MAXWELL
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
GOVERNMENT
|
Legal representative |
15
Very Strong
|
29 | |
|
person
Judge Nathan
|
Judicial |
14
Very Strong
|
16 | |
|
person
Epstein
|
Business associate |
13
Very Strong
|
30 | |
|
location
UNITED STATES OF AMERICA
|
Legal representative |
13
Very Strong
|
18 | |
|
person
Judge Nathan
|
Legal representative |
13
Very Strong
|
20 | |
|
person
Jeffrey Epstein
|
Business associate |
13
Very Strong
|
11 | |
|
person
Epstein
|
Legal representative |
13
Very Strong
|
15 | |
|
person
Juror 50
|
Legal representative |
12
Very Strong
|
22 | |
|
location
United States
|
Legal representative |
12
Very Strong
|
9 | |
|
person
Giuffre
|
Legal representative |
11
Very Strong
|
28 | |
|
person
Epstein
|
Friend |
11
Very Strong
|
19 | |
|
person
Epstein
|
Co conspirators |
11
Very Strong
|
56 | |
|
organization
The government
|
Legal representative |
11
Very Strong
|
15 | |
|
organization
district court
|
Legal representative |
11
Very Strong
|
11 | |
|
person
Epstein
|
Co conspirator |
10
Very Strong
|
6 | |
|
location
USA
|
Legal representative |
10
Very Strong
|
5 | |
|
organization
The Court
|
Legal representative |
10
Very Strong
|
6 | |
|
organization
GOVERNMENT
|
Adversarial |
10
Very Strong
|
14 | |
|
person
Brown
|
Legal representative |
10
Very Strong
|
6 | |
|
person
Epstein
|
Professional |
10
Very Strong
|
9 | |
|
person
CAROLYN
|
Perpetrator victim |
10
Very Strong
|
7 | |
|
person
Kate
|
Acquaintance |
10
Very Strong
|
8 | |
|
person
Judge Nathan
|
Professional |
10
Very Strong
|
17 | |
|
person
Epstein
|
Association |
10
Very Strong
|
10 | |
|
person
CAROLYN
|
Professional |
10
Very Strong
|
10 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Jury selection for Maxwell's trial, including a jury questionnaire where Juror 50 failed to accur... | District Court | View |
| N/A | N/A | District Court denies Maxwell's motion for a new trial. | District Court | View |
| N/A | N/A | Maxwell's indictment was denied, trial proceeded, and she is serving a 20-year sentence. | N/A | View |
| N/A | N/A | District Court's findings and application of sentencing guidelines, including a four-level leader... | N/A | View |
| N/A | N/A | Relocation of victims from Palm Beach to other places in the U.S. (including Southern District of... | Palm Beach, other places in... | View |
| N/A | N/A | Maxwell moved for rehearing en banc, which was denied. | N/A | View |
| N/A | N/A | Maxwell's motion to compel discovery from the Government, including Jencks Act, Brady, Giglio mat... | Court proceedings | View |
| N/A | N/A | Court's ruling on Maxwell's discovery requests, concluding she is not entitled to expedited disco... | Court proceedings | View |
| N/A | N/A | Maxwell's motion is being considered by the Court. | N/A | View |
| N/A | N/A | Court's consideration of categories of questions Maxwell argues are ambiguous. | N/A | View |
| N/A | N/A | Argument by Maxwell that perjury counts should be dismissed due to immateriality of statements. | N/A | View |
| N/A | N/A | Government's intention to produce 'Materials' to the defendant (Maxwell) under a protective order... | N/A | View |
| N/A | N/A | S2 superseding indictment moots Maxwell's grand jury challenge | N/A | View |
| N/A | N/A | Negotiation of expedited discovery timeline | N/A | View |
| N/A | N/A | Maxwell's motion to dismiss perjury counts from a civil case deposition. | N/A | View |
| N/A | N/A | Maxwell contends that the NPA bars her prosecution as a co-conspirator of Jeffrey Epstein. | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss Mann Act counts for lack of specificity or to compel Government to s... | N/A | View |
| N/A | N/A | Maxwell's sentencing to concurrent terms of imprisonment (60, 120, 240 months) followed by superv... | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss indictment due to alleged actual prejudice from Government's delay i... | N/A | View |
| N/A | N/A | Legal arguments by Maxwell to dismiss indictment | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss indictment based on fabricated stories and perjurious conspiracy by ... | N/A | View |
