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-00003031.jpg
This legal document page, filed on April 16, 2021, details discussions from an April 9, 2019 hearing. Chief Judge McMahon questions the Government's request for materials from a civil libel case involving Maxwell, expressing concerns about potential criminal proceedings and the invocation of the Fifth Amendment. The judge also probes into prior contacts between the U.S. Attorney's Office (USAO-SDNY) and the law firm Boies Schiller related to the investigation.
DOJ-OGR-00003025.jpg
This legal document, filed on April 16, 2021, recounts events from 2016 concerning the civil litigation between Giuffre and Maxwell. It details the process of establishing a protective order for discovery materials, initiated by Maxwell's motion on March 2, 2016, contested by Giuffre's counsel (Boies Schiller), and ultimately entered by Judge Robert W. Sweet on March 18, 2016. The document also asserts that the USAO-SDNY did not open an investigation into Epstein or Maxwell in 2016 and that the government has no record of email communication between AUSA-1 and Boies Schiller attorneys after May 3, 2016.
DOJ-OGR-00003024.jpg
This legal document describes a February 2016 meeting where attorneys presented information to an Assistant U.S. Attorney (AUSA-1) about individuals connected to Epstein, with a focus on Maxwell. It asserts that because this meeting pre-dated the depositions central to the current indictment, the attorneys could not have alleged perjury related to those specific depositions at that time. The document also notes AUSA-1's lack of recall regarding specific perjury discussions involving Maxwell and details the government's subsequent review of AUSA-1's emails for related communications.
DOJ-OGR-00003022.jpg
This legal document, filed by the prosecution, refutes the defendant's (Maxwell's) motion which alleges collusion between the law firm Boies Schiller and the U.S. Government. The prosecution argues that the defendant's narrative is false, stating that the perjury investigation began in late 2018, years after the meetings between Boies Schiller and a former AUSA, and that this AUSA had no involvement in the decision to open the investigation.
DOJ-OGR-00003018.jpg
This legal document, filed on April 16, 2021, is a rebuttal to a defendant's accusation that the Government delayed an indictment for tactical advantage. The author contrasts the Government's decision to stay the civil case of *Doe v. Indyke* with its inaction in the settled case of *Giuffre v. Maxwell*, arguing the different procedural postures and the risk of witness deposition in the active *Doe* case justified the different legal strategies. The document asserts that the Government's actions were logical and not part of a conspiracy to gain an advantage in the criminal case.
DOJ-OGR-00003017.jpg
This document is a page from a legal filing in which the prosecution (Government) argues against a motion by the defendant, Maxwell, to dismiss her indictment due to pre-indictment delay. The Government cites several legal precedents (Pierre-Louis, Burke, Carbonaro) to argue that the defendant has failed to show the delay was improper or for a tactical advantage. The document also addresses Maxwell's specific claim that the Government delayed the indictment to benefit from a separate civil litigation involving Giuffre, a claim the Government refutes.
DOJ-OGR-00003016.jpg
This legal document is a filing by the Government arguing that there was no due process violation regarding the timing of an indictment. The Government contends that the delay was justified because two critical witnesses, Minor Victim-1 and Minor Victim-3, only came forward to be interviewed in August and September 2019, less than a year before the indictment was sought in June 2020. The document cites legal precedents to support the position that delays caused by witness unavailability are permissible and that prosecutors can wait until an investigation is complete before seeking charges.
DOJ-OGR-00003008.jpg
This legal document is a filing that argues against a defendant's motion. The defendant claims that testimony from Michael Casey (agent for Minor Victim-1) and Detective Recarey would have been exculpatory. The filing counters that this proposed testimony is speculative, unsubstantiated, likely inadmissible hearsay, and ultimately irrelevant to the charges that the defendant assisted Epstein in the grooming and abuse of other victims.
DOJ-OGR-00003000.jpg
This legal document, part of a court filing from April 16, 2021, argues against using a 'categorical approach' to interpret the phrase 'offense involving' in Section 3283. It cites several legal precedents, most notably Weingarten v. United States, to counter an argument made by an individual named Maxwell. The document asserts that Congress intended a broad application of the statute and that the categorical approach, typically used in sentencing or immigration contexts, is not appropriate here.
