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-00009538.jpg
This document is page 2 of a legal filing (Document 617) in Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on February 24, 2022. The text argues against the defendant's claim that 'Juror 50's' motion to intervene constitutes a discovery request, clarifying that the juror is seeking access to his own questionnaire which he swore under penalty of perjury. The filing argues that the motion is a judicial document that should not remain sealed, noting the defendant's arguments regarding privacy and potential prejudice lack merit.
DOJ-OGR-00003147.jpg
This is a page from a Government legal filing (Case 1:20-cr-00330-PAE) responding to defense motions regarding discovery. The Government argues that witness statements (Jencks Act material) need not be disclosed immediately, and that a request for an unredacted FBI report is moot because it was already provided in November 2020. A key revelation in the footnotes is that a redacted version of an FBI report submitted by the defense was actually recovered directly from one of Jeffrey Epstein's personal devices during a search warrant execution.
DOJ-OGR-00003130.jpg
This document is page 196 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues for the admissibility of evidence regarding 'Minor Victim-3' to demonstrate the defendant's intent and modus operandi, citing legal precedents (McDarrah, Brand). It also argues that the defendant's motion to dismiss Counts One or Three based on multiplicity is premature under Second Circuit precedent.
DOJ-OGR-00003129.jpg
This document is page 195 of 239 from a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330), filed on April 16, 2021. The text argues for the admissibility of evidence regarding 'Minor Victim-3' under Federal Rules of Evidence 403 and 404(b), stating that the defendant's grooming patterns were idiosyncratic and that the evidence is not unfairly prejudicial compared to the charges involving Victims 1 and 2. It explicitly states the defendant witnessed and participated in the abuse of victims at the hands of Epstein.
DOJ-OGR-00003128.jpg
This document is a page from a legal filing (Case 1:20-cr-00330-PAE, US v. Ghislaine Maxwell) arguing for the admissibility of evidence under Rule 404(b). It details the defendant's 'modus operandi' of befriending minors (specifically Minor Victim-3), normalizing sexual topics, and arranging travel to facilitate sexual acts with Epstein. A footnote addresses the defense's anticipated argument regarding lack of knowledge or intent.
DOJ-OGR-00003124.jpg
This document is page 190 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The Government argues against striking allegations related to 'Minor Victim-3,' asserting that her testimony regarding grooming and sex acts in London is probative of the defendant's intent and the conspiracy with Jeffrey Epstein, even if potential statute of limitations issues exist for specific charges. The document emphasizes that the evidence establishes the relationship between the defendant and Epstein.
DOJ-OGR-00003118.jpg
This page is from a Government legal filing (Document 204, filed April 16, 2021) in the case against Ghislaine Maxwell. The Government argues against the defendant's motion to dismiss counts 1-4 and specifically opposes the motion to strike references to 'Minor Victim-3' from the indictment. The prosecution asserts that interactions between the defendant, Epstein, and Minor Victim-3 were part of the broader conspiracy to entice and transport minors, even if specific acts involving this victim might be time-barred as substantive charges.
DOJ-OGR-00003109.jpg
This document is page 175 (labeled 148 internally) of a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. It argues legal points regarding perjury counts, specifically discussing materiality standards for false statements in civil depositions and citing case law (Kross, Gaudin, Kungys). The text argues that a jury can follow limiting instructions to separate the substance of Giuffre's allegations from the determination of whether the defendant committed perjury.
DOJ-OGR-00003104.jpg
This document is page 170 of a legal filing (Document 204) in the case USA v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The text presents a legal argument supporting the joinder of perjury charges with substantive offenses, citing the precedent of *United States v. Ruiz* regarding a NY State Senator who lied to conceal a financial scheme. The prosecution argues that, like in *Ruiz*, the current defendant's perjury was part of a common scheme to conceal her role in the charged sexual offenses.
DOJ-OGR-00003099.jpg
This document is page 165 of a legal filing (Document 204) from April 2021 in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The prosecution argues against the defendant's motion to sever Counts Five and Six, stating that the perjury charges and sex abuse charges are logically connected by a common scheme. The text cites Federal Rule of Criminal Procedure 8(a) and various case precedents to support the joinder of offenses.
