CAROLYN
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
MR. PAGLIUCA
|
Legal representative |
14
Very Strong
|
23 | |
|
person
Jeffrey Epstein
|
Business associate |
13
Very Strong
|
12 | |
|
person
Shawn
|
Friend |
12
Very Strong
|
13 | |
|
person
Virginia Roberts
|
Acquaintance |
12
Very Strong
|
10 | |
|
person
Shawn
|
Business associate |
12
Very Strong
|
11 | |
|
person
Shawn
|
Romantic |
11
Very Strong
|
7 | |
|
person
Epstein
|
Abuser victim |
11
Very Strong
|
7 | |
|
person
Melissa
|
Friend |
11
Very Strong
|
7 | |
|
person
Jeffrey Epstein
|
Client |
11
Very Strong
|
8 | |
|
person
Shawn
|
Acquaintance |
11
Very Strong
|
8 | |
|
person
Jeffrey Epstein
|
Abuser victim |
11
Very Strong
|
7 | |
|
person
Jeffrey Epstein
|
Legal representative |
10
Very Strong
|
10 | |
|
person
Ms. Comey
|
Legal representative |
10
Very Strong
|
10 | |
|
location
Virginia
|
Recruiter recruit |
10
Very Strong
|
7 | |
|
person
Jeffrey Epstein
|
Victim abuser |
10
Very Strong
|
6 | |
|
person
GHISLAINE MAXWELL
|
Abuser victim |
10
Very Strong
|
6 | |
|
person
Jeffrey Epstein
|
Acquaintance |
10
Very Strong
|
5 | |
|
person
Ms. Comey
|
Professional |
10
Very Strong
|
9 | |
|
person
MAXWELL
|
Perpetrator victim |
10
Very Strong
|
7 | |
|
person
MR. SCAROLA
|
Professional |
10
Very Strong
|
6 | |
|
person
MAXWELL
|
Professional |
10
Very Strong
|
10 | |
|
person
Epstein
|
Perpetrator victim |
10
Very Strong
|
5 | |
|
person
Jeffrey Epstein
|
Professional |
10
Very Strong
|
6 | |
|
person
Virginia Roberts
|
Recruiter victim |
10
Very Strong
|
5 | |
|
person
MR. PAGLIUCA
|
Professional |
10
Very Strong
|
27 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | Trial | The trial of Ghislaine Maxwell, where this summation was delivered. | Southern District Court (im... | View |
| N/A | Crime | Maxwell and Epstein used their wealth and privilege to manipulate, groom, and sexually abuse youn... | N/A | View |
| N/A | Scheduling | Maxwell called Carolyn to schedule sexualized massages. This is related to counts Five and Six. | New York | View |
| N/A | Testimony | Mr. Pagliuca summarizes testimony from four witnesses (Carolyn, Jane, Kate, Mr. Alessi) regarding... | Courtroom | View |
| N/A | Court testimony | Carolyn and Juan Alessi provided testimony during a trial regarding the roles of Ms. Maxwell and ... | N/A | View |
| N/A | Conversation | Virginia told Carolyn about an opportunity to make money by giving massages to a man in Palm Beach. | N/A | View |
| N/A | Trip | A group traveled to Jeffrey Epstein's house. | Jeffrey Epstein's house | View |
| N/A | Trip | Maxwell and Epstein invited Carolyn, under the age of 17, to travel from Florida to a place outsi... | from Florida to a place out... | View |
| N/A | Meeting | Carolyn had meetings with lawyers about the lawsuits before they were filed. | N/A | View |
| N/A | Meeting | Sean allegedly brought Melissa to a house with Carolyn. | Carolyn's boyfriend's house | View |
| N/A | Legal action | Carolyn hired an attorney and sued Epstein and his assistant, Sarah Kellen. | N/A | View |
| N/A | Legal action | Carolyn brought a second lawsuit against Epstein and Kellen. | federal court in Florida | View |
| N/A | Drug abuse | Shawn stated that he and Carolyn were abusing marijuana, cocaine, ecstasy, and other pills during... | N/A | View |
| N/A | Recruitment/exploitation | Epstein and Maxwell recruited Carolyn to engage in sex acts with Epstein, for which Maxwell paid ... | Palm Beach Residence | View |
| N/A | Recruitment | Epstein and Maxwell encouraged and enticed Carolyn to recruit other girls to engage in paid sex a... | N/A | View |
| N/A | Trial testimony | Carolyn testified, recalling that Sarah Kellen scheduled massages and Maxwell was present at the ... | Courtroom | View |
| N/A | N/A | Carolyn brought friends Amanda, Tatum, and Julie to Jeffrey Epstein's house. | Jeffrey Epstein's house | View |
| N/A | Birthday | Carolyn's 18th birthday is mentioned as a significant date that may mark the end of the conspirac... | N/A | View |
