HADDON, MORGAN & FOREMAN P.C.
OrganizationRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Legal representative |
7
|
2 | |
|
person
Jeffrey S. Pagliuca
|
Professional employment |
6
|
1 | |
|
person
Laura A. Menninger
|
Professional employment |
6
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2021-02-04 | Court filing | Document 145 was filed in Case 1:20-cr-00330-AJN. | N/A | View |
21-770_Documents%20Pt%202%20of%203.pdf
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.
EFTA00031918.pdf
This document is a Reply Memorandum filed on March 16, 2021, by Ghislaine Maxwell's defense team in support of her third motion for bail. The defense proposes a comprehensive bail package including a $28.5 million bond, asset monitoring by a retired federal judge, and renunciation of her British and French citizenships to mitigate flight risk concerns. Attached as Exhibit A is a legal opinion from French attorney William Julié arguing that if Maxwell renounces her French citizenship, she would no longer be protected from extradition by France, countering the French Ministry of Justice's position.
EFTA00029816.pdf
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.
EFTA00029100.pdf
This legal filing is a Reply Memorandum by Ghislaine Maxwell's defense team, arguing for the suppression of evidence and dismissal of charges based on government misconduct. The defense asserts that prosecutors misled Chief Judge McMahon about the extent of their prior coordination with civil attorneys (Boies Schiller Flexner) to obtain a grand jury subpoena, thereby circumventing a civil protective order. The document details a specific meeting on February 29, 2016, where civil attorneys 'pitched' the prosecution of Maxwell and provided documents, including flight records (though the specific flight data is not listed in this text), which the prosecution later failed to disclose to the judge.
EFTA00028974.pdf
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.
EFTA00028968.pdf
This document is a Reply Memorandum filed on March 15, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that Counts 1 and 3 of the Superseding Indictment are multiplicitous (charging the same crime twice based on identical facts) and requests the Court order the government to elect one count to prosecute and dismiss the other prior to trial to avoid jury prejudice. The filing contends that the government has failed to prove the existence of two distinct conspiracies.
EFTA00028929.pdf
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.
EFTA00028903.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts one through four of her indictment as time-barred. The defense argues that the 2003 Amendment to 18 U.S.C. § 3283, which extended the statute of limitations, cannot be applied retroactively because Congress explicitly rejected a retroactivity provision. Additionally, the defense contends that the Mann Act offenses charged (enticement to travel and transportation of a minor) do not 'necessarily entail' the sexual abuse of a child, and thus the extended statute of limitations under § 3283 does not apply.
EFTA00028880.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting her motion to dismiss the indictment based on the Non-Prosecution Agreement (NPA) Jeffrey Epstein signed in Florida. Maxwell argues that the NPA's clause immunizing 'potential co-conspirators of Epstein' explicitly covers her and bars the current prosecution in the Southern District of New York. The defense contends that the government's attempt to limit the NPA geographically (to Florida) or to specific crimes is contradicted by the plain text of the agreement and legal precedent regarding plea agreements.
EFTA00023047.pdf
This document is a 'Notice of Motion' filed on January 25, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The motion seeks to suppress all evidence obtained from a government subpoena to the law firm Boies Schiller and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The document lists the legal counsel representing Maxwell.
EFTA00021944.pdf
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.
EFTA00021019.pdf
This document is a Notice of Motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell (20 Cr. 330). The defense team, consisting of attorneys from three separate law firms, formally requests a severance and separate trial for Counts Five and Six of the Superseding Indictment. The filing includes the attorneys' contact information and signatures.
EFTA00019291.pdf
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.
EFTA00018709.pdf
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.
EFTA00018214.pdf
This document is a subpoena from the US District Court (SDNY) in the case of USA v. Ghislaine Maxwell, issued to Jordana Feldman of the Epstein Victim's Compensation Program (EVCP). The defense (Maxwell's legal team) is demanding the production of all claim forms, communications, payment records, and releases related to four specific (redacted) accusers who submitted claims to the EVCP. The deadline for production was set for November 29, 2021.
EFTA00016206.pdf
This document is a motion in limine filed by Ghislaine Maxwell's defense team on October 18, 2021, seeking to exclude evidence offered by the government under Rule 404(b) due to lack of proper notice. The defense argues the government failed to identify specific evidence or articulate a non-propensity purpose for its admission. The motion references disputed evidence including emails between Maxwell and 'influential men' regarding dates, testimony from a former Epstein employee (2005-06) regarding 'sexualized massages,' and various exhibits including flight logs (GX-661 & 662) and financial statements.
EFTA00015303.pdf
This document is a legal memorandum filed on January 25, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The motion seeks to suppress evidence obtained via a grand jury subpoena issued to a third party (name redacted) and to dismiss Counts Five and Six of the indictment. The defense argues that the subpoena violated the Fourth Amendment due to overbreadth and lack of a warrant, violated the 'Martindell' doctrine regarding the sanctity of protective orders in civil litigation, and infringed upon Maxwell's Fifth Amendment rights against self-incrimination regarding her 2016 civil deposition testimony.
EFTA00011115.pdf
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.
EFTA00011096.pdf
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.
EFTA00010224.pdf
This document is a subpoena issued by the defense team of Ghislaine Maxwell (Case No. 20CR330) to an undisclosed recipient (likely an administrator of the Epstein Victims' Compensation Program). The subpoena demands the production of materials submitted by accusers to the EVCP, including claim forms, communications, payment records, and releases. Attached to the subpoena is the 'Independent Epstein Victims' Compensation Program Protocol' (dated May 29, 2020), which details the rules, eligibility requirements, and procedures for victims seeking compensation from the Epstein Estate, noting that the program is voluntary, independent, and confidential.
EFTA00010045.pdf
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.
DOJ-OGR-00008435.jpg
This document is the signature page (page 5 of 5) of a legal filing dated December 15, 2021, addressed to Judge Alison J. Nathan in the case regarding Ghislaine Maxwell. It lists the contact information and signatures of Maxwell's defense attorneys: Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim.
DOJ-OGR-00008427.jpg
This document is the third and final page of a legal filing (Document 553) in case 1:20-cr-00330-PAE, dated December 15, 2021, and filed on December 17, 2021. It serves as the signature page for a letter or motion addressed to The Honorable Alison J. Nathan from the legal team representing Ghislaine Maxwell, including attorneys Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim. The document also indicates that a copy was sent via email to the counsel of record.
DOJ-OGR-00008372.jpg
This document is the final page of a legal filing (Document 544) from December 13, 2021, addressed to Judge Alison J. Nathan. Attorneys for Ghislaine Maxwell assert her constitutional right to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as witnesses. The page includes the contact information for her legal counsel from three different law firms.
DOJ-OGR-00008210.jpg
This document is the signature page (page 5 of 5) of a legal filing, Document 521, in case 1:20-cr-00330-PAE, dated December 3, 2021. It is respectfully submitted to The Honorable Alison J. Nathan by the legal team representing Ghislaine Maxwell, which includes attorneys Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim from three different law firms.
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