DOJ-OGR-00002993.jpg
This legal document, part of a court filing from April 16, 2021, argues for the retroactive application of a 2003 amendment to Section 3283, a statute of limitations. It contends that applying the amendment to pre-enactment conduct satisfies the Supreme Court's two-step 'Landgraf' analysis, as it does not impair the rights or increase the liability of the defendant, Maxwell. The document asserts that the amendment merely preserves the status quo rather than attaching new legal consequences.
DOJ-OGR-00002985.jpg
This legal document is a court filing from Case 1:20-cr-00330-PAE, dated April 16, 2021. It outlines the statutory background regarding the statute of limitations for crimes against minors, arguing against a motion by the defendant, Maxwell. The document traces the history of relevant legislation, including the Crime Control Act of 1990, to counter Maxwell's claim that the charges against her do not involve the sexual or physical abuse of a child, and urges the court to deny her motion.
DOJ-OGR-00002978.jpg
This legal document, part of case 1:20-cr-00330-PAE filed on April 16, 2021, presents the government's argument against defendant Maxwell's motion to dismiss an indictment. The government contends that a Non-Prosecution Agreement (NPA) does not cover the specific crimes Maxwell is charged with under the Mann Act, as the statutes listed in the NPA differ from those in the indictment. Furthermore, the document argues that the NPA does not confer enforceable rights upon Maxwell to preclude the current prosecution, even under contract law principles.
DOJ-OGR-00002976.jpg
This legal document, part of a court filing, argues that a Non-Prosecution Agreement (NPA) does not immunize the defendant, Maxwell, from prosecution. The argument is based on two points: the NPA's scope is strictly limited to specific federal crimes committed between 2001 and 2007, and the mere mention of "co-conspirator" does not automatically include Maxwell within the agreement's protections.
DOJ-OGR-00002936.jpg
This document is the table of contents for a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. The filing appears to be a response from the prosecution arguing against motions made by the defendant, Maxwell. Key arguments outlined include the irrelevance of Jeffrey Epstein's Non-Prosecution Agreement to this case, the timeliness of the indictment, and reasons why the defendant's motions to dismiss and suppress evidence should be denied.
DOJ-OGR-00004803.jpg
This document is page 19 of a court order filed on June 25, 2021, in the case of United States v. Ghislaine Maxwell. The Court denies Maxwell's motion to suppress evidence obtained via a grand jury subpoena, rejecting her arguments based on the 'Franks' and 'Martindell' legal precedents. The text affirms a previous decision by Judge McMahon to modify a protective order to allow a secret Government investigation into a high-profile matter, noting that while Judge Netburn disagreed, McMahon's decision had a substantial basis and is entitled to deference.
DOJ-OGR-00004799.jpg
This document page discusses the legal standards applicable to the defendant Maxwell's request for an evidentiary hearing, specifically debating the applicability of the 'Franks' standard. The Court concludes that despite differences in context (Fourth vs Fifth Amendment), the 'Franks' standard is appropriate and Maxwell must make a substantial preliminary showing to justify a hearing.
DOJ-OGR-00004794.jpg
This legal document, filed on June 25, 2021, argues that a person named Maxwell has no reasonable expectation of privacy regarding documents produced during a prior civil litigation. It asserts that because a protective order allowed these documents to be widely shared among various parties (attorneys, witnesses, court staff), they were not truly private. The document cites Supreme Court and Second Circuit precedents, such as Carpenter and Andover, to support the position that such information can be used by the Government in a subsequent criminal prosecution.
DOJ-OGR-00004791.jpg
This page from a legal filing (Document 307 in Case 1:20-cr-00330-PAE) argues that Ghislaine Maxwell's Fifth Amendment rights were not violated when the Government used her civil deposition testimony in her criminal trial. The text asserts that civil protective orders do not prevent testimony from being used in subsequent criminal proceedings and that Maxwell was free to plead the Fifth during the original civil case but chose not to. It also addresses an argument regarding the law firm BSF turning over transcripts.