| N/A | N/A | Maxwell seeks writ of mandamus to direct District Court to modify protective order. | N/A | View |
| N/A | N/A | Maxwell seeks to consolidate her criminal appeal with civil appeal Guiffre v. Maxwell, No. 20-241... | N/A | View |
| N/A | N/A | Court denies Maxwell's motions to consolidate as moot. | N/A | View |
| N/A | N/A | Maxwell appeals denial of motion to modify a protective order. | N/A | View |
DOJ-OGR-00021770.jpg
This document is page 28 of a legal appellate brief (Case 22-1426) filed on July 27, 2023, arguing that Ghislaine Maxwell's conviction should be overturned due to 'Juror 50's' bias. The text contends that Juror 50 failed to disclose his own history of sexual abuse during voir dire, which later caused him to improperly identify with prosecution witnesses and influence other jurors based on his personal trauma rather than the evidence alone.
DOJ-OGR-00021769.jpg
This legal document argues that the defendant, Maxwell, was denied a fair trial because the court failed to explore potential bias in a seated juror (Juror 50). The filing draws an analogy to the case of Nieves, asserting that the court's refusal to investigate the juror's background related to child sexual abuse—a central theme in Maxwell's case due to her association with Epstein—deprived the defense of the opportunity to challenge the juror for cause. The document contends this failure is particularly significant given the pervasive community bias against those accused of sex trafficking.
DOJ-OGR-00021766.jpg
This page from a legal document, dated July 27, 2023, argues that the District Court abused its discretion in the case against Maxwell. The argument focuses on the court's handling of Juror 50, whose failure to provide truthful answers during voir dire and whose personal life experiences mirrored trial testimony, should have been grounds for a challenge for cause due to unexplored potential bias.
DOJ-OGR-00021751.jpg
This legal document from July 27, 2023, argues that Ms. Maxwell has legal standing to enforce a Non-Prosecution Agreement (NPA) as a third-party beneficiary. It cites precedent from the Second and Seventh Circuits to support the claim that the immunity granted in the NPA should prevent the United States from prosecuting her in the Southern District of New York. The document asserts that the District Court has already correctly found in Maxwell's favor on this point.
DOJ-OGR-00021737.jpg
This legal document, part of an appeal, outlines the court's findings regarding Ghislaine Maxwell's supervisory role over Sarah Kellen. It cites testimony from Epstein's pilots and evidence from trial, such as flight logs and Kellen's scheduling of illicit massages under Maxwell's direction, to affirm that Maxwell led Kellen. The document dismisses Maxwell's argument that another person was her assistant, emphasizing that the key issue was Maxwell's exercise of authority over Kellen, not formal job titles.
DOJ-OGR-00021735.jpg
This legal document, page 75 of a filing dated June 29, 2023, presents arguments defending the conviction of Maxwell. It counters Maxwell's claims by stating the jury's verdict was plausible and not based on speculation, and that there was no variance between the indictment and the trial proof regarding events in New Mexico. The document asserts Maxwell had 'fair and adequate notice' of the charges, citing the government's disclosure of an interview with the victim, Jane, weeks before the trial.
DOJ-OGR-00021734.jpg
This legal document, part of an appeal (Case 22-1426), argues against Ghislaine Maxwell's interpretation of a jury note from her trial. The prosecution contends the jury's question about her guilt based on events in New Mexico was a valid inquiry into her intent, not a misunderstanding of the law. The document also refutes Maxwell's claim of insufficient evidence regarding her arrangement of a victim's (Jane's) return flight from New Mexico, suggesting the jury could have reasonably convicted her on that basis despite a lack of specific documentary proof.