DOJ-OGR-00003095.jpg
This page from a 2021 court filing (Case 1:20-cr-00330-PAE) presents arguments regarding the defendant's (Ghislaine Maxwell) perjury or false statements. It quotes a deposition where the defendant unequivocally denies ever giving anyone a massage, specifically denying giving massages to Mr. Epstein or '[Minor Victim-2].' The government argues that these answers were not ambiguous and that a jury could conclude the defendant lied.
DOJ-OGR-00003094.jpg
This legal document is a filing by the prosecution arguing against the defendant's motion to dismiss perjury charges. The prosecution contends that the defendant understood the plain meaning of questions asked during a July 2016 deposition regarding her relationship with Epstein and her knowledge of his activities, and that her answers were knowingly false. The document cites specific deposition questions and answers, including one about massages, as evidence that a jury should be allowed to determine the truthfulness of her statements.
DOJ-OGR-00003093.jpg
This document is a page from a court filing (Case 1:20-cr-00330-PAE, filed April 16, 2021) containing excerpts of a deposition. The defendant (implied to be Ghislaine Maxwell) testifies that she was unaware of Jeffrey Epstein having sexual activities with anyone other than herself, a 'blond,' and a 'brunette' during the 1990s and 2000s. The document includes legal analysis arguing that the defendant's statement '[w]hen I was with him' referred strictly to moments of sexual acts rather than the duration of their relationship.
DOJ-OGR-00003086.jpg
This document is page 152 of a legal filing (Document 204) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against dismissing a perjury count, stating that the defendant's denial of knowledge regarding Epstein's scheme to recruit underage girls for sexual massages was not due to fundamental ambiguity in the questioning. It includes a transcript excerpt from a deposition where Giuffre's counsel asks the defendant to list girls under 18 she brought to Epstein's house, to which Mr. Pagliuca objects.
DOJ-OGR-00003085.jpg
This legal document, filed on April 16, 2021, presents a transcript of testimony where an unnamed defendant is questioned about their knowledge of a scheme by Jeffrey Epstein to recruit underage girls for sexual massages. The defendant denies knowledge, a statement noted as a charged false statement, while their counsel, Mr. Pagliuca, objects. The document also references a related defamation case where a victim, Giuffre, alleged both Epstein and the defendant sexualized a massage, and notes the Government's intent to use this evidence at trial.
DOJ-OGR-00003077.jpg
This document is page 143 of a legal filing by the Government in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. The text argues against granting the defendant an evidentiary hearing regarding a 'Franks' analysis and asserts that the defendant failed to meet the burden of proof to obtain discovery or dismiss perjury counts. The Government contends that a jury should decide whether the defendant committed perjury during two depositions in a prior civil matter.
DOJ-OGR-00003069.jpg
This document is page 135 of a legal filing (Case 1:20-cr-00330-PAE, U.S. v. Ghislaine Maxwell) dated April 16, 2021. It argues that the current case is distinguishable from past precedents regarding prosecutorial misconduct and the misuse of false evidence. The text asserts that the defendant has not been deprived of a fair trial and notes that a jury will determine if her statements during April and July 2016 depositions were perjurious.
DOJ-OGR-00003063.jpg
This document page is from a legal filing in the case United States v. Ghislaine Maxwell (1:20-cr-00330). The text presents a legal argument distinguishing the current case from *United States v. Oshatz*, specifically regarding the enforceability of subpoenas for deposition transcripts and protective orders. It cites Chief Judge McMahon's finding that the Government demonstrated 'extraordinary circumstances' justifying the modification of a protective order, unlike in *Oshatz* where the government was characterzied as 'trolling for evidence'.
DOJ-OGR-00003013.jpg
This page is from a legal filing (Document 204) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues that the Defendant failed to prove the Indictment was delayed for an improper purpose. The text discusses the legal standards for pre-indictment delay, citing Supreme Court and Circuit precedents, and rejects the Defendant's request for a 'balancing test' regarding prejudice.
