the defendant

Person
Mentions
996
Relationships
332
Events
485
Documents
491

Relationship Network

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Interactive Network: Click nodes or edges to highlight connections and view details with action buttons. Drag nodes to reposition. Node size indicates connection count. Line color shows relationship strength: red (8-10), orange (6-7), yellow (4-5), gray (weak). Use legend and help buttons in the graph for more guidance.
332 total relationships
Connected Entity Relationship Type
Strength (mentions)
Documents Actions
person Juror 50
Legal representative
17 Very Strong
24
View
organization The government
Legal representative
15 Very Strong
65
View
person Jeffrey Epstein
Co conspirators
13 Very Strong
13
View
organization The government
Adversarial
13 Very Strong
21
View
person Jeffrey Epstein
Business associate
13 Very Strong
23
View
person Epstein
Business associate
12 Very Strong
9
View
person Juror 50
Juror defendant
11 Very Strong
7
View
organization The Court
Legal representative
11 Very Strong
13
View
person Defense counsel
Legal representative
11 Very Strong
10
View
person ALISON J. NATHAN
Judicial
10 Very Strong
6
View
person Defense counsel
Client
10 Very Strong
8
View
person Epstein
Co conspirators
10 Very Strong
14
View
organization GOVERNMENT
Legal representative
10 Very Strong
6
View
person MDC staff
Custodial
10 Very Strong
6
View
organization GOVERNMENT
Adversarial
10 Very Strong
7
View
person Defense counsel
Professional
9 Strong
5
View
person JANE
Abuser victim
9 Strong
5
View
person Giuffre
Legal representative
9 Strong
5
View
person Mr. Everdell
Legal representative
8 Strong
4
View
person Jeffrey Epstein
Co conspirator alleged
8 Strong
4
View
person Epstein
Financial
8 Strong
3
View
person Epstein
Legal representative
8 Strong
3
View
person Minor Victim-3
Abuser victim
7
3
View
location France
Citizenship
7
3
View
person Minor Victim-4
Legal representative
7
3
View
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-00005557.jpg

This document is page 3 of 40 from a legal filing (Document 383) in Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on October 29, 2021. It is a Table of Contents listing arguments G through I, which focus on excluding evidence of victims' consent, addressing defense refusals regarding motions, and preventing the defense from mentioning previous civil litigation outcomes to the jury. The page bears a Department of Justice footer stamp.

Legal filing (table of contents)
2025-11-20

DOJ-OGR-00005556.jpg

This document is the table of contents for a legal motion filed by the government on October 29, 2021, in case 1:20-cr-00330-PAE. The motion outlines arguments to protect the privacy of minor victims by allowing testimony under pseudonyms and sealing exhibits. It also seeks to preclude the defense from introducing what the government deems irrelevant evidence and improper arguments, including prior investigations of the defendant and the government's alleged motives.

Legal document
2025-11-20

DOJ-OGR-00005416.jpg

This page is from a legal filing (Document 380) in the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on October 29, 2021. It contains a Government argument (Section A) requesting the Court preclude the Defense from presenting evidence regarding government charging decisions. The text cites Federal Rules of Evidence 402 and 403 and case law (Rosado, Borrero) to argue that such evidence is irrelevant, hearsay, and likely to confuse the jury.

Legal filing / court motion (government motion in limine)
2025-11-20

DOJ-OGR-00005413.jpg

This document is page 20 of a legal filing (Doc 380) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. The Government argues for the admissibility of 'prior consistent statements' made by Minor Victims to other witnesses regarding sexual abuse by the defendant and Jeffrey Epstein in the 1990s and early 2000s. The text asserts these statements, made over a decade ago, refute potential defense claims of recent fabrication or improper influence.

Legal filing (government motion/memorandum)
2025-11-20

DOJ-OGR-00005407.jpg

This document is page 14 of a legal filing (Document 380) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), dated October 29, 2021. The text argues for the protection of the identities of Minor Victims 1 through 6, citing the risk of social stigma, harassment by the press, and damage to future employment prospects. It notes that Victims 1-4 are expected to testify about explicit sexual abuse by Epstein and the defendant, while Victims 5 and 6 will not testify.