| N/A | Crime | A decade-long conspiracy of sexual abuse and federal sex-trafficking, which the government charge... | N/A | View |
| N/A | Personal event | Carolyn turned 18, which is legally significant as she could no longer be deemed a victim under t... | N/A | View |
| N/A | Trial | A trial was held where Carolyn provided testimony and a jury was present. | N/A | View |
| N/A | Interview | Carolyn was interviewed by the FBI about Epstein. | N/A | View |
| N/A | Trip | Carolyn brought her friends Amanda, Tatum, and Julie to Jeffrey Epstein's house on separate occas... | Jeffrey Epstein's house | View |
| N/A | Activity | Carolyn and a friend entered Jeffrey Epstein's house through the kitchen and went upstairs to a m... | massage room | View |
| N/A | Introduction | Carolyn was introduced to Epstein by Virginia Roberts. | N/A | View |
DOJ-OGR-00008654.jpg
This document is page 116 of 167 from a court filing (Document 563) dated December 18, 2021, in the case against Ghislaine Maxwell. It contains Jury Instruction No. 26 regarding the first element of Count Six: Sex Trafficking of an Individual Under the Age of 18. The text explicitly names 'Carolyn' as the specific individual the Government must prove Maxwell knowingly recruited or trafficked.
DOJ-OGR-00008653.jpg
This legal document is a jury instruction (Instruction No. 25) from case 1:20-cr-00330-PAE, filed on December 18, 2021. It outlines the four specific elements the Government must prove beyond a reasonable doubt to convict the Defendant on Count Six, Sex Trafficking of an Individual Under the Age of 18. The instruction specifies that this particular count pertains to a person named Carolyn and the alleged acts occurred between 2001 and 2004.
DOJ-OGR-00008591.jpg
This document is a page from a legal filing (Case 1:20-cr-00330-PAE) detailing overt acts for Counts Three and Five of an indictment against Ghislaine Maxwell. It lists specific allegations of sexual abuse and recruitment involving minors named Jane and Carolyn between 1994 and 2004 in New York and Florida. The document is heavily edited with strike-throughs, notably removing allegations related to victims named Annie and Kate, and adjusting the age of victims from 17 to 18.
DOJ-OGR-00008590.jpg
This document is a page from jury instructions (Instruction No. 36) in a federal criminal case, filed on December 18, 2021. It details the 'overt act' element required to prove a conspiracy charge, listing specific allegations from the indictment against conspirators Maxwell and Epstein. The alleged overt acts, occurring between 1994 and 2002, involve the sexual abuse and exploitation of underage victims identified as Jane, Annie, Kate, and Carolyn across multiple locations including New York, Florida, New Mexico, and London.
DOJ-OGR-00008576.jpg
This document is a jury instruction from a legal case filed on December 18, 2021, detailing the third element the prosecution must prove for a conviction on Count Six: Sex Trafficking of a Minor. It specifies that the defendant, Ms. Maxwell, must have known the victim, Carolyn, would be engaged in a commercial sex act, and clarifies that the victim's consent is not a defense if she was under 18.
DOJ-OGR-00008574.jpg
This document is a jury instruction (No. 26) from a federal criminal case, filed on December 18, 2021. It specifies the first element the government must prove for Count Six, Sex Trafficking of a Minor, which is that the defendant, Ms. Maxwell, knowingly recruited, enticed, harbored, transported, provided, or obtained a person named Carolyn.
DOJ-OGR-00008573.jpg
This legal document is a jury instruction (Instruction No. 25) from a court case, filed on December 18, 2021. It outlines the four elements the government must prove beyond a reasonable doubt to find the defendant guilty of Count Six: Sex Trafficking of a Minor. The instruction specifies that this particular count pertains solely to a person named Carolyn and the alleged acts occurred between 2001 and 2004.
