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 | Maxwell's motion denied by District Court without an evidentiary hearing. | N/A | View |
| N/A | N/A | Maxwell argues Counts Three and Four of the Indictment are untimely. | N/A | View |
| N/A | N/A | Court declines Maxwell's motion to strike surplusage at this juncture. | N/A | View |
| N/A | N/A | Maxwell moves to strike surplusage from the S1 superseding indictment, specifically allegations r... | N/A | View |
| N/A | N/A | Court agrees that some of Maxwell's concerns are overstated but acknowledges defamation action re... | N/A | View |
| N/A | N/A | Maxwell's motion for a new trial denied by District Court. | N/A | View |
| N/A | N/A | Massage incident | New Mexico Ranch | View |
| N/A | N/A | Jury instruction on Count Four, requiring finding that Maxwell transported Jane for sexual activity. | N/A | View |
| N/A | N/A | Maxwell filed a letter seeking reconsideration of the District Court's response. | District Court | View |
| N/A | N/A | Maxwell appealed the District Court's denial. | N/A | View |
| N/A | N/A | Court found that nothing in the NPA or its negotiation history suggested it precluded USAO-SDNY f... | N/A | View |
| N/A | N/A | Cancellation of Maria's trip to New Mexico | New Mexico (intended destin... | View |
| N/A | N/A | Denial of motion to compel immediate disclosure of Minor Victim-4's prior statements. | Court | View |
| N/A | N/A | Rule 33 Motion Ruling | District Court | View |
| N/A | N/A | Dismissal of lawsuit against Maxwell | Court | View |
| N/A | N/A | Offenses committed by Maxwell that were subject to motions to dismiss. | N/A | View |
| N/A | N/A | Denial of temporary release | Court | View |
| N/A | N/A | Flashlight checks performed on Maxwell every 15 minutes due to enhanced security schedule. | MDC | View |
| N/A | N/A | Maxwell's appeal/contention regarding the application of the NPA to her prosecution in SDNY. | Second Circuit Court of App... | View |
| N/A | N/A | Judge Nathan declined to modify protective order | Court | View |
| N/A | N/A | Defamation Action | Unknown | View |
| N/A | N/A | Massage incident where Maxwell instructed Farmer to undress, performed a massage, exposed Farmer'... | The room where Farmer was s... | View |
| N/A | N/A | Travel with Epstein and Maxwell | Various (Travel) | View |
| N/A | N/A | District Court denied Maxwell's motion for reconsideration. | District Court | View |
| N/A | N/A | MAXWELL arranged for Minor Victim-1 to be transported multiple times from Florida to New York for... | Florida to New York | View |
DOJ-OGR-00000132.tif
This document discusses the legislative history and intent behind the PROTECT Act's retroactivity provisions, emphasizing that Congress removed an express retroactivity clause due to constitutional concerns. It cites a Supreme Court case (Stogner v. California) and Senator Leahy's statements to argue that the Act applies to past conduct, like Maxwell's, where the statute of limitations had not yet expired, without violating the Ex Post Facto Clause.
DOJ-OGR-00000129.tif
This document is a legal excerpt discussing the application of the PROTECT Act and related statutes of limitations, particularly concerning offenses involving child sexual abuse. It references legal precedents like Weingarten, Schneider, and United States v. Dodge, emphasizing Congress's intent to broadly apply these statutes. The text also addresses Maxwell's contention regarding the applicability of the PROTECT Act to her alleged offenses based on the timing of the conduct.
DOJ-OGR-00000127.tif
This document is an excerpt from a legal analysis discussing the interpretation of statutory language, specifically § 3283, and the application of 'categorical' versus 'circumstance-specific' approaches in legal contexts. It references several court cases including United States v. Schneider (2015), Weingarten (865 F.3d at 58), United States v. Morgan (2004), and Nijhawan v. Holder (2009), to support the argument that courts should look beyond bare legal charges to the circumstances of an offense, especially when a statute uses the word 'involves'.
DOJ-OGR-00000125.tif
This document is a legal analysis concerning the timeliness of an indictment, specifically addressing the statute of limitations for charges involving the sexual abuse and kidnapping of minors. It discusses the PROTECT Act of 2003, which extended the limitations period for such offenses, and concludes that the charges against Maxwell and Epstein, including Mann Act charges, are timely under this act because they involve the sexual abuse of minors, with Maxwell allegedly enticing them to travel and Epstein allegedly abusing them.
DOJ-OGR-00000121.tif
This document is an excerpt from a legal ruling or report, discussing the scope and binding nature of a Non-Prosecution Agreement (NPA) involving Epstein. It addresses the argument that the NPA might bind other judicial districts and concludes that it only binds the U.S. Attorney's office where it was signed, specifically stating it does not bind the U.S. Attorney for the Southern District of New York.
