the defendant
PersonRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Juror 50
|
Legal representative |
17
Very Strong
|
24 | |
|
organization
The government
|
Legal representative |
15
Very Strong
|
65 | |
|
person
Jeffrey Epstein
|
Co conspirators |
13
Very Strong
|
13 | |
|
organization
The government
|
Adversarial |
13
Very Strong
|
21 | |
|
person
Jeffrey Epstein
|
Business associate |
13
Very Strong
|
23 | |
|
person
Epstein
|
Business associate |
12
Very Strong
|
9 | |
|
person
Juror 50
|
Juror defendant |
11
Very Strong
|
7 | |
|
organization
The Court
|
Legal representative |
11
Very Strong
|
13 | |
|
person
Defense counsel
|
Legal representative |
11
Very Strong
|
10 | |
|
person
ALISON J. NATHAN
|
Judicial |
10
Very Strong
|
6 | |
|
person
Defense counsel
|
Client |
10
Very Strong
|
8 | |
|
person
Epstein
|
Co conspirators |
10
Very Strong
|
14 | |
|
organization
GOVERNMENT
|
Legal representative |
10
Very Strong
|
6 | |
|
person
MDC staff
|
Custodial |
10
Very Strong
|
6 | |
|
organization
GOVERNMENT
|
Adversarial |
10
Very Strong
|
7 | |
|
person
Defense counsel
|
Professional |
9
Strong
|
5 | |
|
person
JANE
|
Abuser victim |
9
Strong
|
5 | |
|
person
Giuffre
|
Legal representative |
9
Strong
|
5 | |
|
person
Mr. Everdell
|
Legal representative |
8
Strong
|
4 | |
|
person
Jeffrey Epstein
|
Co conspirator alleged |
8
Strong
|
4 | |
|
person
Epstein
|
Financial |
8
Strong
|
3 | |
|
person
Epstein
|
Legal representative |
8
Strong
|
3 | |
|
person
Minor Victim-3
|
Abuser victim |
7
|
3 | |
|
location
France
|
Citizenship |
7
|
3 | |
|
person
Minor Victim-4
|
Legal representative |
7
|
3 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Testimony of Minor Victims-1 through -4 | Court | View |
| N/A | N/A | Illegal sexual abuse | Unknown | View |
| N/A | N/A | Payment of criminal monetary penalties within 30 (or 60) days after release from imprisonment, ba... | N/A | View |
| N/A | N/A | Jane's testimony regarding sexual abuse | New Mexico (abuse location) | View |
| N/A | N/A | Sexual Abuse | Unspecified | View |
| N/A | N/A | Defendant living in isolation and hiding assets | Unknown hiding location | View |
| N/A | N/A | Period during which the defendant and Epstein committed crimes together. | Epstein's properties | View |
| N/A | N/A | Attendance at Arts Camp | Arts Camp | View |
| N/A | N/A | Flights on private planes with minors | Epstein's private planes | View |
| N/A | N/A | Search of the New York Residence. | New York Residence | View |
| N/A | N/A | Limited Hearing | Court | View |
| N/A | N/A | Trial completion | Court | View |
| N/A | N/A | Flight to New Mexico | New Mexico | View |
| N/A | N/A | Post-trial allegation of juror bias | Court | View |
| N/A | N/A | Defendant's evasion of detection leading up to arrest. | Unknown | View |
| N/A | N/A | Massages taking place in Epstein's bedroom. | Epstein's Bedroom | View |
| N/A | N/A | Defendant's Quarantine | MDC | View |
| N/A | N/A | Motion for a New Trial | Court | View |
| N/A | N/A | Grooming and sex acts involving Minor Victim-3 | London | View |
| N/A | N/A | Evasion of detection/press | Unknown | View |
| N/A | N/A | Deposition where alleged perjury occurred. | Unknown | View |
| N/A | N/A | Sentencing Hearing / Legal Ruling | Courtroom (Southern District) | View |
| N/A | N/A | Arrest of Defendant | N/A | View |
| N/A | N/A | Anticipated trial where evidence regarding victims and terms like 'rape' will be used. | Court | View |
| N/A | N/A | Sentencing hearing ruling where the judge determines Virginia Roberts and Melissa are victims for... | Courtroom | View |
DOJ-OGR-00009837.jpg
This document is page 39 of a government legal filing (Document 643) in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The prosecution argues against the defendant's motion to call all twelve jurors as witnesses to investigate potential non-disclosure of sexual abuse, labeling it a 'fishing expedition' damaging to the jury process. The text specifically addresses a New York Times article mentioning a second juror's abuse history and argues that questioning should be strictly limited to Juror 50.