DOJ-OGR-00021729.jpg
This legal document excerpt from a court case details a judge's decision to reject a jury instruction proposed by the defendant, Maxwell. Judge Nathan ruled that Maxwell's requested instruction was incorrect, explaining that alleged sexual activity with the victim, Jane, in New Mexico could be relevant to proving intent for the charges under New York law. The judge ultimately decided to redirect the jury back to the original charge rather than adopt the defense's proposed language.
DOJ-OGR-00021728.jpg
This legal document details a specific event during the jury deliberations in the trial of Maxwell. The jury sent a note to Judge Nathan questioning whether Maxwell could be found guilty on Count Four if she only aided in the victim Jane's return flight, not the initial flight to New Mexico where the criminal intent was allegedly formed. Judge Nathan found the question too complex and referred the jury back to the original instructions, prompting Maxwell to file a letter that night challenging the judge's response.
DOJ-OGR-00021727.jpg
This legal document, part of Case 22-1426, details the Government's arguments during the trial of Maxwell, focusing on the legal requirement that the criminal conduct was directed at New York. The prosecution argued that transporting victims like Jane to New York and intending for abuse to occur there was sufficient for conviction, even if the abuse itself happened elsewhere. The document also mentions the District Court's jury instructions, which focused on Maxwell's intent for sexual activity to take place in New York.
DOJ-OGR-00021723.jpg
This page from a legal document refutes an argument by the defendant, Maxwell, that the trial judge, Judge Nathan, erred by not finding implied bias in Juror 50. The document argues that under existing case law (citing Torres and Greer), a juror's similar personal experience does not automatically necessitate dismissal, and that there were significant differences between Juror 50's childhood abuse and the abuse discussed in the trial.
DOJ-OGR-00021722.jpg
This legal document details the rejection of defendant Maxwell's appeal arguments concerning Juror 50. Judge Nathan found Maxwell's claim of implied bias, based on the juror's personal history, to be unfounded, noting that the defense failed to pursue follow-up questions during voir dire. The document upholds Judge Nathan's determination that Juror 50 was credible, despite erroneous questionnaire answers, and that his post-verdict statements were properly disregarded.
DOJ-OGR-00021720.jpg
This page is from a legal brief (likely by the Government/DOJ given the footer) in the appeal of Ghislaine Maxwell (Case 22-1426). It argues against Maxwell's claim for a new trial based on 'Juror 50's' failure to disclose prior sexual abuse. The text cites legal precedents (McDonough, Shaoul, Langford) to establish that a new trial requires 'deliberate dishonesty' by a juror, not just an honest mistake, and asserts that Juror 50 was genuinely surprised by the questionnaire content.
DOJ-OGR-00021719.jpg
This legal document discusses an appeal by a party named Maxwell, who is attempting to overturn a jury verdict due to errors made by Juror 50 on a questionnaire. The document outlines Judge Nathan's findings from a hearing, where she concluded that the juror's errors were inadvertent and his testimony was credible. Judge Nathan's opinion is that there are insufficient grounds to justify overturning the verdict based on this issue.
DOJ-OGR-00021715.jpg
This legal document details the District Court's decision, specifically Judge Nathan's denial of Maxwell's motion for a new trial. Judge Nathan's ruling was based on her assessment of Juror 50's testimony during a hearing, where she found his answers credible and concluded that his personal experiences did not compromise his impartiality, and that he would not have been struck for cause.
DOJ-OGR-00021713.jpg
This document is a page from a legal brief (Case 22-1426) detailing the procedural history of a hearing concerning 'Juror 50' in the Ghislaine Maxwell trial. It describes how Judge Nathan ordered a hearing to investigate whether Juror 50 failed to answer jury selection questions truthfully regarding past sexual abuse. The document notes that on March 8, 2022, Juror 50 testified under immunity and admitted that his answers to specific questions (25 and 48) were inaccurate.
DOJ-OGR-00021712.jpg
This legal document describes the statements and actions of Juror 50 in a criminal case involving a defendant named Maxwell. During jury selection, Juror 50 affirmed his impartiality and denied on a questionnaire that he or his family had ever been victims of sexual abuse or crime. However, in post-verdict interviews with journalists, he revealed he was a survivor of childhood sexual abuse, stating he had "flew through" the questionnaire but believed he answered honestly.