DOJ-OGR-00004788.jpg
This legal document, filed on June 25, 2021, describes a court proceeding from April 9, 2019, where Judge McMahon granted the Government's application to modify a protective order. The judge found extraordinary circumstances allowed the modification, enabling the Government to obtain information for its investigation into high-profile targets, including Maxwell, without tipping them off. Consequently, the law firm BSF turned over records from a civil litigation, including transcripts of Maxwell's depositions, to the Government.
DOJ-OGR-00004786.jpg
This page from a 2021 court filing details a February 29, 2016, meeting between the Government (AUSA) and Virginia Giuffre's attorneys, where Maxwell was identified as Epstein's 'head recruiter.' It discusses a protective order issued shortly after that meeting which prevented the sharing of discovery documents with law enforcement without a court order. It also addresses a dispute regarding an alleged second meeting in the summer of 2016, which the Government denies occurred.
DOJ-OGR-00004740.jpg
This page from a court order addresses two requests by the defendant, Maxwell. The court denies Request 9 regarding forensic analysis of a journal, deeming the arguments speculative and improper for a Rule 17(c) subpoena, and denies Request 10 for a pair of boots as moot because the government has already agreed to make them available for inspection.
DOJ-OGR-00004717.jpg
This legal document, filed on May 25, 2021, is a legal argument concerning the scope of plea agreements across different federal judicial districts. The author argues, based on Second Circuit precedent like Annabi, that a plea agreement from one district does not bind another unless explicitly stated. The document contrasts this with a broader interpretation from the Third Circuit (in United States v. Gebbie), which the defendant in the current case (Maxwell) is urging the court to adopt.
DOJ-OGR-00004715.jpg
This document is page 8 of a legal filing (Document 295) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on May 25, 2021. The text presents a legal argument by the prosecution distinguishing the current case from the precedent set in *Annabi*, *Abbamonte*, and *Alessi* regarding the Double Jeopardy Clause and plea agreements. The prosecution argues that Maxwell cannot claim Double Jeopardy protections because she was not previously prosecuted for the offenses listed in the S2 Indictment, and disputes her interpretation of the Non-Prosecution Agreement (NPA).
DOJ-OGR-00020380.jpg
This legal document from May 27, 2021, argues that a renewed motion for Ghislaine Maxwell's release should be denied. It supports Judge Nathan's prior ruling that Maxwell is a flight risk and asserts that no new "compelling" reason has been presented to overturn the decision. The document also details Maxwell's extensive access to legal discovery materials and communication with her attorneys while in custody at the MDC.
DOJ-OGR-00014624.jpg
This legal document outlines specific actions taken between 2001 and 2004 as part of a conspiracy charge. It details how Jeffrey Epstein, Ghislaine Maxwell, and other employees sent gifts (including lingerie) to a woman named Carolyn and repeatedly called her to schedule massages for Epstein. The document concludes with a legal clarification that for a conspiracy conviction, it is sufficient to prove that any member of the conspiracy committed an overt act, not necessarily the defendant (Ms. Maxwell) herself.
| 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.
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.
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.
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 with Jeffrey Epstein
Carolyn named Maxwell as one of two people who would call her to schedule massages with Jeffrey Epstein.
Civil Case Testimony
Testimony given by Maxwell in a civil case (Giuffre v. Maxwell).
Scheduling massages
Maxwell calling Carolyn to schedule sexualized massages when Maxwell was in New York.
Instruction to undress
She told me to get undressed.
Spending time vs Communicating
Witness clarifies distinction between spending physical time vs communicating. States she stopped spending time around age 24.
Legal Review
Review of discovery materials
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.
Reconsideration of response
Seeking reconsideration claiming constructive amendment or prejudicial variance.
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.
Small talk during massage
making small talk
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.
Request to question Juror 50
Renewing request to question Juror 50 directly and proposing twenty-one pages of questions.
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.
Culture of silence
Maxwell directed employees at Epstein's households to 'see nothing, hear nothing, say nothing' regarding the sexual abuse that occurred.
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