DOJ-OGR-00009823.jpg
This page from a legal filing (Case 1:20-cr-00330-PAE) argues against a defense motion claiming Juror 50 was biased. The Government asserts that Juror 50's post-trial statements and negative attitude toward the defendant reflect the evidence presented during the trial, not pre-existing bias. It cites legal precedents including *United States v. Stewart* to support the argument that jurors bring subjective lived experiences to deliberations.
DOJ-OGR-00009818.jpg
This legal document is a filing that refutes a defendant's claims that a juror, Juror 50, lied during the jury selection process (voir dire). The filing argues there is insufficient evidence to prove the juror deliberately lied about not being a victim of a crime or about his social media usage. It specifically addresses the juror's failure to mention an inactive Twitter account and the claim he deleted his Facebook and Instagram accounts, suggesting these were not material or deliberate falsehoods.
DOJ-OGR-00009815.jpg
This document is page 17 of a legal brief filed on March 11, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). It argues that the defendant has not met the burden of proving that 'Juror 50' deliberately lied during jury selection (voir dire) regarding past sexual abuse, distinguishing between deliberate deceit and honest mistakes based on Second Circuit case law. The Government notes that while Juror 50 made public statements about being a victim, it is not yet proven that his questionnaire answers were deliberately false.
DOJ-OGR-00009813.jpg
This is page 15 of a legal filing (Document 643) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on March 11, 2022. The Government argues that the defendant has failed to meet the 'McDonough test' requirements to secure a new trial based on juror misconduct, specifically stating that the defendant must prove the juror committed a 'deliberate falsehood' rather than an honest mistake. Despite this, the Government notes that it consents to a 'limited hearing' on the matter.
DOJ-OGR-00009644.jpg
This legal document, dated March 1, 2022, is a page from a court filing in case 1:20-cr-00330-PAE. It appears to be a transcript of questions directed at a potential juror regarding their knowledge of the case, which they gained from a jury questionnaire. The questionnaire summarized charges that 'the Defendant' conspired with and aided Jeffrey Epstein in sex trafficking of minors from 1994 through 2004.
DOJ-OGR-00009613.jpg
This is the conclusion and signature page of a legal filing by the United States Attorney for the Southern District of New York (Case 1:20-cr-00330-PAE). The Government submits that the Court should grant the defendant's motion regarding 'Count One' but deny all other post-trial motions. The document is dated February 25, 2022, and signed by US Attorney Damian Williams and four Assistant US Attorneys.
DOJ-OGR-00009612.jpg
This legal document excerpt details the conviction of 'the defendant' on multiple counts related to sex trafficking and exploitation. It outlines evidence showing the defendant's involvement in transporting and abusing Jane with Epstein, arranging sex acts for Carolyn with Epstein for money, and recruiting Virginia, all while they were minors. The document emphasizes that the evidence was sufficient to sustain the jury's verdict despite defense arguments regarding victim credibility.
DOJ-OGR-00009596.jpg
This legal document is a filing by the Government arguing against the defendant's motion to vacate her conviction and dismiss the indictment. The Government contends that the conspiracies were distinct from those of Epstein, despite shared methods like grooming, and that the defendant has failed to prove her due process rights were violated by any pre-trial delay, as she has not shown actual prejudice.
DOJ-OGR-00009595.jpg
This page from a court filing (Case 1:20-cr-00330) argues against a claim of multiplicity by distinguishing between two separate conspiracies involving the defendant. It details a 1990s scheme focused on grooming and mentoring victims for abuse at Epstein's properties, and a separate 2000s 'pyramid scheme' where victims were paid to recruit others for massage appointments.
