MAXWELL
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
plaintiff
|
Adversarial |
5
|
1 | |
|
organization
GOVERNMENT
|
Adversarial litigant |
5
|
1 | |
|
person
Jane
|
Criminal exploitative |
5
|
1 | |
|
person
Jane
|
Abuser victim alleged |
5
|
1 | |
|
person
Jeffrey Epstein
|
Accomplice |
5
|
1 | |
|
person
Minor Victim-4
|
Exploitative |
5
|
1 | |
|
person
Guiffre
|
Litigation opponent |
5
|
1 | |
|
person
Donald Trump
|
Social |
5
|
1 | |
|
person
A. Farmer
|
Victim perpetrator |
5
|
1 | |
|
person
CAROLYN
|
Abuser victim |
5
|
1 | |
|
organization
district court
|
Litigant judiciary |
5
|
1 | |
|
person
David
|
Juror and defendant |
5
|
1 | |
|
person
Jane
|
Defendant and accuser |
5
|
1 | |
|
person
CAROLYN
|
Professional exploitative |
5
|
1 | |
|
person
Mr. Epstein
|
Business associate |
5
|
1 | |
|
person
Andrew A. Rohrbach
|
Legal representative |
5
|
1 | |
|
person
Unnamed victim (speaker)
|
Abuser victim |
5
|
1 | |
|
person
Minor Victim-4
|
Groomer victim |
5
|
1 | |
|
person
Elizabeth
|
Unspecified |
5
|
1 | |
|
person
CAROLYN
|
Alleged giver recipient |
5
|
1 | |
|
organization
Morgan
|
Professional |
5
|
1 | |
|
person
her counsel/lawyer
|
Client |
5
|
1 | |
|
organization
This Court
|
Litigant court |
5
|
1 | |
|
person
SARAH
|
Unspecified |
5
|
1 | |
|
person
Jane
|
Victim perpetrator implied |
5
|
1 |
| 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-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 |
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.
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.
Spending time vs Communicating
Witness clarifies distinction between spending physical time vs communicating. States she stopped spending time around age 24.
Instruction to undress
She told me to get undressed.
Small talk during massage
making small talk
Reconsideration of response
Seeking reconsideration claiming constructive amendment or prejudicial variance.
Request to question Juror 50
Renewing request to question Juror 50 directly and proposing twenty-one pages of questions.
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.
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.
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'.
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'.
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.
Legal Review
Review of discovery materials
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.
Scheduling appointments
Maxwell called to schedule massage appointments for Carolyn, who was a minor.
Scheduling massages
Maxwell calling Carolyn to schedule sexualized massages when Maxwell was in New York.
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.
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.
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