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 | Production of documents in Giuffre v. Maxwell civil litigation | Civil Court | View |
| N/A | Grand jury proceeding | Maxwell grand jury proceedings | N/A | View |
| N/A | N/A | Carolyn arriving at Epstein's house for massage appointments, entering through the kitchen, and m... | Epstein's house (Kitchen) | View |
| N/A | N/A | Approximately ten flights taken by Dershowitz | Unknown | View |
| N/A | N/A | Employment at Palm Beach House | Palm Beach house | View |
| N/A | N/A | Setting up massage tables | Epstein's house | View |
| N/A | N/A | Production of Giglio and Jencks Act material | N/A | View |
| N/A | N/A | Foot massage instruction session. | The Ranch (New Mexico), in ... | View |
| N/A | N/A | Bail Hearings/Decisions | District Court | View |
| N/A | N/A | Government's Motion to Dismiss | Court | View |
| N/A | N/A | Maxwell's Appeal of the Order | Court of Appeals | View |
| N/A | N/A | Maxwell's Motion to Modify the Protective Order | District Court | View |
| N/A | N/A | Maxwell's Sentencing | Court | View |
| N/A | N/A | S2 Indictment | Southern District of New Yo... | View |
| N/A | N/A | Denial of Motion for New Trial | District Court | View |
| N/A | N/A | The 'first time with Maxwell' | Unspecified | View |
| N/A | N/A | Sentencing hearing where fines were imposed. | District Court | View |
| N/A | Trip | Kate's first visit to Maxwell's townhouse. | Maxwell's townhouse | View |
| N/A | Sexual abuse | MAXWELL involved Minor Victim-1 in group sexualized massages of Epstein, during which MAXWELL and... | Epstein's residences in bot... | View |
| N/A | Travel | Epstein and MAXWELL both encouraged Minor Victim-1 to travel to Epstein's residences. | New York and Florida | View |
| N/A | Grooming/interaction | MAXWELL interacted with Minor Victim-2, who was under 18, at Epstein's residence. Minor Victim-2 ... | Epstein's residence in New ... | View |
| N/A | Social activity/grooming | While in New Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie. | New Mexico | View |
| N/A | Social activity/grooming | While in New Mexico, MAXWELL took Minor Victim-2 shopping. | New Mexico | View |
| N/A | Legal motion | Maxwell presented a motion to Judge Nathan to modify a Protective Order in her criminal case. | Court | View |
| N/A | Legal ruling | Judge Nathan ruled that Maxwell's arguments to modify a protective order failed to establish good... | Court | View |
DOJ-OGR-00010338.jpg
This legal document is a court's analysis of a defendant's motion for a new trial. The defendant argues that Juror 50's failure to disclose a history of sexual abuse denied her the ability to use a peremptory challenge. The court distinguishes the applicable federal law (the McDonough standard) from the New Jersey state law cited by the defendant and begins its analysis of the first prong of the McDonough test, noting that Juror 50 did provide inaccurate answers on a questionnaire.
DOJ-OGR-00010315.jpg
This is page 9 of a legal filing by the Law Offices of Bobbi C. Sternheim, dated March 15, 2022, regarding the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE). The document argues that 'Juror 50' was biased and answered voir dire questions (specifically Question 25 and 49) incorrectly regarding his history of sexual abuse because he does not identify as a 'victim' due to his healing process. The defense argues this psychological coping mechanism prevented accurate answers and demonstrates bias, reiterating objections to the Court's limitation on questioning the juror.
DOJ-OGR-00010219.jpg
This document is a court transcript from a hearing on March 11, 2022, related to the case of United States v. Maxwell. The judge confirms on the record with Juror 50 and his attorney, Mr. Spodek, that the juror will invoke his Fifth Amendment privilege against self-incrimination regarding his answers during jury selection. The court also acknowledges receiving a written application from the government, which is confirmed by government representative Ms. Moe.
DOJ-OGR-00009969.jpg
This document is a page from an index for a court transcript dated February 15, 2012, from the case of 'United States of America, v. Paul M. Daugerdas, et al.'. The page lists numerous words and proper names (such as McCarthy, McDonough, and Massachusetts) and provides the page and line numbers where they can be found in the full transcript. The document was produced by Southern District Reporters and bears the Bates number DOJ-OGR-00009969.
DOJ-OGR-00009863.jpg
This document is a screenshot of a Daily Mail Online news article from January 26, 2022, related to legal case 1:20-cr-00330-RA. It features a photograph from the U.S. District Attorney's Office showing Ghislaine Maxwell and Jeffrey Epstein together. The caption states that Maxwell faced six sex trafficking counts based on the testimony of four victims.
DOJ-OGR-00009822.jpg
This legal document argues that there is no evidence of actual bias from Juror 50 in the trial of a defendant named Maxwell. It cites the juror's public statements affirming his belief in the presumption of innocence, the jury's careful deliberations, and his answers during voir dire as proof of his impartiality. The document contrasts this with the defendant's claims that the juror made prejudicial statements after the trial, such as calling her a 'predator'.
