeffrey Epstein's circle, including Ghislaine Maxwell, Sarah Kellen, Marvin Minsky, and Dr. Mehmet Oz. The report includes invoice numbers, dates, names, specific amounts, and a running balance, with several names redacted by the DOJ.

This document is a transcript of a prosecutor's, Ms. Moe's, summation in the trial of Ghislaine Maxwell. Ms. Moe argues that the government has proven Maxwell's guilt on all six charges, asserting that Maxwell made her own choices and committed crimes in partnership with Jeffrey Epstein. She refutes the defense's opening statement and urges the jury to hold Maxwell accountable based on the evidence presented.

In this court transcript page from the cross-examination of Mr. Alessi, the witness confirms that Jeffrey Epstein was considered 'the boss' and owner. The defense questions Alessi on whether Ghislaine Maxwell's instructions were understood to come directly from Epstein, to which Alessi replies he does not know. The testimony also discusses a 'household manual' and Epstein's hiring of a 'countess' to purportedly create it.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) filed on August 10, 2022, featuring the cross-examination of witness A. Farmer by Ms. Menninger. The testimony focuses on a specific incident where the witness and Ghislaine Maxwell simultaneously gave Jeffrey Epstein a foot massage. The witness states that while there was no touching of private parts, she considered the entire environment to be 'sexualized.'

This document is Page 4 of a court filing (Document 367-1) from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on October 22, 2021. It outlines proposed 'Voir Dire' (jury selection) questions focused on determining if potential jurors have been biased by pretrial publicity regarding Maxwell or Jeffrey Epstein. The document includes sidebar annotations showing a legal dispute where the Government objects to specific questions as repetitive or inappropriate, while the Defense argues they are necessary to ensure an impartial jury, citing case law such as *United States v. Tsarnaev*.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE, US v. Maxwell) featuring the direct examination of witness A. Farmer. The testimony details an incident at a movie theater in New Mexico where Epstein's behavior was described as 'blatant,' followed by an incident at 'the ranch' where Ghislaine Maxwell instructed the witness on how to give Epstein a foot massage while he was barefoot.

This document is a legal letter filed on October 23, 2020, by attorney Jeffrey Pagliuca on behalf of Ghislaine Maxwell, addressed to Judge Alison J. Nathan. The defense argues that the Government has failed to meet discovery deadlines promised during the July 14, 2020, initial conference, particularly regarding investigative files from the Southern District of Florida. The letter criticizes the Government's recent production as lacking substance, noting it consists largely of civil litigation documents and old records related to Jeffrey Epstein rather than the charged conspiracy.

A 2011 Telegraph article reporting that Jeffrey Epstein kept a 'black book' journal listing under-aged victims and celebrity associates, including Bill Clinton and Donald Trump. The article details how a servant at Epstein's Palm Beach manor stole the journal and was imprisoned for trying to sell it, and mentions Prince Andrew's stays at the property where he received daily massages. The document bears a House Oversight Committee Bates stamp.

This is page 50 of a court transcript from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). Witness A. Farmer testifies under direct examination by Ms. Pomerantz about a weekend trip to Epstein's ranch (identifiable by the description of a 'western movie set'). Farmer testifies that she believed Epstein and Maxwell were romantic partners based on their intimate behavior and confirms that she stayed in a 'small residence' on the property with only Epstein and Maxwell.

This document contains pages 162 and 163 from a book (likely a narrative non-fiction like 'Filthy Rich') detailing the background of State Attorney Barry Krischer and incidents related to the Epstein investigation. Page 162 describes witness intimidation involving a woman named Alison being offered money to refuse cooperation, and mentions a private investigator named Ivan Robles monitoring visitors. Page 163 provides a biographical overview of Barry Krischer, noting his career history, awards from figures like Jeb Bush, and his reputation for prosecuting high-profile cases like Rush Limbaugh.

This is page 1 (marked as page 2 of the filing) of a sentencing memorandum filed on June 15, 2022, on behalf of Ghislaine Maxwell. The defense requests a sentence significantly below the guideline range of 292-365 months and below the Probation Department's recommended 240 months. The text argues that Maxwell is being unfairly treated as a proxy for the deceased Jeffrey Epstein, whom the defense characterizes as the true mastermind and principal abuser.

This is a page from a court transcript (cross-examination) filed on August 10, 2022. Attorney Mr. Pagliuca questions witness Ms. Hesse about her knowledge of women visiting Jeffrey Epstein for massages when Ghislaine Maxwell was not present, which Hesse confirms based on messages she took. The testimony also establishes that Hesse knew Maxwell had a home in New York but was unaware of a residence in Miami.

This is a court docket log from the Ghislaine Maxwell case covering July 27-30, 2020. It details the dispute and subsequent ruling on a Protective Order where Maxwell sought to publicly reference alleged victims who had previously spoken to the media about her or Jeffrey Epstein. Judge Alison Nathan ruled in favor of the Government, adopting their proposed protective order to restrict the public identification of victims and witnesses to protect their privacy and safety.

This document is a page from a court transcript (likely a sentencing hearing) detailing Ghislaine Maxwell's managerial role in Jeffrey Epstein's criminal enterprise between 1994 and 2004. The judge cites testimony from pilots (Visoski, Alessi, Rodgers) and notes Maxwell's control over household staff and her own assistants, including Sarah Kellen, to justify legal sentencing enhancements for leading extensive criminal activity.

