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 | Grooming/abuse | Maxwell groomed and abused multiple girls. For Annie, it started with instructions on massaging E... | N/A | View |
| N/A | N/A | Court's conclusion that perjury charges against Maxwell are legally tenable and appropriately pre... | N/A | View |
| N/A | Legal proceeding | A discussion during a trial regarding a request by the defendant, Maxwell, for a specific jury in... | Courtroom | View |
| N/A | Conviction | Maxwell was convicted on federal sex trafficking charges and two counts of perjury. | N/A | View |
| N/A | Meeting | Mr. Blanche met with Ms. Maxwell, seemingly at her request, to obtain information. | N/A | View |
| N/A | Meeting | The first time Carolyn met the defendant, described as a "scarring memory" for her. | N/A | View |
| N/A | Conversation | Carolyn had conversations with Maxwell where she discussed her upbringing, her mother's alcoholis... | N/A | View |
| N/A | Transfer | Maxwell was recently moved to a lower-security prison without prior notice to victims. | Lower-Security Facility | View |
| N/A | Legal proceeding | The Defendant (Maxwell) contends that Juror 50 was biased due to similarities between his persona... | N/A | View |
| N/A | Meeting | Maxwell met Virginia Roberts. | Mar-a-Lago | View |
| N/A | Conversation | Carolyn told Maxwell that she had been raped and molested by her grandfather starting at the age ... | N/A | View |
| N/A | Invitation | Mr. Epstein and Maxwell invited Carolyn to go to an island. | an island | View |
| N/A | Legal motion | Maxwell's motion for a new trial was denied by the District Court. | District Court | View |
| N/A | Conversation | Maxwell told the witness, Kate, that she owned a house in London. | N/A | View |
| N/A | Conversation | Kate had conversations with Maxwell during tea about Maxwell's personal life and relationships. | N/A | View |
| N/A | Flight | Jane's return flight to New Mexico, which the defendant allegedly aided. | New Mexico | View |
| N/A | Legal proceeding | Discovery process in the Giuffre v. Maxwell case, which included large document productions, resp... | N/A | View |
| N/A | Trip | Carolyn's experiences at 'that house' involving Maxwell. | that house | View |
| N/A | Trip | The witness, Jane, describes spending time at Epstein's house in Palm Beach. | Epstein's house in Palm Beach | View |
| N/A | Crime | The witness, Jane, testifies to being sexually abused by Jeffrey Epstein when she was 14, 15, and... | A room, presumably in one o... | View |
| N/A | Legal proceeding | The Maxwell prosecution, which the document claims was fomented based on information obtained by ... | N/A | View |
| N/A | Hearing | A post-hearing brief was filed by Maxwell, and the court is analyzing testimony from a hearing in... | N/A | View |
| N/A | Legal proceeding | The Government argued that Maxwell's motion to modify the Protective Order should be denied. | N/A | View |
| N/A | Legal argument | Maxwell argues that Judge Nathan should have implied bias in Juror 50 due to similarities between... | District Court | View |
| N/A | Legal proceeding | Two civil depositions of Maxwell were taken in the Giuffre v. Maxwell case, which are the basis f... | N/A | View |
DOJ-OGR-00021143.jpg
This legal document argues for vacating Maxwell's convictions on Counts Three and Four due to a variance between trial proof and indictment allegations. It notes that Jane initially denied sexual abuse in New Mexico to the FBI but later claimed sexual activity with Epstein at a ranch, which was not included in the Mann Act counts. The document concludes that a new trial is necessary for these counts.
DOJ-OGR-00021142.jpg
This legal document argues that Maxwell's conviction on Count Four (substantive transportation) was likely improper. The argument posits that the jury convicted her based on arranging a return flight for 'Jane' from New Mexico after the alleged sexual abuse had already occurred, and the Court's refusal to provide a clarifying instruction allowed this. This potential error also casts doubt on the validity of the conviction for a related conspiracy charge, Count Three.