Legal filing (court order/memorandum)
2025-11-20

DOJ-OGR-00005395.jpg

This document is the table of contents for a legal motion filed on October 29, 2021, in case 1:20-cr-00330-PAE. The motion, presumably from the prosecution, outlines a series of requests to the court to limit the defense's ability to introduce certain evidence and arguments during the upcoming trial. Key issues addressed include protecting witness identities, the admissibility of minor victims' statements, precluding discussion of prior investigations, and preventing arguments related to jury nullification or the defendant's status in a past civil case.

Legal document
2025-11-20

DOJ-OGR-00005320.jpg

This document is a page from a court filing (Case 1:20-cr-00330, United States v. Ghislaine Maxwell) filed on October 22, 2021, containing instructions to the jury pool. The text outlines strict prohibitions against jurors discussing the case on social media or conducting independent research via Google or news outlets. It also details privacy and safety measures due to the 'high-profile' nature of the case and COVID-19, including the use of juror numbers instead of names and the provision of daily transportation for jurors.

Court filing / jury instructions / transcript
2025-11-20

DOJ-OGR-00005251.jpg

This document is Page 2 of a legal filing from the United States v. Ghislaine Maxwell case (1:20-cr-00330), filed on October 18, 2021. The text outlines legal arguments regarding jury selection (*voir dire*), citing Second Circuit precedents to argue that the court, rather than attorneys, should conduct the questioning of potential jurors to ensure impartiality and efficiency. The filing asserts that the defendant (Maxwell) has provided no persuasive reason to deviate from this customary practice.

Legal filing / court order (page 2 of 5)
2025-11-20

DOJ-OGR-00005235.jpg

This document is Page 2 of a Government filing (Case 1:20-cr-00330-PAE, filed 10/15/21) addressing defense complaints regarding legal mail delays at the MDC. The Government argues that a request for 1-day mail turnaround is burdensome given the facility houses 1,700 inmates. It details the timeline of a specific hard drive delivery: sent Oct 11, received Oct 12, delayed Oct 13 due to an 'institutional emergency,' and personally delivered to the defendant by MDC legal counsel on Oct 14, 2021.

Court filing / legal memorandum
2025-11-20

DOJ-OGR-00002893.jpg

This document is Page 4 of a legal filing (Document 195) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell) filed on April 5, 2021. The text argues that defense subpoenas asking for 'any and all' records are improper discovery requests and asserts that the Court should require the Defendant to notify the Government of any Rule 17(c) subpoena applications. It cites concerns regarding the harassment of witnesses and the protection of victim confidentiality.

Legal filing / court memorandum
2025-11-20

DOJ-OGR-00002883.jpg

This legal document, dated March 22, 2021, is a submission by Sigrid S. McCawley arguing against a defendant's motion to subpoena evidence from a third party, BSF. The document contends that the requested materials—including communications, a Grand Jury subpoena, cowboy boots, and photographs involving individuals like Annie Farmer, Virginia Giuffre, and Jeffrey Epstein—are either obtainable from the government or not relevant enough to require pre-trial production. The author concludes that the defendant's motion should be denied.

Legal document
2025-11-20

DOJ-OGR-00005863.jpg

This is a page from a Government legal filing (dated Oct 29, 2021) in the case against Ghislaine Maxwell. It argues that witnesses, including expert Dr. Rocchio and the Minor Victims themselves, should be permitted to use the term 'victim' during testimony. Furthermore, it discloses that the Government expects testimony describing Jeffrey Epstein raping a minor, arguing this is directly relevant to the charges of trafficking and enticing minors.

Legal filing / court document (government motion/response)
2025-11-20

DOJ-OGR-00005861.jpg

This legal document is a portion of the Government's response to a defense motion in case 1:20-cr-00330-PAE, filed on October 29, 2021. The Government argues against the defendant's request to prohibit the use of the word 'victim' when referring to the 'Minor Victims' during the trial. The prosecution contends that using the term is part of its legitimate litigating position and not improper vouching for witness credibility, citing legal precedent from the Second Circuit to support its stance.

Legal document
2025-11-20

DOJ-OGR-00005837.jpg

This document is a page from a Government filing in the Ghislaine Maxwell trial (Case 1:20-cr-00330), filed on October 29, 2021. It argues for the admissibility of the terms 'minor' and 'sexual abuse' regarding Minor Victim-3, noting she was 17 when sexual contact with Epstein began. The prosecution asserts that the defendant knew of Epstein's preference for underage girls and rejects the defense's request for jury instructions regarding United Kingdom law.