DOJ-OGR-00008557.jpg
This document is a page from a legal filing dated December 18, 2021, outlining two counts of an indictment. Count Five charges an unnamed defendant with conspiring to sex traffic multiple minors between 2001 and 2004. Count Six charges the same defendant with the sex trafficking of a specific individual named Carolyn during the same time period.
DOJ-OGR-00008538.jpg
This document is the final page (Page 82 of 82, internal page 2) of a blank verdict form filed on December 17, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It lists Counts Four, Five, and Six, which include charges of transportation for illegal sexual activity involving 'Jane,' sex trafficking conspiracy, and sex trafficking of a minor named 'Carolyn.' The form includes spaces for the jury foreperson to mark 'Guilty' or 'Not Guilty' and to sign.
DOJ-OGR-00008508.jpg
This document is page 52 of a legal filing from December 17, 2021, in the case against Ms. Maxwell. It contains jury instructions regarding the legal definition and requirements for proving an "overt act" as part of a conspiracy. The instructions clarify that the government does not need to prove Maxwell herself committed the act, that the act does not have to be one specifically listed in the indictment, and that a conviction on certain counts cannot be based solely on the testimony of a witness named Kate.
DOJ-OGR-00008507.jpg
This legal document, part of an indictment, details overt acts related to a criminal case against Epstein and Maxwell. It outlines specific instances between 1994 and 2004 where they allegedly conspired to recruit and sexually abuse several minors, identified as Jane, Annie, Kate, and Carolyn, in various locations including New York, Florida, New Mexico, and London. The document describes methods of enticement, such as arranging travel and providing cash payments, and alleges that one victim, Carolyn, was also encouraged to recruit other girls.
DOJ-OGR-00008506.jpg
This document outlines Jury Instruction No. 36 regarding the 'Third Element' of a conspiracy charge, specifically requiring proof of an 'overt act.' It details specific allegations from the indictment against Maxwell involving Epstein and victims identified as Jane, Annie, Kate, and Carolyn across various years and locations.
DOJ-OGR-00008492.jpg
This document constitutes Jury Instruction No. 28 from the trial of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on December 17, 2021. It outlines the legal standards for 'Count Six: Sex Trafficking of a Minor,' specifically regarding a victim named Carolyn. The instruction clarifies that consent is not a defense if the victim is under 18 and defines 'commercial sex act' broadly to include the exchange of anything of value.
DOJ-OGR-00008491.jpg
This legal document, filed on December 17, 2021, is a jury instruction (No. 27) from a criminal case (1:20-cr-00330-PAE). It pertains to Count Six, 'Sex Trafficking of a Minor,' and directs the jury on the second element the Government must prove: that the defendant, Ms. Maxwell, knew that the victim, Carolyn, was under eighteen years of age.
DOJ-OGR-00008490.jpg
This document is page 34 of 82 from a court filing dated December 17, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains Jury Instruction No. 26 regarding 'Count Six: Sex Trafficking of a Minor – First Element,' specifically instructing the jury on the requirement to prove that Maxwell knowingly recruited, enticed, harbored, transported, provided, or obtained a specific individual named Carolyn.
DOJ-OGR-00008489.jpg
This document is page 33 of a court filing (Jury Instructions) from December 2021 in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It outlines the four legal elements required to prove Count Six: Sex Trafficking of a Minor. The document specifically specifies that this count relates to a victim named Carolyn during the period of 2001 to 2004.
DOJ-OGR-00008473.jpg
This is page 17 of 82 from a legal filing (Document 562) in Case 1:20-cr-00330-PAE, filed on December 17, 2021. The text clarifies that Count Six of the indictment charges the Defendant with sex trafficking of minors specifically regarding an individual named Carolyn during the time period of 2001 to 2004.
DOJ-OGR-00008428.jpg
A letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan dated December 18, 2021, regarding the Ghislaine Maxwell trial. The Government is writing to oppose the addition of a specific jury instruction (Sand instruction 7-12) concerning the impeachment of witnesses by prior felony convictions, arguing it is not necessary in this context. The letter mentions a witness named 'Carolyn' whose prior convictions were elicited.