This document is a page from a court transcript (Case 1:20-cr-00330-AJN) filed on August 10, 2022. It details a legal argument regarding jury instructions in the trial of Ghislaine Maxwell. The Court rules that a 'conscious avoidance instruction' is appropriate because the government argues Maxwell either knew or consciously avoided knowing that the purpose of her travel with Jeffrey Epstein and minors was sexual abuse.

This document is a page from a court transcript (Summation by Ms. Menninger) filed on August 10, 2022. The defense attorney argues that the accuser (Ms. Moe) changed her story between the victims' compensation fund claim (where she received $1.5 million) and her trial testimony regarding sexual abuse by Epstein and Maxwell. The defense also argues Maxwell was in Santa Fe for architectural meetings and had no role in planning the trip involving the accuser, noting that a person named Maria was originally supposed to go.

This document is a page from a court transcript dated August 10, 2022, featuring the direct examination of a witness named Rodgers. Rodgers, a pilot, describes a flight on July 26, 1991, from Teterboro, NJ, to Palm Beach, FL, confirming that Jeffrey Epstein, Ghislaine Maxwell, and two other individuals were passengers. The witness also states that Epstein owned a home on Palm Beach Island.

This document is a court transcript from August 10, 2022, detailing the direct examination of a witness named Meder. The witness identifies a photograph, Government's Exhibit 341, as originating from a CD reviewed during the 'Epstein and Maxwell investigation' and identifies the individuals in the photo as Ghislaine Maxwell and Jeffrey Epstein. The court, addressed by government attorney Ms. Comey, admits the photograph into evidence.

This document is a page from a court transcript (Case 1:20-cr-00330-AJN) involving a legal argument between attorneys Ms. Moe and Mr. Pagliuca before the Judge. The discussion concerns limiting the scope of questioning for a witness (identified in the header as Dubin) regarding 'sexualized massages' and misconduct involving Jeffrey Epstein and Ghislaine Maxwell. Mr. Pagliuca argues that the witness's lack of knowledge regarding inappropriate activity is relevant to why she continued dating 'him' (Epstein).

This page is a transcript from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). A witness named Meder is under direct examination by Ms. Comey regarding evidence collected during the Epstein and Maxwell investigation. The witness identifies Government Exhibit 307 as a photograph of Jeffrey Epstein and Ghislaine Maxwell, retrieved from a CD logged as evidence number 1B26.

This document is an email chain from September 2015 between Ghislaine Maxwell, Jeffrey Epstein (using the alias J Jep/jeevacation), and Darren K. Indyke. The conversation is initiated by Maxwell sharing a Page Six article titled 'ex-teen-prostitute-files-suit-in-billionaire-sex-slave-case'. The subsequent responses between the parties are redacted under privilege claims.

An email chain from March 4, 2011, primarily between Jeffrey Epstein and 'The Duke' (Prince Andrew). The discussion concerns allegations surfacing against Ghislaine Maxwell. The Duke explicitly demands that any legal response clarify he is not involved and knows nothing about the allegations, stating he 'can't take any more of this.' Epstein dismisses the allegations as 'salacious and ridiculous,' joking that the only person Maxwell didn't have sex with was Elvis.

This document is page 25 of a defense filing arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell was not evading arrest but rather avoiding the press, evidenced by the government's ability to easily track her phone. It further argues she is not a flight risk to the UK or France, noting she waived extradition rights and remained in the US following Jeffrey Epstein's arrest and death.

This document is a court transcript of a direct examination of a witness named Rodgers. The witness confirms details of two specific flights: one on May 12, 1997, from Santa Fe, NM to Van Nuys, CA with Jeffrey Epstein as the only passenger, and another, Flight 1105, on May 3, 1998, from Palm Beach, FL to Teterboro, NJ with passengers Jeffrey Epstein, Ghislaine Maxwell, and an individual identified only as 'Jane'.

This document appears to be a forwarded email or list of allegations produced during a House Oversight inquiry (indicated by the footer). It details 14 specific claims regarding Ghislaine Maxwell and Jeffrey Epstein's trafficking of a redacted victim (Jane Doe 102), starting when she was 15. The allegations include forced sexual encounters with high-profile figures such as Prince Andrew, Glenn Dubin, Les Wexner, Ehud Barak, George Mitchell, and Stephen Kosslyn, as well as details about payments, surveillance cameras in Epstein's homes, and a helicopter trip involving Bill Clinton.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022. It details the direct examination of a witness named Meder by prosecutor Ms. Comey, wherein the witness identifies Jeffrey Epstein and Ghislaine Maxwell in photographs derived from a CD (logged as 1B75) seized during their investigation. Government Exhibit 321 is formally admitted into evidence during this exchange.

This document is page 17 of a court filing (Document 136) in the case US v. Ghislaine Maxwell, filed on February 4, 2021. The text describes a dispute over a line of questioning during testimony where an examiner asked Maxwell to list all girls under 18 she had brought to Jeffrey Epstein's house. The defense argues the question was improper, lacked foundation, and asked for recall of events from nearly 20 years prior; the document notes Maxwell admitted she could not make such a list.

This document is a page from a legal filing (Document 97) dated December 14, 2020, arguing against Ghislaine Maxwell being a flight risk. It highlights a letter from her spouse (whose name is redacted) describing their domestic life in the US over the previous four years and asserting that the criminal charges do not resemble the person he knows. The filing also references Jeffrey Epstein's arrest and death in 2019 as the catalyst for a 'media frenzy' affecting the family.