DOJ-OGR-00000118.tif
This document details aspects of Jeffrey Epstein's non-prosecution agreement (NPA) in Florida, where he pleaded guilty to soliciting minors for prostitution and served 18 months in jail. The NPA included a controversial provision where the U.S. Attorney's Office agreed not to charge Epstein federally or his 'potential co-conspirators,' a point criticized by the OPR as 'poor judgment.' The document also discusses Ghislaine Maxwell's contention that the NPA bars her prosecution as Epstein's co-conspirator, a claim the Court rejects based on Second Circuit precedent and the scope of the NPA.
DOJ-OGR-00000117.tif
This document outlines several motions made by 'Maxwell' in a legal proceeding, including motions to dismiss perjury counts, sever counts, strike indictment language, compel discovery, and dismiss all counts related to grand jury indictments. It also states that Jeffrey Epstein's non-prosecution agreement from September 2007 does not prevent the current prosecution.
DOJ-OGR-00000085.tif
This document excerpt discusses a District Court's findings regarding the sentencing of Maxwell, specifically focusing on the application of sentencing guidelines and a leadership enhancement. The court found Maxwell supervised Sarah Kellen, who was Epstein's 'number two' and 'lady of the house' in Palm Beach, where significant abuse occurred, and noted Maxwell's pivotal role in facilitating the abuse of underaged girls.
DOJ-OGR-00000083.tif
This document is an excerpt from a legal filing or report, discussing legal arguments concerning a defendant named Maxwell. It addresses whether the evidence at trial varied prejudicially from the indictment and concludes that the evidence presented, which included Maxwell transporting 'Jane' to New York for sexual abuse, did not materially differ from the indictment's allegations. The text references legal precedents like United States v. Salmonese and Dove.
DOJ-OGR-00000081.tif
This document details an appeal by Maxwell challenging a District Court's denial related to a constructive amendment or prejudicial variance in an indictment. Maxwell argues that testimony regarding a witness's sexual abuse in New Mexico created a new basis for conviction distinct from the original indictment, and that jury instructions regarding the transportation of 'Jane' for sexual activity constituted a constructive amendment. The document affirms the District Court's denial, citing legal precedents for interpreting the Grand Jury Clause and constructive amendment claims.
DOJ-OGR-00000080.tif
This document outlines legal arguments concerning Maxwell's trial, specifically addressing the District Court's handling of juror selection and a jury note related to Count Four of the Indictment. It discusses whether Maxwell could be found guilty for aiding in Jane's transportation if the intent for sexual activity was not tied to the New Mexico flight, and references a case (United States v. Ianniello) regarding juror questioning.
DOJ-OGR-00000078.tif
This document discusses legal arguments related to the application of statutes of limitations for sexual abuse charges under the PROTECT Act, specifically as it pertains to Maxwell's conduct. It also details Maxwell's appeal for a new trial, arguing that Juror 50's failure to disclose a history of sexual abuse during jury selection deprived her of a fair trial, a motion which the District Court denied. The document cites several legal precedents regarding the definition and application of 'abuse of discretion' in judicial review.
DOJ-OGR-00000077.tif
This document is an excerpt from a legal filing or opinion, discussing the application of a statute of limitations (§ 3283) in a case involving Maxwell. It focuses on whether the 2003 amendment to § 3283, which extended the statute of limitations for child sexual abuse and kidnapping offenses, can be applied retroactively to pre-enactment conduct, citing Supreme Court precedent on statutory retroactivity.
DOJ-OGR-00000076.tif
This legal document discusses the denial of Maxwell's motions to dismiss charges related to the sexual abuse of minors, focusing on the application of § 3283. It references the Weingarten v. United States case, which established a 'case-specific approach' for interpreting statutory provisions, and notes that one of the victims is identified as 'Jane'. The document cites several legal precedents, including United States v. Sampson, Weingarten v. United States, United States v. Maxwell, and Taylor v. United States.
DOJ-OGR-00000075.tif
This document discusses legal arguments concerning the timeliness of an indictment against Maxwell and the scope of U.S. Attorney's powers. It states that the District Court denied Maxwell's motion, finding that the Non-Prosecution Agreement (NPA) did not prevent the USAO-SDNY from prosecuting her. Maxwell also argues that certain counts are untimely and that a 2003 amendment to the statute of limitations (§ 3283) should not apply to her case.
DOJ-OGR-00000069.tif
This document details the conclusion of a jury trial for Maxwell, who was found guilty on December 29, 2021, of multiple counts including sex trafficking and transportation of a minor for sexual activity, but acquitted on one count. It also highlights a critical issue with Juror 50, who, despite stating in post-verdict interviews that he was a survivor of child sexual abuse, had previously answered 'no' to relevant questions on the jury questionnaire.