Court filing (legal brief/motion response)
2025-11-20

DOJ-OGR-00005836.jpg

This document page discusses legal arguments regarding the admissibility of testimony from "Minor Victim-3" in a case involving Jeffrey Epstein and a defendant. The text argues against the defense's claim that such testimony would be unfairly prejudicial or cause confusion regarding United Kingdom law, asserting that jury instructions will be sufficient.

Legal filing / court order page
2025-11-20

DOJ-OGR-00005835.jpg

This document is page 52 of a legal filing (Case 1:20-cr-00330, U.S. v. Ghislaine Maxwell) dated October 29, 2021. The text argues for the admissibility of 'Minor Victim-3's' testimony under Rule 404(b) to establish the defendant's intent and modus operandi regarding grooming and recruitment. It cites three legal precedents (Vickers, McDarrah, and Brand) to support the admission of evidence regarding grooming, email communications, and interest in minors.

Legal filing / court document (motion/brief)
2025-11-20

DOJ-OGR-00005834.jpg

This legal document, filed on October 29, 2021, is a prosecution argument asserting that evidence related to the defendant's involvement with "Minor Victim-3" is admissible in court. The prosecution argues these actions are direct evidence of the defendant's role in a conspiracy to provide minors to Jeffrey Epstein for sexual abuse. The document dismisses the relevance of United Kingdom law and clarifies that this evidence is crucial for demonstrating the defendant's knowledge and participation in the scheme, even if a conviction cannot be based solely on this victim's testimony due to the statute of limitations.

Legal document
2025-11-20

DOJ-OGR-00005826.jpg

This legal document, filed on October 29, 2021, details allegations against a defendant concerning their involvement with 'Minor Victim-3' and Epstein in London between 1994 and 1995. The defendant is accused of befriending the minor, introducing her to Epstein, and encouraging her to give him massages, which led to sexual abuse by Epstein. The document also outlines the government's opposition to the defendant's motion to strike these allegations from the indictment, arguing they are evidence of a broader criminal scheme.

Legal document
2025-11-20

DOJ-OGR-00005825.jpg

This document is page 42 of a legal filing (Document 397) from October 29, 2021, in the case against Ghislaine Maxwell (implied by case number). The Government argues that the testimony of 'Minor Victim-3' is admissible as direct evidence of the charged offenses, specifically citing the sexual abuse committed by the defendant and Jeffrey Epstein. It also addresses procedural arguments regarding Rule 404(b) notices.

Legal filing (court brief/motion response)
2025-11-20

DOJ-OGR-00005817.jpg

This is page 34 of a legal filing (Document 397) in case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on October 29, 2021. The Government argues against the defendant's motion to exclude certain evidence under Rule 404(b), asserting they provided sufficient notice and Jencks Act materials. The text cites Second Circuit case law to define relevant evidence and justify the admission of uncharged crimes if they are inextricably intertwined with the charged offense.

Legal filing (government opposition to motion in limine)
2025-11-20

DOJ-OGR-00002905.jpg

This document is page 5 of a legal filing (Case 1:20-cr-00330-PAE) dated April 6, 2021, addressing the confinement conditions of the defendant (Ghislaine Maxwell). It details that her meals are heated in thermal ovens and defends the quality of tap water at the MDC, noting that staff drink the same water and bottled water is provided during maintenance. The filing also reports on the defendant's health, stating she is weighed weekly (fluctuating between 130s and 140s lbs), has a normal BMI, has not experienced hair loss, and is fully vaccinated against COVID-19.

Legal filing / court document (status report or response regarding conditions of confinement)
2025-11-20

DOJ-OGR-00002903.jpg

This document is page 3 of a court filing (Case 1:20-cr-00330-PAE) dated April 6, 2021, detailing the detention conditions of a female defendant (Ghislaine Maxwell) at the MDC. It confirms the defendant is fully vaccinated against COVID-19 and communicates with counsel via VTC and email, as counsel has declined in-person visits. The text also describes security protocols, including daily pat-down searches during movement between the isolation cell and day room, as well as weekly body scans.