DOJ-OGR-00008378.jpg
This document is a legal filing (page 5 of 9) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated December 15, 2021. It argues against the defense's attempt to call attorney Scarola to the stand to testify about his client Carolyn's cooperation with the government and the Epstein Victims' Compensation Program (EVCP), citing attorney-client privilege and Federal Rule of Evidence 403 (prejudice/confusion). The text asserts that Carolyn was unaware of when the EVCP began accepting claims when she decided to cooperate, negating the defense's theory of financial bias.
DOJ-OGR-00008377.jpg
This legal document, filed on December 15, 2021, is a motion from the prosecution arguing against allowing testimony from an individual named Scarola. The prosecution contends that Scarola's proposed testimony regarding another witness, Carolyn, is irrelevant and non-impeaching, as the information has already been obtained from Carolyn directly. The document also details over $3.2 million in compensation Carolyn received from claims related to Epstein and Sarah Kellen, and discusses a 2020 meeting where Scarola showed Carolyn a picture of an Epstein associate.
DOJ-OGR-00008376.jpg
This document is page 3 of a court filing (Document 545) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 15, 2021. The text argues against the defendant's motion to call three attorneys for victims (Jack Scarola, Brad Edwards, and Robert Glassman) as witnesses, stating such testimony would be irrelevant, duplicative, or improper impeachment. Specifically regarding Jack Scarola, the document notes he represented victim 'Carolyn' in a 2008 lawsuit and before the Epstein Victims Compensation Program, facts which Carolyn already admitted during cross-examination.
DOJ-OGR-00008368.jpg
This legal document, part of a court case and addressed to Judge Alison J. Nathan, argues that any potential attorney-client privilege regarding statements about a person named Carolyn was waived. The argument posits that because Mr. Scarola disclosed this information to the government, the confidentiality required for privilege was broken. The document cites multiple legal precedents to support the claim that this voluntary disclosure to a third party (the government) results in the forfeiture of the privilege, which is relevant for assessing Carolyn's credibility as she testifies against Ms. Maxwell.
DOJ-OGR-00008366.jpg
This legal document, dated December 13, 2021, chronicles the government's efforts throughout 2020 to contact and meet with an individual named Carolyn. The communications were primarily facilitated by an intermediary, Mr. Scarola, who was present at meetings on July 17 and August 11, 2020. The document details the timeline of contact attempts, the involvement of another associate named Mike Danchuck, and a specific statement Mr. Scarola made to the government during one of the meetings.
DOJ-OGR-00008365.jpg
This legal document, dated December 13, 2021, is a filing on behalf of Ms. Maxwell addressed to Judge Alison J. Nathan. The defense argues that the Court should permit the testimony of three witnesses—Mr. Scarola, Mr. Edwards, and Mr. Glassman—to establish motive and bias of Maxwell's accusers, after the government refused to stipulate. The document details the proposed testimony of attorney Jack Scarola, including his prior representation of an accuser named 'Carolyn' in a civil suit against Jeffrey Epstein and his communications with the government.