DOJ-OGR-00021139.jpg
This legal document argues that there is a substantial likelihood that the defendant, Maxwell, was convicted on Counts Three and Four based on conduct that was not charged in the indictment, specifically conduct in New Mexico. The filing contends that the jury was not properly instructed that the charged offense required travel from Florida to New York, potentially leading to an improper conviction based on uncharged acts. This would constitute a constructive amendment of the indictment.
DOJ-OGR-00021137.jpg
This legal document, dated February 28, 2023, is a page from a court filing discussing a legal argument related to a criminal case. It outlines the requirements for a "constructive amendment claim," citing the precedent set in *United States v. D'Amelio*. The context is an appeal or motion by a defendant named Maxwell, who was charged under Count Four with transporting a person named Jane across state lines for sexual activity in violation of New York Penal Law.
DOJ-OGR-00021136.jpg
This legal document, dated February 28, 2023, discusses the conviction of Maxwell on Count Four, which was based on Jane's testimony about sexual activity with Epstein in New Mexico. It argues that the Court's failure to address the jury's misunderstanding, as revealed by a 'Jury Note' concerning the transportation count, warrants vacating Maxwell's convictions on Counts Three and Four and granting a new trial. The document highlights the distinction between the original indictment and the basis for conviction, implicitly linking the 'defendant' in the jury note to Maxwell.
DOJ-OGR-00021132.jpg
This legal document argues that the court incorrectly applied Federal Rule of Evidence 606 to block an inquiry into statements made by Juror 50 to journalists. The author contends that because the juror voluntarily broadcast his experiences and role in the deliberations to convict Maxwell, the rule's purpose of protecting jurors from harassment is not applicable in this specific instance. The document cites 'Tanner v. United States' as precedent for the rationale behind the rule.
DOJ-OGR-00021130.jpg
This legal document, part of case 22-1426, argues that the District Court abused its discretion during a post-trial hearing. The filing contends that the court improperly prevented the defense from cross-examining Juror 50, who, it is argued, would have been dismissed from the jury had he truthfully disclosed the nature of his past abuse during jury selection. The document contrasts the severe abuse suffered by Juror 50 with lesser forms of sexual assault reported by other potential jurors who were not dismissed.
DOJ-OGR-00021125.jpg
This legal document argues that the defendant, Maxwell, was denied her constitutional right to a fair trial. The basis for this claim is that a juror, identified as Juror 50, made false statements on his juror questionnaire and later revealed in interviews that he used his personal history as a victim of child sexual abuse to persuade other jurors to convict. Although the court held a hearing on the matter, it found the juror's testimony credible and denied the defendant's motion for a new trial.
DOJ-OGR-00019634.jpg
This legal document, part of an appellate court filing, argues that the District Court did not abuse its discretion when it denied a motion by Maxwell to modify a protective order. The filing contends that the appellate court should not issue a writ of mandamus and should instead affirm the lower court's decision, as the case does not present the rare and exceptional circumstances required for such intervention.
DOJ-OGR-00019632.jpg
This legal document, part of a court filing, presents the Government's argument against an appeal by Maxwell. The Government contends that Maxwell has failed to show sufficient harm from Judge Nathan's Order to warrant an appeal and that pursuing the appeal is an inefficient use of resources while a criminal case is pending in the District Court.
DOJ-OGR-00019631.jpg
This legal document, part of a court filing, argues against Ghislaine Maxwell's appeal of an unsealing order. The author contends that Maxwell's appeal is improper because the issue can be reviewed after a final judgment, and she has not sufficiently explained how the unsealing would prejudice her criminal case. The document cites legal precedent to assert that Maxwell's appeal does not satisfy the requirements of the collateral order doctrine.