DOJ-OGR-00000065.tif
This document is an excerpt from a legal opinion affirming the District Court's June 29, 2022, judgment of conviction for 'Maxwell' (presumably Ghislaine Maxwell). It addresses five appellate questions, including whether Jeffrey Epstein's Non-Prosecution Agreement barred Maxwell's prosecution and if her sentence was procedurally reasonable. The document also lists the attorneys involved for both the Appellee (United States Attorney's Office for the Southern District of New York) and the Defendant-Appellant.
DOJ-OGR-00000061.tif
This document, dated April 10, 2025, is a legal filing arguing for the granting of a petition for certiorari. It highlights a legal dispute regarding the enforceability of a government promise not to prosecute Epstein's co-conspirators, specifically mentioning Ghislaine Maxwell's prosecution despite such a promise. David Oscar Markus, Counsel of Record from MARKUS/MOSS PLLC, is representing the petitioner.
DOJ-OGR-00000057.tif
This document is a legal analysis discussing principles of statutory interpretation, particularly concerning the meaning of 'United States' in plea agreements. It details how language placement in a Non-Prosecution Agreement (NPA) informs intent, specifically noting how a co-conspirator immunity clause was severed from Epstein's immunity clause and how the NPA's terms may preclude Maxwell's prosecution.
DOJ-OGR-00000056.tif
This document discusses legal principles of contract interpretation in the context of plea agreements, citing several court cases. It argues that ordinary contract principles should apply to plea agreements, with a strong emphasis on fairness to the defendant and construing ambiguity against the government, and suggests that the cases of Annabi and Maxwell should be reversed based on these principles.
DOJ-OGR-00000049.tif
This document, likely a legal petition or brief, discusses the reasons for granting a petition filed by 'Maxwell' after an en banc rehearing was denied. It focuses on a circuit split regarding the binding nature of plea agreements made by a U.S. Attorney's office in one district on other U.S. Attorney's offices. The document cites Santobello v. New York as a precedent suggesting that such promises should be binding across different prosecutors.
DOJ-OGR-00000044.tif
This document outlines the procedural background of Jeffrey Epstein's Non-Prosecution Agreement (NPA) from September 2007, where he agreed to plead guilty to state charges in Florida and serve an eighteen-month sentence, in exchange for the U.S. agreeing not to prosecute him for offenses from 2001-2007 and not to charge potential co-conspirators. It also highlights a legal inconsistency regarding the enforceability of such agreements across different circuit courts, referencing a motion to dismiss by Maxwell that would have been granted under different circumstances.
DOJ-OGR-00000041.tif
This document is a 'Table of Authorities—Continued' listing various legal cases, statutes, and rules. It includes multiple 'United States v. Maxwell' cases, one from 2024 and another from 2021, along with other cases like 'United States v. McDowell', 'United States v. O’Doherty', 'United States v. Rubbo', 'United States v. Transfiguracion', 'United States v. Van Thournout', 'United States v. Warner', and 'United States v. Williams', citing their legal references and page numbers within the larger document. It also lists relevant statutes (18 U.S.C. § 2255 and 28 U.S.C. § 1254(1)) and a rule (Fed. R. Civ. P. 35(b)).
DOJ-OGR-00018394.jpg
This is a court transcript of a direct examination of a witness named Kate. Kate testifies that she first traveled to meet Maxwell and Epstein when she was approximately 18, and traveled to see them a total of four or five times. She states that Maxwell was very accommodating and arranged the travel, and confirms that Epstein engaged in sex acts with her during massages at Maxwell's house.
DOJ-OGR-00018393.jpg
This document is a court transcript of the direct examination of a witness named Kate. She testifies about giving massages to Epstein, stating that none of them were non-sexual, and that Maxwell would debrief her afterwards. Kate also recounts receiving a Prada handbag as a birthday gift in London from "Ghislaine and Jeffrey."
| 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 |
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.
Spending time vs Communicating
Witness clarifies distinction between spending physical time vs communicating. States she stopped spending time around age 24.
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.
Small talk during massage
making small talk
Legal Review
Review of discovery materials
Culture of silence
Maxwell directed employees at Epstein's households to 'see nothing, hear nothing, say nothing' regarding the sexual abuse that occurred.
Reconsideration of response
Seeking reconsideration claiming constructive amendment or prejudicial variance.
Instruction to undress
She told me to get undressed.
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.
Request to question Juror 50
Renewing request to question Juror 50 directly and proposing twenty-one pages of questions.
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.
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.
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.
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.
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