DOJ-OGR-00021708.jpg
This document is page 61 of a legal brief filed on June 29, 2023 (Case 22-1426), likely by the government in response to an appeal by Ghislaine Maxwell. The text argues that case law cited by Maxwell regarding the 'essential ingredient' test and statutes of limitations (specifically Bridges, Scharton, and Noveck) is distinguishable and inapplicable to her case involving sexual abuse of a child (18 U.S.C. § 3283). It asserts that Congress intended a broader application for child sexual abuse statutes compared to the fraud statutes discussed in the cited cases.
DOJ-OGR-00021707.jpg
This legal document presents an argument against Maxwell's interpretation of Section 3283 of the U.S. Code. The author refutes Maxwell's claim that the phrase "offense involving" requires a narrow, elements-based analysis, citing precedents like *Weingarten* and *Nijhawan* to support a broader, circumstance-specific approach. The document distinguishes the cases cited by Maxwell by arguing they involved different statutory language, specifically definitions of a "crime of violence," which are not present here.
DOJ-OGR-00021703.jpg
This document is page 43 (PDF page 56) of a government legal brief filed on June 29, 2023, in the appeal case of United States v. Maxwell (Case 22-1426). The text argues against Maxwell's claim that Counts Three and Four do not constitute offenses involving the sexual abuse of a child because no completed sex act occurred. The government argues that under 18 U.S.C. § 3283 and § 3509(k), the definition of sexual abuse is broader and includes employment, persuasion, and enticement.
DOJ-OGR-00021702.jpg
This legal document, dated June 29, 2023, presents an argument regarding the application of Section 3283 to charges against Maxwell for transporting a minor for illegal sexual activity. Maxwell contends the statute doesn't apply because a completed sex act isn't an element of the charge, but the document counters that trial evidence, including testimony from a victim named Jane, established that her offenses did involve completed sex acts. A footnote adds that Judge Nathan found another charge, Count Six, to be timely based on the retroactive application of a different statute, § 3299.
DOJ-OGR-00021701.jpg
This document is a page from a legal brief (likely by the Government) appearing in the appellate case of United States v. Maxwell (Case 22-1426). It argues that the statute of limitations for the charges against Maxwell had not expired due to the 2003 amendment to Section 3283. The text supports Judge Nathan's lower court ruling that applying this amendment was not an impermissible retroactive effect, distinguishing Maxwell's situation from the precedent set in United States v. Richardson.
DOJ-OGR-00021699.jpg
This legal document argues that the extension of the statute of limitations for charges against Maxwell was legally sound. It cites multiple court cases (Enterprise, Weingarten, Cruz v. Maypa) to support the conclusion of Judge Nathan that since the original limitations period had not expired, Maxwell was not deprived of a vested right. The document further asserts that such an extension does not violate the Ex Post Facto Clause of the Constitution.
DOJ-OGR-00021698.jpg
This legal document discusses discrimination claims and the application of statutes of limitations. It references previous cases such as Landgraf and Enterprise, and considers the retroactive effect of revised statutes of limitations, particularly in the context of securities fraud claims and child sexual abuse cases involving Maxwell.
DOJ-OGR-00021695.jpg
This legal document argues that the legislative history of a statute of limitations for child sex abuse offenses demonstrates Congress's clear intent for a 2003 amendment to apply retroactively to pre-enactment conduct. It cites a conference report and the 9th Circuit case United States v. Sure Chief to support its position. The document also refutes an argument by Maxwell that the statute's language is only "forward-looking," using a hypothetical offense from the year 2000 to illustrate the amendment's intended effect.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Paid | MAXWELL | Court/Government | $250,000.00 | Fine imposed on each count. | View |
| N/A | Paid | MAXWELL | Court/Government | $750,000.00 | Total fine imposed. | View |
| 2022-06-29 | Paid | MAXWELL | Court/Government | $750,000.00 | Criminal fine imposed at sentencing. | View |
| 1999-10-19 | Received | Financial Trust C... | MAXWELL | $18,300,000.00 | Transfer sourced from the sale of JP Morgan Ins... | View |
| 1999-10-19 | Received | Financial Trust C... | MAXWELL | $0.00 | Transfer to Maxwell discussed in email; investi... | View |
Scheduling massages with Jeffrey Epstein
Carolyn named Maxwell as one of two people who would call her to schedule massages with Jeffrey Epstein.