DOJ-OGR-00009593.jpg
This document is page 31 of a legal filing from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 25, 2022. It argues against a defense claim of 'multiplicity' regarding conspiracy counts, referencing trial testimony from a victim named Carolyn. The text highlights that Sarah Kellen, Epstein's personal assistant since the early 2000s, contacted Carolyn to schedule appointments for sexualized massages.
DOJ-OGR-00009589.jpg
This page is from a legal filing (Document 621) in the case US v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 25, 2022. The text presents legal arguments citing Second Circuit precedents (specifically the 'Korfant factors') to argue that separate conspiracy counts are distinct and do not violate double jeopardy protections. The prosecution argues that Counts Three and Five charge different offenses and requests the Court reject the defendant's multiplicity claim.
DOJ-OGR-00009587.jpg
This document is page 25 of a legal filing (Document 621) from Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), filed on February 25, 2022. The Government argues that the Court should enter judgment on Count Three (Mann Act conspiracy) and Count Five (Sex Trafficking conspiracy under the Trafficking Victims Protection Act), asserting they are distinct criminal schemes and not multiplicitous. It also addresses procedural arguments regarding jury instructions related to a witness/victim referred to as 'Jane'.
DOJ-OGR-00009585.jpg
This document is page 23 of a legal filing (Document 621) in Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on Feb 25, 2022. It argues that no legal 'variance' occurred during the trial regarding the charges in the S2 Indictment. The text discusses the grooming of a victim named 'Jane' between 1994 and 1997 and addresses the defendant's argument regarding prejudice concerning testimony about abuse at Epstein's ranch in New Mexico.
DOJ-OGR-00009583.jpg
This document is page 21 of a legal filing (Document 621) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on February 25, 2022. The text contains legal analysis rejecting the defendant's argument that the Court's response to a jury note constructively amended the indictment. It cites various legal precedents (Jones, Lebedev, Muraca) to support the Court's discretion in handling jury inquiries and instructions.
DOJ-OGR-00009573.jpg
This page is from a Government legal filing (Document 621, Case 1:20-cr-00330-PAE) arguing against a post-trial motion by the defendant (Ghislaine Maxwell). The Government asserts that the jury did not improperly convict the defendant based solely on sexual abuse of a victim named 'Jane' in New Mexico, but rather followed instructions regarding violations of New York law. The text discusses jury instructions, the lack of New Mexico specific legal charges presented to the jury, and refutes the defense's claim of a constructive amendment or variance.
DOJ-OGR-00009572.jpg
This document is page 10 of a legal filing (Document 621) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 25, 2022. It discusses the Court's jury instructions regarding the Mann Act, specifically focusing on whether the defendant intended for victims (referred to as 'Jane,' 'Kate,' and 'Annie') to engage in sexual activity in New York in violation of New York Penal Law Section 130.55. The text argues that the Court properly defined the scope of the alleged crimes and limited the jury's consideration to specific state offenses.
DOJ-OGR-00009564.jpg
This document is the table of contents for a legal filing (Document 621) in case 1:20-cr-00330-PAE, filed on February 25, 2022. The filing outlines legal arguments against a defendant's motions to vacate their conviction, dismiss the indictment due to alleged pre-trial delays, and for a judgment of acquittal. The document structures the arguments, including discussions on applicable law and specific counts of the indictment.
DOJ-OGR-00009561.jpg
This document is page 20 of a Court Order filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell. The Judge orders that Juror 50's completed questionnaire be unsealed and docketed, citing that public interest outweighs privacy concerns following the juror's public comments. Additionally, the Court schedules a hearing for March 8, 2022, requiring Juror 50 to testify under oath regarding their answers to specific questions on the juror questionnaire.