DOJ-OGR-00003010.jpg
This page from a court filing (Case 1:20-cr-00330-PAE) outlines the Government's argument that the defendant has failed to prove prejudice regarding the unavailability of Detective Recarey and various unnamed 'Epstein employees.' The text argues that fading memories and lost witnesses do not automatically justify dismissing the indictment. A footnote clarifies that Minor Victim-2 was interviewed by the FBI, but not by Detective Recarey.
DOJ-OGR-00003001.jpg
This document is page 67 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text contains legal arguments regarding the interpretation of 18 U.S.C. § 3283, specifically debating whether a 'categorical approach' or 'fact-based approach' applies to defining offenses involving sexual abuse. The prosecution argues that the defendant's interpretation would contradict Congress's intent to broadly prosecute crimes against children.
DOJ-OGR-00002990.jpg
This document is a page from a legal filing in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text argues against the defendant's claim that the prosecution is unfair due to the passage of time, citing the Retroactivity of Section 3283 and the 2003 Congressional amendment which extended the statute of limitations for child sexual abuse. It references legal precedents from the Eighth and Ninth Circuits to support the validity of prosecuting sex crimes decades after they occurred.
DOJ-OGR-00002980.jpg
This document is page 46 of a court filing (Document 204) from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on April 16, 2021. The text presents legal arguments refuting the defendant's claim that she has standing to enforce a Non-Prosecution Agreement (NPA) as a third-party beneficiary. It cites previous case law to argue that third-party standing principles from contract law do not necessarily apply to plea agreements.
DOJ-OGR-00002972.jpg
This document is page 38 of a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The government argues that the Non-Prosecution Agreement (NPA) signed by the USAO-SDFL with Jeffrey Epstein did not bind other districts. It cites the November 2020 DOJ Office of Professional Responsibility (OPR) report, noting that while USAO-SDFL prosecutor Maria Villafaña consulted with DOJ Child Exploitation Chief Andrew Oosterbaan, this does not support the defendant's claim of a wider immunity promise.
DOJ-OGR-00002971.jpg
This document is a page from a Government filing in the Ghislaine Maxwell case (1:20-cr-00330) arguing that the Southern District of New York (USAO-SDNY) was not involved in Jeffrey Epstein's Non-Prosecution Agreement (NPA). The Government asserts that communications between the Southern District of Florida (USAO-SDFL) and SDNY were solely regarding an old civil lawsuit from the 1990s, not plea negotiations. The text refutes defense claims involving 'Main Justice' and provides context on an AUSA who left the SDNY in April 2007.
| 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 |
Argument on the merits of Juror 50's motion to intervene
Previews argument regarding Juror 50's motion, claiming it is a discovery request.
Legal Defense
Review of discovery materials and legal consultation.
N/A
Hypothetical 'absence of phone calls' mentioned as a potential argument by the defense regarding missing phone records.
Sexual Topics
Defendant discussed sexual topics with girls to make them comfortable with sexual contact involving Epstein.
Legal Consultation
5 hours per weekday (25 hours/week) of attorney calls.
Legal Consultation
Calls placed from the day room phone.
Sentencing Arguments
Defendant's brief cited at page 12 regarding legislative history.
Questioning regarding guilt
Defendant was asked 'did you do that' and answered 'no', leading to perjury charges.
Motion for a New Trial
Referenced as 'The Defendant's Motion for a New Trial'
Identification
Announced themselves as federal agents.
Financial Assets
Defendant reported approximately $3.8 million in assets; Government claims this was less than candid.
Recruitment of minors
Q. Can you list for me all the girls that you have met and brought to Jeffrey Epstein’s house that were under the age of 18?
Request 2(c)
Request seeking documentation of dates on which Juror 50 opened and closed social media accounts.
No Subject
Defendant stated ''92, '93 was when I was there' regarding the residence.
Appointments
Called to set up appointments with Carolyn at Epstein's mansion.
Personal Life
Talked about family problems, traumatic personal experiences, and goals; compliemented her body.
Legal Defense
Communications regarding defense preparation and review of discovery
Response Letter (Dkt. No. 331)
Raised two issues: seeking identities of co-conspirators and disclosure of co-conspirator statements.
Mem. of Law (Dkt. No. 293)
Pretrial motions requesting identification of uncharged co-conspirators.
Legal consultation
Phone conversations observed visually but not audibly by MDC staff.
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.
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.
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