Culture of silence
Maxwell directed employees at Epstein's households to 'see nothing, hear nothing, say nothing' regarding the sexual abuse that occurred.
Mr. Epstein's status
Maxwell would inform Carolyn upon her arrival that Mr. Epstein was out for a jog but would be back any moment, and that Carolyn could go upstairs and set up.
Travel
Maxwell told Kate that she was very accommodating and that whenever Kate wanted to visit, Maxwell and others ('they') would take care of everything. This conversation happened before Maxwell gave Kate a handbag.
Setting up appointment times for so-called massages
Maxwell would call Carolyn to set up appointments for massages, particularly in the first year or two.
Travel
Maxwell told Kate that she was very accommodating and that whenever Kate wanted to visit, Maxwell and others ('they') would take care of everything. This conversation happened before Maxwell gave Kate a handbag.
Culture of silence
Maxwell directed employees at Epstein's households to 'see nothing, hear nothing, say nothing' regarding the sexual abuse that occurred.
Minor Victim-3's life and family
MAXWELL discussed Minor Victim-3's life and family with her as part of the grooming process.
Maxwell Reply
A reply brief filed by the Defendant, Maxwell, which raises an argument about the jury instructions.
Instruction to touch Epstein
According to Kate's testimony, when Maxwell introduced her to Epstein, Maxwell told her to give his feet a squeeze to show how strong she was.
General life updates and invitations
The witness (Kate) testifies that she communicated with Maxwell by phone. Maxwell would ask about her life, if she was dating, and if she wanted to visit. Sexual topics were not discussed on the phone.
Scheduling an appointment for Carolyn
Carolyn's mom would receive a phone call, which Carolyn later learned was from Maxwell, and would hand the phone to Carolyn to schedule an appointment.
Scheduling an appointment for Carolyn
Shawn would receive a phone call from Maxwell and would then tell Carolyn that she had a phone call and instruct her to say yes to the appointment.
Reconsideration of the District Court's response
Maxwell filed a letter seeking reconsideration of a response from the District Court, claiming it resulted in a constructive amendment or prejudicial variance.
Travel and an invitation to an island
Maxwell asked Carolyn about her travel history and invited her to an island. Carolyn declined, stating she was too young and her mother would not permit it.
Scheduling massage appointments
The question implies that Maxwell would call Carolyn to schedule massage appointments with Jeffrey Epstein, even after learning she was 14.
Carolyn's career aspirations
Maxwell asked Carolyn what she wanted to do in the future, and Carolyn replied that she wanted to become a massage therapist.
Epstein's sexual preferences and needs
Maxwell told the witness, Kate, that Epstein likes 'cute, young, pretty' girls and that he needed to have sex about three times a day. These conversations occurred frequently ('All the time') within the first couple of months after they met.
Massage
MAXWELL sent an unsolicited message to Minor Victim-2, during which Minor Victim-2 was topless.
Massage
MAXWELL sent an unsolicited message to Minor Victim-2, during which Minor Victim-2 was topless.
Reconsideration of response to jury note
Maxwell filed a letter seeking reconsideration of Judge Nathan's response to the jury's note and raised issues of constructive amendment or prejudicial variance.
Taking over the house
Maxwell told Juan Alessi that she was taking over the house right away when she arrived.
Reply to Government's Opposition
A reply brief cited as "Maxwell Reply at 18" where the Defendant asserts the government failed to prove its case.
Rule 29 Motion for Acquittal
A brief cited as "Maxwell Br. at 30" where the Defendant requests a judgment of acquittal on all counts.
Massages
Maxwell asked Annie if she had ever received a massage and told her she would have the opportunity to have one, describing how enjoyable it would be.
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