DOJ-OGR-00009560.jpg
This document is page 19 of a court order filed on February 25, 2022, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Court denies the Defendant's request for pre-hearing discovery, characterizing it as a 'fishing expedition.' Additionally, the Court rules that 'Juror 50' will be provided a copy of his completed jury questionnaire and that the document must be unsealed (docketed), rejecting the Defendant's argument that this would taint the juror's testimony.
DOJ-OGR-00009559.jpg
This page is from a court order (Case 1:20-cr-00330-PAE, likely *US v. Maxwell*) denying the Defendant's request to subpoena social media companies for Juror 50's communications. The Court rules that the request is a 'fishing expedition' and procedurally improper under the Stored Communications Act (SCA), which generally prohibits private parties (like the Defendant) from subpoenaing content from providers like Facebook or Instagram; only the Government may do so with a warrant.
DOJ-OGR-00009551.jpg
This court order page denies the Defendant's (Maxwell) request to investigate Juror 50's social media and to examine other jurors regarding a 'second juror' allegedly abused as a minor. The court rules that Juror 50's Instagram posts were personal and do not warrant a 'fishing expedition,' and that the theory regarding a second juror is unfounded speculation based on a New York Times article. Footnote 5 details a timeline of communications between the court and jurors regarding media harassment, noting that these communications will be shared with the parties under seal with redactions to protect juror privacy.
DOJ-OGR-00009550.jpg
This document is page 9 of a court filing (Document 620) from the United States v. Ghislaine Maxwell case, dated February 25, 2022. The text discusses a post-trial motion regarding 'Juror 50,' specifically addressing whether the juror lied during voir dire about social media usage. The Court ruled that a hearing is warranted regarding specific questionnaire answers but denied the Defendant's request to probe the juror's social media history, citing that the juror's minimal Twitter usage and explanation for deleting apps were consistent with their testimony.
DOJ-OGR-00009546.jpg
This document is page 5 of a court filing (Case 1:20-cr-00330-PAE) dated February 25, 2022. The Court denies the Defendant's (Maxwell) motion for an immediate new trial based on the current record but rules that an evidentiary hearing must be held to investigate Juror 50's alleged nondisclosure of sexual abuse history during jury selection. The text cites the 'McDonough standard' and legal precedents requiring hearings when juror impartiality is in doubt.
DOJ-OGR-00009544.jpg
This document is Page 3 of a court filing (Document 620) from February 25, 2022, in the Ghislaine Maxwell case (1:20-cr-00330). It details the discovery that 'Juror 50' gave media interviews admitting to being a sexual abuse victim despite denying it on his juror questionnaire, leading the Defendant to file a motion for a new trial. The document also chronicles communications between Juror 50 and the SDNY Jury Department/District Executive in January 2022, where the juror sought legal guidance and access to his questionnaire.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Paid | the defendant | Security Guards | $0.00 | Defendant proposes to pay for on-premises secur... | View |
| N/A | Paid | the defendant | Young girls | $0.00 | Cash payments handed to girls after massage app... | View |
| N/A | Paid | the defendant | Bank Accounts | $0.00 | Placing assets into accounts held under other n... | View |
| N/A | Paid | the defendant | Unnamed real esta... | $0.00 | Purchasing a home using a trust in another name. | View |
| N/A | Paid | the defendant | Unknown (Employee... | $250,000.00 | Payment discussed by The Court and Defense as p... | View |
| N/A | Paid | the defendant | Unknown (Employee... | $100,000.00 | Payment discussed by The Court and Defense as p... | View |
| N/A | Paid | the defendant | Security Guards | $0.00 | Proposal that Defendant would pay for on-premis... | View |
| N/A | Received | Epstein | the defendant | $0.00 | Receipt of funds mentioned in context of missin... | View |
| N/A | Paid | the defendant | Spouse/Husband | $0.00 | Transfer of 'millions of dollars' of assets thr... | View |
| N/A | Paid | the defendant | CAROLYN | $0.00 | Paid twice as much when she brought friends to ... | View |
| N/A | Paid | the defendant | Virginia | $0.00 | Paid more as encouragement to recruit additiona... | View |