Court filing / government response
2025-11-20

DOJ-OGR-00002902.jpg

This document is page 2 of a legal filing from April 6, 2021, regarding Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It details the conditions of the defendant's confinement at the MDC, specifically highlighting that she is separated from her isolation cell from 7am to 8pm daily with access to electronics and showers. The text extensively describes the protocols for attorney-client communications, noting she receives 25 hours of private VTC calls per week, and clarifies that surveillance cameras monitor the door but do not record the audio or visual content of these legal meetings.

Federal court filing / legal status report (case 1:20-cr-00330-pae)
2025-11-20

DOJ-OGR-00002897.jpg

This is page 8 of a court filing (Document 195) in Case 1:20-cr-00330-PAE (US v. Maxwell), filed on April 5, 2021. The Government argues against the defendant's attempt to issue a subpoena to 'BSF' (Boies Schiller Flexner), characterizing it as an improper 'fishing expedition' for victim information and impeachment material that violates the 'Nixon test.' The Government also notes that the defendant failed to file a required response by the April 2, 2021 deadline.

Court filing / legal memorandum
2025-11-20

DOJ-OGR-00002753.jpg

This document is page 6 of a US Government filing (Case 1:20-cr-00330-AJN) opposing the defendant's (Ghislaine Maxwell) third bail motion. The prosecution argues that the defendant's offer to renounce her French and British citizenships is "window dressing" and a strategic but meaningless gesture. The document cites correspondence with the French Ministry of Justice confirming that France will not extradite her because she held French nationality at the time of the alleged crimes (1990s and 2016), regardless of current renunciation. It further notes that while UK extradition is not barred by nationality, the process is lengthy, uncertain, and subject to extensive litigation.

Legal filing (court document - government opposition to bail motion)
2025-11-20
Total Received
$459,768,958.00
14 transactions
Total Paid
$45,550,000.00
31 transactions
Net Flow
$414,218,958.00
45 total transactions
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
As Sender
73
As Recipient
17
Total
90

Def. Mot.

From: the defendant
To: THE COURT

Arguments for bail including family ties, financial reports, and extradition waivers.

Motion
2020-12-30

Plea Entry

From: THE COURT
To: the defendant

Discussion regarding waiving the reading of the indictment and entering a plea.

Court proceeding
2020-12-10

Legal Strategy/Defense

From: the defendant
To: Defense counsel

Access to email with defense counsel

Email
2020-12-01

Asset Information

From: the defendant
To: THE COURT

Information presented regarding assets, which showed discrepancies compared to July 2020.

Disclosure
2020-12-01

Legal Strategy/Defense

From: the defendant
To: Defense counsel

Calls with defense

Call
2020-12-01

Reply letter regarding disclosure of information

From: the defendant
To: THE COURT

Defendant states she is seeking to disclose factual information under seal regarding grand jury subpoenas.

Letter
2020-08-24

Request to disclose information under seal

From: the defendant
To: THE COURT

Defendant seeking to disclose factual information regarding grand jury subpoenas to judicial officers.

Reply letter
2020-08-24

Reply Letter (Dkt. No. 46)

From: the defendant
To: THE COURT

States she is seeking to disclose factual information regarding grand jury subpoenas under seal to judicial officers.

Letter
2020-08-24

Arrest

From: FBI agents
To: the defendant

Announced themselves and directed defendant to open the door.

Verbal command
2020-07-02

Asset declaration and residence status

From: the defendant
To: Pretrial Services

Defendant claimed property was owned by a corporation and she was 'just able to stay there'; declared approx $3.4M in assets.

Interview/report
2020-07-01

Asset Information

From: the defendant
To: Pretrial Services

Information presented regarding assets.

Disclosure
2020-07-01

Personal Status

From: the defendant
To: Pretrial Services

Stated she has no children, no current employment, and was in the process of divorcing her husband.

Interview/report
2020-01-01

Financial Disclosure Form

From: the defendant
To: THE COURT

A form submitted by the defendant which the government argues is incomplete, unsworn, and lacks validation.

Legal document
2019-07-24

Form 114 (FBAR)

From: the defendant
To: United States Treasury...

Submissions listing accounts at the English Bank.

Form submission
2018-01-01

Scheduling

From: the defendant
To: CAROLYN

Setting up appointments for Carolyn to perform sexualized massages on Epstein.

Call
2001-01-01

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