DOJ-OGR-00019630.jpg
This legal document, part of a court filing, argues against an immediate appeal by a party named Maxwell regarding the use of criminal discovery materials. It contends that Maxwell has not met the legal standard for such a review, citing precedents like Flanagan, Martoma, and Guerrero. The document asserts that Maxwell's concerns about privacy and publicity can be adequately addressed during a standard appeal after a final judgment is rendered in her criminal case.
DOJ-OGR-00019626.jpg
This document is page 13 of a legal brief filed on October 2, 2020, in case 20-3061 (Maxwell appeal). The text argues that Maxwell's appeal regarding pretrial discovery materials does not meet the strict requirements of the collateral order doctrine established by the Supreme Court. The Government distinguishes Maxwell's situation from cases she cited (Pichler v. UNITE, Minpeco S.A. v. Conticommodity Servs.), noting those involved intervenors in civil cases rather than parties in criminal cases.
DOJ-OGR-00019625.jpg
This document is page 18 of a legal brief filed on October 2, 2020, in Case 20-3061 (related to Ghislaine Maxwell). The text argues that protective orders regarding discovery documents in criminal cases are not subject to interlocutory appeal, citing Second Circuit precedents like U.S. v. Caparros and U.S. v. Pappas. The argument specifically asserts that Maxwell's jurisdictional arguments fail to meet the criteria for immediate appeal under the collateral order doctrine.
DOJ-OGR-00019621.jpg
This document is a legal filing arguing that the court lacks jurisdiction to hear an appeal by Maxwell. The argument is based on the 'final judgment rule' (28 U.S.C. § 1291), asserting that the order being appealed is not a final decision and does not qualify as an immediately appealable collateral order. The document notes that the Government filed a motion to dismiss the appeal on similar grounds on September 16, 2020.
DOJ-OGR-00019620.jpg
This document is a page from a legal filing that describes a court order issued by Judge Nathan on September 2, 2020. The order denied a motion from Maxwell, finding her arguments for using criminal discovery materials in her civil cases to be vague and unsubstantiated. The document also notes that Maxwell subsequently filed an appeal of this order on September 4, 2020, and a motion to consolidate the appeal on September 10, 2020.
DOJ-OGR-00019619.jpg
This legal document, dated October 2, 2020, outlines the procedural history of a case between the Government and a defendant named Maxwell. It details the Government's arguments against Maxwell's motion to modify a Protective Order, citing her failure to justify using criminal discovery materials in civil litigation. The document also describes conflicting rulings from two courts, "Court-1" and "Court-2," regarding the Government's applications related to sealed grand jury subpoenas.
DOJ-OGR-00019617.jpg
This legal document, dated October 2, 2020, details a dispute in a criminal case concerning a Protective Order. The defendant, Maxwell, sought to modify the order on August 17, 2020, to use discovery materials from her criminal case in separate civil proceedings, despite having previously agreed not to. The Government filed an opposition to this motion on August 21, 2020, citing the original terms of the agreement.
DOJ-OGR-00019615.jpg
This legal document, dated October 2, 2020, outlines a series of events in a criminal case against a defendant named Maxwell. It details that on July 30, 2020, Judge Nathan issued a protective order preventing criminal discovery materials from being used in civil litigation, and on September 2, 2020, denied Maxwell's motion to modify this order. Consequently, Maxwell filed a notice of appeal on September 4, 2020.
DOJ-OGR-00019609.jpg
This document is the Table of Contents for a legal brief filed on October 2, 2020 (Document 82 in Case 20-3061). It outlines arguments asserting that the appellate court lacks jurisdiction to hear the appeal and that the District Court did not abuse its discretion in denying Ghislaine Maxwell's motion to modify a protective order. The document references Judge Nathan and details the structure of the argument spanning 30 pages.
DOJ-OGR-00019482.jpg
This document is a page from a legal indictment against an individual named MAXWELL, filed on July 8, 2020. It outlines specific allegations of sexual abuse and exploitation of three unnamed minors (Victim-1, Victim-2, and Victim-3) between 1994 and 1997. The alleged crimes, which involved a co-conspirator named Epstein, took place in various locations including New York, Florida, New Mexico, and London, England.