DOJ-OGR-00021094.jpg
This legal document argues that the government is precluded from charging the Appellant under Count Six due to a prior Non-Prosecution Agreement (NPA). The argument is based on legal precedent against prosecuting the same crime in a new district and asserts that the charge, involving the trafficking of a witness named Carolyn, falls within the time period covered by the NPA. The document also references a court's finding that the NPA covers Maxwell's involvement in offenses committed by Epstein.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Received | Sarah Kellen / Je... | CAROLYN | $600.00 | Offer of 'five to $600' to take pictures of the... | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $0.00 | Gift: Massage book for dummies | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $300.00 | Payment made before Carolyn left the house with... | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $300.00 | Payment for massage, left on the sink. Stated a... | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $400.00 | Payment for massage, left on the sink. Stated a... | View |
| N/A | Received | Victims' Compensa... | CAROLYN | $2,800,000.00 | Payout received by the witness Carolyn, cited b... | View |
| N/A | Received | The defendant (Ma... | CAROLYN | $0.00 | Payments for sexualized massages, personally pa... | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $300.00 | Payment for an encounter involving a massage an... | View |
| N/A | Received | Ghislaine Maxwell... | CAROLYN | $300.00 | Payment for each time Carolyn gave Epstein an e... | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $0.00 | Epstein sent her gifts. | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $0.00 | Epstein paid Carolyn after sexual act. | View |
| N/A | Received | the defendant | CAROLYN | $0.00 | Paid twice as much when she brought friends to ... | View |
| N/A | Paid | CAROLYN | Shawn | $0.00 | Money given to witness, ostensibly for gas, adm... | View |
| N/A | Received | Implied (Epstein/... | CAROLYN | $0.00 | Ms. Roberts told Carolyn 'we could make money' ... | View |
| N/A | Received | Jeffrey Epstein (... | CAROLYN | $600.00 | Payment for massage/visit, paid in hundreds. | View |
| N/A | Received | Mr. Epstein (impl... | CAROLYN | $300.00 | Cash payment found on top of the sink after the... | View |
| N/A | Received | Jeffrey Epstein /... | CAROLYN | $0.00 | Carolyn begging to come over because she 'neede... | View |
| N/A | Received | Implied (Epstein/... | CAROLYN | $0.00 | Money received for attending 'appointments'. | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $0.00 | Over 100 paid sexualized massages. | View |
| N/A | Received | The defendant | CAROLYN | $0.00 | Large sums of money needed to fuel her drug add... | View |
| N/A | Received | The defendant | CAROLYN | $0.00 | Money for engaging in sex acts. | View |
| N/A | Received | Implied (Epstein/... | CAROLYN | $0.00 | General statement that 'we could make money' by... | View |
| N/A | Received | Unnamed Older Man... | CAROLYN | $300.00 | Proposed payment for providing a massage (discu... | View |
| N/A | Received | Implied (Virginia... | CAROLYN | $300.00 | Offer made by Virginia to Carolyn to 'make $300'. | View |
| N/A | Received | Jeffrey Epstein | CAROLYN | $0.00 | Gift: Concert tickets to Incubus | View |
Recruitment/Massage
Virginia allegedly explaining Carolyn could make money massaging a man.
Appointments
Called to schedule appointments
Scheduling appointments
Maxwell would call and set up appointment times.
Scheduling appointments
Sarah would call to schedule appointments.
Scheduling appointments
Carolyn sometimes called to make appointments.
Request for friends
Epstein asked if she had friends her age or younger.
Personal History
Carolyn told Maxwell about her previous sexual abuse by family members.
Sexual Abuse Complaint
A complaint against Epstein and Sarah Kellen that allegedly omitted Ghislaine Maxwell.
Recruitment
Testified she was recruited by Virginia and recruited others.
Recruitment for massages
Virginia told Carolyn she could make money giving massages to a guy in Palm Beach.
Investigation
Investigative interview
Incubus Tickets
Call from New York informing Carolyn that Epstein left concert tickets for her.
Photographs
Call informing Carolyn that Epstein wanted to take photographs of her.
Maxwell's name
Carolyn told Shawn the woman's name was Maxwell but could not pronounce her first name.
Scheduling massages
Maxwell would call and set up appointment times.
Scheduling massages
Sarah Kellen took over calling for appointments.
Scheduling appointments
Carolyn sometimes called to make appointments herself.
Scheduling massage appointments
Maxwell calling to schedule massage appointments.
Package sent by Federal Express
Epstein caused a package to be sent by Federal Express from an address in Manhattan to Carolyn in Florida.
Cross-examination regarding substance abuse
Attorney questions witness about drug use in 2002-2003 and at age 13.
Lawsuit settlement and victim compensation fund payments
An unnamed questioner interviews Carolyn about money she received from a 2009 lawsuit settlement against Jeffrey and Sarah, and a subsequent award from a victim compensation fund related to Jeffrey Epstein.
Direct Examination regarding personal history
Witness testifies about moving to Florida in 1999, dropping out of school in 7th grade, and addiction to pain pills and cocaine.
Direct Examination
Questioning regarding witness's mental health diagnoses (schizophrenia), medications (Vyvanse, Doxepine), and reliability of memory.
Confirmation of past events and prior legal complaints
Questioning regarding paragraph 33 of a 2009 complaint and the details of a sexual encounter with Epstein.
Cross-examination
Questioning regarding signature on Exhibit C8.
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