DOJ-OGR-00009696.jpg
This document is a 'Table of Authorities' from a legal document filed on March 11, 2022, for case 1:20-cr-00330-PAE. It lists numerous legal cases, with decision dates ranging from 1933 to 2022, which are cited as legal precedent in the main filing. Each entry includes the case name, citation, and the page number(s) where it is referenced in the document.
DOJ-OGR-00009608.jpg
This document constitutes page 46 of a legal filing (Document 621) in the case United States v. Ghislaine Maxwell, filed on February 25, 2022. The text argues that Maxwell failed to prove that the Government intentionally delayed her indictment to gain a 'tactical advantage,' citing numerous Second Circuit legal precedents to support this standard. The court dismisses Maxwell's arguments regarding the delay as 'specious' and notes a lack of evidence that the delay was intended to thwart her defense.
DOJ-OGR-00009597.jpg
This legal document, part of a court filing, argues that the defendant's (Maxwell's) due process claim should be denied. The court asserts that she has failed to demonstrate actual prejudice from a pre-indictment delay or that the Government's delay was for an improper purpose. The document cites legal precedents, including United States v. Marion, to emphasize that the statute of limitations is the main safeguard against stale charges and that cases brought within that period hold a strong presumption of validity.
DOJ-OGR-00009571.jpg
This document is an excerpt from a legal filing, dated February 25, 2022, detailing the Government's arguments in a criminal case. It focuses on the alleged enticement and transportation of individuals, specifically 'Jane,' by Maxwell, Epstein, and the defendant across state lines to New York for abuse, emphasizing the intent behind these actions as sufficient for a Mann Act violation. The document also mentions the alleged grooming of 'Annie' by the defendant after she had visited Epstein in New York, and the intent of the defendant and Epstein to abuse 'Carolyn' and 'Annie'.
DOJ-OGR-00009554.jpg
This document is page 13 of a legal filing (Document 620) from February 25, 2022, in the case United States v. Ghislaine Maxwell. The text presents the Government's argument against the Defendant's motion for a new trial, specifically addressing allegations that 'Juror 50' made false statements during voir dire. The filing cites *Warger v. Shauers* and Federal Rule of Evidence 606(b) to argue that juror testimony regarding internal deliberations or personal experiences (unless 'extraneous') cannot be used to impeach a verdict.
DOJ-OGR-00009547.jpg
This legal document is a page from a court filing, likely an opinion or order, dated February 25, 2022. The court is addressing a defendant's argument for an evidentiary hearing, rejecting it by citing numerous legal precedents that establish a very high standard for post-verdict inquiries into jury conduct. The court emphasizes that motions to set aside verdicts are disfavored and that allowing such inquiries without concrete evidence could lead to negative consequences like jury harassment and tampering.
DOJ-OGR-00009545.jpg
This document is page 4 of a legal filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 25, 2022. It discusses a motion for a new trial based on 'Juror 50' allegedly failing to disclose information (specifically regarding childhood sexual abuse) during voir dire. The text outlines the legal standards for such a motion, citing Federal Rule of Criminal Procedure 33 and the Supreme Court case *McDonough Power Equipment, Inc. v. Greenwood*.
DOJ-OGR-00003135.jpg
This legal document is a filing by the prosecution (the Government) in the criminal case against the defendant, Maxwell. The Government argues that Maxwell's various motions for disclosure, including a request for a bill of particulars, should be denied as they are meritless or premature. The prosecution asserts that it has already provided sufficient information through the indictment and discovery, and that the defendant is not entitled to the requested details under established law.
DOJ-OGR-00003098.jpg
This legal document is a filing arguing against a defendant's motion to dismiss a perjury charge. The prosecution contends that the defendant's false statements in a deposition for the 'Giuffre v. Maxwell' civil suit were material, as truthful answers could have corroborated claims that the defendant and Epstein recruited Giuffre and could have led to other victims or witnesses. The filing asserts that the issue of materiality is a question for the jury and should not be decided by the court at this stage.
DOJ-OGR-00003089.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents an argument that a jury could find the defendant's testimony to be false. The prosecution argues that the defendant, likely Maxwell, falsely claimed to be unaware of any minors at Jeffrey Epstein's properties besides Giuffre, contradicting an indictment alleging interactions with 'Minor Victim-1'. The document refutes the defense's claims that the questions were ambiguous or improper, citing the defendant's own statements that the events in question 'never happened'.
DOJ-OGR-00003078.jpg
This legal document, filed on April 16, 2021, provides the factual background for a case, detailing how Virginia Roberts Giuffre joined a lawsuit concerning a non-prosecution agreement with Epstein. Giuffre alleged that the defendant was a "primary co-conspirator" who procured underage girls for Epstein and participated in sexual abuse. The document cites Giuffre's specific allegations that the defendant persuaded her to go to Epstein's mansion and was involved in a sexual encounter there.
DOJ-OGR-00003064.jpg
This legal document is a filing by the Government arguing against the defendant's (Maxwell's) claims. The Government refutes the defendant's assertion that she was protected by a civil protective order when giving deposition testimony, citing case law (e.g., Andover Data Servs., Davis) to establish that such orders do not provide the same protections as the Fifth Amendment. The document also dismisses the defendant's claim that the Government's conduct violated her due process rights as "meritless."