| N/A | Received | Sale of Property | the defendant | $0.00 | Sale of the Manhattan townhouse, noted as the p... | View |
| N/A | Paid | the defendant | Various Accounts | $0.00 | Placing assets into accounts held under other n... | View |
| N/A | Paid | the defendant | Unknown seller | $0.00 | Purchase of a real estate transaction under a f... | View |
| N/A | Paid | the defendant | US | $0.00 | Purchasing a home using a trust in another name. | View |
| N/A | Received | Jeffrey Epstein | the defendant | $0.00 | Hypothetical 'absence of payments' mentioned as... | View |
| N/A | Paid | the defendant | Real Estate Selle... | $0.00 | Purchase of a real estate transaction under a f... | View |
| N/A | Paid | the defendant | Virginia | $0.00 | Monetary incentives used to encourage Virginia ... | View |
| N/A | Paid | the defendant | Security Guards | $0.00 | Proposal that Defendant would pay for on-premis... | View |
| N/A | Received | N/A | the defendant | $70,000.00 | Cash found in safe at NY home. | View |
| N/A | Paid | the defendant | Unknown | $0.00 | Purchase of Kinnerton Street residence | View |
| 2025-03-01 | Paid | the defendant | Marital Assets | $20,000,000.00 | Amount brought to the marriage by the defendant... | View |
| 2023-02-28 | Paid | the defendant | Court/Government | $750,000.00 | Fine imposed as part of sentencing | View |
| 2022-07-08 | Paid | the defendant | Court/Government | $750,000.00 | Fine imposed as part of sentencing. | View |
| 2022-07-08 | Paid | the defendant | Court/Government | $750,000.00 | Criminal Fine imposed during sentencing | View |
No Subject
The document states the defendant has access to email with her defense counsel while detained at the MDC.
No Subject
The document states the defendant has access to calls with her defense counsel while detained at the MDC.
Tax returns
The defendant was faxed information relating to the tax returns.
Legal consultation
The defendant will be given a legal call to confer with her counsel if the counsel does not visit in person on the day of the report.
Legal counsel communication
The document states that MDC staff does not record or listen to the substance of the defendant’s calls and visits with legal counsel.
Defendant's finances and property ownership
The defendant told Pretrial Services that a New Hampshire property was owned by a corporation whose name she didn't know, and she was just permitted to stay there.
Defendant's finances and property ownership
The defendant told Pretrial Services that a New Hampshire property was owned by a corporation whose name she didn't know, and she was just permitted to stay there.
Legal Counsel
5 hours per weekday; 25 hours per week total.
In-person legal visits
In-person visits as needed.
Carolyn's life and background
The defendant had multiple conversations with Carolyn, during which Carolyn revealed details about her life, including prior sexual abuse, her parents' separation, and her mother's addiction.
Legal Consultation
Defense counsel will be able to schedule legal calls for the defendant on weekends as needed.
Defendant's bail proposal and financial resources
The defendant submitted a memorandum that the government claims pointedly declines to provide information about her financial resources.
Legal consultation
In-person visits available 7 days a week but declined by counsel
Legal consultation
VTC calls and supplemental phone calls
Legal consultation
Defendant is able to send and receive emails every day
Third motion for bail
Defendant argues new conditions warrant reconsideration of earlier rulings and that the Government's case is diminished.
Little Black Book
Contact book containing Melissa's name and noting she is a friend of Carolyn's.
Maxwell Br. at 53
Argument that disclosure will color Juror 50's testimony.
Work duties
Instructions to schedule massage appointments, set up massage tables, clean up after massages.
Massages
Defendant denies giving massages to anyone, including Epstein and Minor Victim-2.
Civil matter depositions
Two depositions in a civil matter where the defendant allegedly made false material declarations.
Code of Silence
Instructed employees not to speak directly with Epstein, not to talk to visitors, and to 'see nothing, hear nothing, say nothing.'
Instruction
Directed Virginia to show Carolyn how to sexually gratify Epstein.
Dkt. No. 569
Informing the Court about the juror's interviews.
Dkt. No. 570
Opposing the Government's request for a hearing and arguing for a new trial.
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