DOJ-OGR-00019480.jpg
This legal document alleges that Ghislaine Maxwell groomed and befriended a minor, referred to as Minor Victim-3, in London between 1994 and 1995. Maxwell introduced the victim to Epstein and encouraged her to perform massages, knowing Epstein would sexually abuse her, which he subsequently did. The document further alleges that in a 2016 deposition for a civil case, Maxwell provided false statements under oath to conceal her role in facilitating the abuse.
DOJ-OGR-00019449.jpg
This document is a legal filing, specifically a section from a motion for a stay filed on behalf of Maxwell. It outlines the applicable legal standards for staying a civil action pending the completion of a parallel criminal prosecution. The document cites several legal precedents to argue that while such a stay is an "extraordinary remedy," courts will grant one when justice requires, particularly when there is an overlap of issues between the civil and criminal cases, and lists six factors that guide the court's decision.
DOJ-OGR-00019446.jpg
This legal document, filed on September 14, 2020, outlines the arguments surrounding a motion for a stay in a civil case involving a defendant named Maxwell. Maxwell requested the stay pending her criminal case, a motion supported by the Co-Executors who argued against a partial stay. The Plaintiff vigorously opposed the motion, accusing Maxwell of attempting to gain an unfair discovery advantage.
DOJ-OGR-00019418.jpg
This legal document, part of a court filing, argues that an appeal concerning Judge Nathan's order should proceed. The author contends that the appeal is separate from an ongoing criminal case involving Ms. Maxwell, will not cause delays, and that waiting for the criminal trial to conclude would render the issue moot. The document references a stay on Judge Preska's order to unseal deposition material as a reason for the current proceedings.
| 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 |
Famous people (e.g., Prince Andrew, Donald Trump)
The witness, Kate, states that Maxwell might be talking on the phone about her famous friends while Kate was present.
Reply brief
A filing titled "Maxwell Reply" is cited, where the Defendant raises an argument in a footnote for the first time.
Small talk during massage
making small talk
Legal Review
Review of discovery materials
Request to question Juror 50
Renewing request to question Juror 50 directly and proposing twenty-one pages of questions.
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.
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.
Rule 29 Motion for Acquittal
A brief cited as "Maxwell Br. at 30" where the Defendant requests a judgment of acquittal on all counts.
Scheduling massage appointments
The question implies that Maxwell would call Carolyn to schedule massage appointments with Jeffrey Epstein, even after learning she was 14.
Massage
MAXWELL sent an unsolicited message to Minor Victim-2, during which Minor Victim-2 was topless.
Scheduling sexualized massages
Maxwell called Carolyn to schedule sexualized massages while Maxwell was in New York.
Scheduling appointments
Maxwell would call Carolyn to ask if she was available for an appointment, sometimes mentioning that she and Mr. Epstein would be out of town and flying in.
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.
Civil Case Testimony
Testimony given by Maxwell in a civil case (Giuffre v. Maxwell).
Epstein's whereabouts
Maxwell informing Carolyn that Epstein was on a jog or would be back soon and that she could go upstairs to set up.
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.
Scheduling massages
Maxwell calling Carolyn to schedule sexualized massages when Maxwell was in New York.
Spending time vs Communicating
Witness clarifies distinction between spending physical time vs communicating. States she stopped spending time around age 24.
Reconsideration of response
Seeking reconsideration claiming constructive amendment or prejudicial variance.
Massage
MAXWELL sent an unsolicited message to Minor Victim-2, during which Minor Victim-2 was topless.
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.
Instruction to undress
She told me to get undressed.
Staff rules and operation of the Palm Beach residence
A household manual dictated the operation of the Palm Beach residence and included rules for staff, such as to 'see nothing, hear nothing, say nothing'.
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