DOJ-OGR-00003046.jpg
This legal document is a page from a court filing, dated April 16, 2021, which presents an argument against the defendant Maxwell's claim to Fourth Amendment privacy for her deposition transcripts. The text refutes Maxwell's argument by distinguishing her case from the Supreme Court's narrow ruling in *Carpenter*, which concerned the privacy of cell phone location data and surveillance, not deposition testimony given in a civil suit. The document asserts that Maxwell's situation does not fall under the specific privacy protections established in *Carpenter*.
DOJ-OGR-00003043.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, argues that a Fourth Amendment motion by an individual named Maxwell should be dismissed. The core argument is that Maxwell lacks legal standing to make the claim because she had no legitimate expectation of privacy in the files of a third-party law firm that represented her adversary in a separate civil litigation. The document cites numerous legal precedents to support the position that Fourth Amendment rights are personal and cannot be asserted on behalf of others.
DOJ-OGR-00003042.jpg
This document is a legal filing, likely from the Government, arguing against a motion by a defendant named Maxwell to suppress evidence. The Government contends that Maxwell has no legal basis for suppression under the 'Martindell' precedent and that the court should decline to review a prior, coequal judge's (Chief Judge McMahon) decision to modify a protective order. The filing cites several Second Circuit cases to support its position that suppression is not the proper remedy and that pre-existing documents are not covered by the protective order's presumptions.
DOJ-OGR-00003041.jpg
This legal document is a page from a court filing, likely a motion from the defendant, Maxwell. The text argues against the Government's position by citing legal precedents like Palmieri and Martindell and contrasting the differing rulings of two judicial officers, Judge Netburn and Chief Judge McMahon, on the matter of sealing orders and grand jury secrecy. The core issue revolves around whether exceptional circumstances exist to justify the Government's actions, with Maxwell siding with Judge Netburn's finding that the Government's arguments were 'unpersuasive'.
DOJ-OGR-00003037.jpg
This legal document is the Government's response arguing against Defendant Maxwell's motion to suppress evidence. The Government asserts that it lawfully obtained materials from the law firm Boies Schiller via a grand jury subpoena, following the correct legal procedure under the Martindell precedent by getting judicial authorization to modify a protective order. The document contends that Maxwell's motion is based on incorrect facts and law and should therefore be denied.
DOJ-OGR-00003034.jpg
This legal document details a ruling by Chief Judge McMahon concerning a government investigation related to a civil lawsuit between Giuffre and Maxwell. The judge concluded that Giuffre's law firm, Boies Schiller, did not improperly instigate the government's investigation and, due to "extraordinary circumstances," granted the government's request to access certain materials previously under a protective order. The ruling permitted the Government to share a specific court order with Boies Schiller to aid its investigation.
DOJ-OGR-00003033.jpg
This legal document describes a ruling made on April 9, 2019, by Chief Judge McMahon, who granted the Government's application to modify a protective order. The judge analyzed the case using Martindell factors and Second Circuit case law, concluding that while the order was necessary for Giuffre to depose Maxwell, Maxwell's reliance on it to shield information from law enforcement was unreasonable. Ultimately, the judge granted the government's application for modification.
| 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 |
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.
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.
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.
Reply brief
A filing titled "Maxwell Reply" is cited, where the Defendant raises an argument in a footnote for the first time.
Appointments
Maxwell has been on record since 2009 calling Carolyn for appointments.
Scheduling sexualized massages
Carolyn testified that Maxwell called her to schedule sexualized massages.
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'.
Scheduling an appointment to massage Epstein
Maxwell, acting as one of Epstein's employees, would call victims to schedule appointments for them to massage Epstein at his Palm Beach Residence.
Interaction with Epstein
Maxwell directed Juan Alessi to speak to Epstein only when spoken to and not to look him in the eyes.
Advice about boyfriends
Maxwell advised Jane that once she has a sexual relationship with a boyfriend, she can always have one again because they are 'grandfathered in'.
Maxwell's personal life, relationships, and her boyfriend...
Maxwell told Kate 'amazing things' about her boyfriend, describing him as a philanthropist who liked to help young people, and suggested it would be wonderful for Kate to meet him.
Minor Victim-3's life and family
MAXWELL discussed Minor Victim-3's life and family with her as part of the grooming process.
Scheduling massages and scheme operations
Maxwell instructed Kellen on how to schedule massages and manage a part of the criminal scheme that Maxwell had previously handled.
Scheduling massages with Jeffrey Epstein
Carolyn named Maxwell as one of two people who would call her to schedule massages with Jeffrey Epstein.
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.
Culture of silence
Maxwell directed employees at Epstein's households to 'see nothing, hear nothing, say nothing' regarding the sexual abuse that occurred.
Culture of silence
Maxwell directed employees at Epstein's households to 'see nothing, hear nothing, say nothing' regarding the sexual abuse that occurred.
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.
Scheduling appointments
Maxwell called to schedule massage appointments for Carolyn, who was a minor.
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.
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.
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