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-00002969.jpg
This document is page 35 of a court filing (Document 204) in the case against Ghislaine Maxwell (Case 1:20-cr-00330), filed on April 16, 2021. The text argues that Jeffrey Epstein's Non-Prosecution Agreement (NPA) was strictly limited to the Southern District of Florida (USAO-SDFL) and did not provide national immunity for co-conspirators. It contends that the defendant's interpretation—that Epstein secured broader immunity for co-conspirators than himself—is counterintuitive and unsupported by the text.
DOJ-OGR-00002968.jpg
This document is page 34 of a legal filing (Document 204) from the Ghislaine Maxwell case (1:20-cr-00330), filed on April 16, 2021. It discusses the legal interpretation of Jeffrey Epstein's Non-Prosecution Agreement (NPA), specifically rejecting the defendant's argument that the NPA binds the entire federal government rather than just the Southern District of Florida. The text quotes the specific NPA section granting immunity to potential co-conspirators, explicitly naming Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova.
DOJ-OGR-00002938.jpg
This document is a table of contents for a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It outlines legal arguments against various motions made by the defendant, including challenges to the indictment, requests for disclosure, and the propriety of using a grand jury in White Plains. The filing also addresses the defendant's claim that the grand jury unfairly represented Blacks or Hispanics.
DOJ-OGR-00004773.jpg
This document is a page from a court transcript dated June 15, 2021. In it, a judge questions the defendant, Ms. Days, to ensure she understands the terms of her plea agreement, specifically a clause waiving her right to appeal if her sentence is 78 months or less. The judge confirms that her attorney, Mr. Donaldson, explained this waiver to her before she signed the agreement.
DOJ-OGR-00004726.jpg
This document is page 19 of a legal filing (Case 1:20-cr-00330-PAE) filed on May 25, 2021, likely by the prosecution. It argues that the 'S2 Indictment' was filed timely and not delayed for strategic reasons, explaining that interviews with 'Minor Victim-4' were delayed until early 2021 due to COVID-19 travel constraints. The text refutes the defendant's motion to dismiss based on pre-indictment delay.
DOJ-OGR-00004724.jpg
This document is page 17 of a Government filing (Document 295) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on May 25, 2021. The text argues that the Defendant's motion to dismiss the S2 Indictment based on improper pre-trial delay should be denied, citing that the Court has already rejected similar arguments and that the defendant failed to prove actual prejudice or intentional delay by the Government. It references case law standards for due process violations regarding pre-indictment delays.
DOJ-OGR-00004721.jpg
This document is page 14 of a legal filing from May 25, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It argues that Epstein's Non-Prosecution Agreement (NPA) with the USAO-SDFL does not protect the current defendant under the Double Jeopardy Clause because the NPA was merely an agreement between parties, not a judicial adjudication of facts. The text cites *United States v. Cambindo Valencia* to distinguish how plea agreements affecting third parties (like Jesus and Rosalinda Losada) operate legally.
DOJ-OGR-00004714.jpg
This page is from a government legal filing (Document 295) in the case of USA v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on May 25, 2021. The text argues against the defendant's motion to dismiss charges based on a prior Non-Prosecution Agreement (NPA) with the Southern District of Florida (USAO-SDFL). Citing the *Annabi* precedent, the government asserts that plea agreements are generally only binding in the specific district where they are signed, not universally across all federal districts.
DOJ-OGR-00004709.jpg
This document is the table of contents for a legal filing (Document 295) in case 1:20-cr-00330-PAE, filed on May 25, 2021. It outlines the arguments to be made in the filing, which address several motions from the defendant, including arguments related to Jeffrey Epstein's non-prosecution agreement, double jeopardy, pre-trial delay, and the disclosure of statements from 'Minor Victim-4'.
DOJ-OGR-00014699.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely USA v. Ghislaine Maxwell) filed on August 10, 2022. Attorneys Mr. Everdell and Ms. Moe argue before the judge regarding a question posed by the jury about 'Count Four,' specifically whether a return flight from New Mexico involving a victim named 'Jane' constitutes aiding in illegal sexual activity if the initial flight to New Mexico did not. The defense argues the return flight cannot be the sole basis for conviction, while the prosecution argues intent can be inferred.
DOJ-OGR-00014695.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, U.S. v. Ghislaine Maxwell) filed on August 10, 2022. It details a discussion between the Court and counsel regarding jury deliberation schedules, followed by the Judge reading a specific note from the jury. The note asks for legal clarification on 'Count Four,' specifically questioning if the defendant can be found guilty if she aided in 'Jane's return flight' but not the initial flight to New Mexico where sexual activity was intended to occur.
DOJ-OGR-00014628.jpg
This legal document is a jury charge from case 1:20-cr-00330-PAE, filed on August 10, 2022. It instructs the jury on the concept of "conscious avoidance" or "willful blindness," explaining that if a defendant deliberately avoids confirming a high probability of criminal activity, this avoidance can be legally considered the equivalent of actual knowledge. This instruction is provided to guide the jury's deliberations, particularly concerning conspiracy counts against the defendant.
DOJ-OGR-00014616.jpg
This document is page 216 of a court transcript (Document 767) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It contains the judge's charge to the jury regarding 'Count Three,' specifically outlining the requirements to prove a conspiracy to transport minors for illegal sexual activity between 1994 and 2004. The text explains that the jury must find beyond a reasonable doubt that the defendant agreed with another person to commit these acts.
DOJ-OGR-00014613.jpg
This document is page 213 of 257 from the court transcript (Document 767) filed on August 10, 2022, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It contains Jury Instruction No. 33 regarding Counts One, Three, and Five, specifically defining the legal elements of 'Conspiracy to violate federal law.' The text explains that a conspiracy requires an agreement between two or more persons to commit an unlawful act and at least one overt act, regardless of the conspiracy's ultimate success.
DOJ-OGR-00014584.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, USA v. Maxwell) filed on August 10, 2022. It captures the final sentences of prosecutor Ms. Comey's closing argument, urging the jury to find the defendant guilty of sexual abuse of underage girls. Following this, the Court (Judge Nathan) begins reading the jury instructions (The Charge), specifically starting with Instruction No. 1 regarding the Role of the Court.
DOJ-OGR-00014577.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring a rebuttal argument by prosecutor Ms. Comey. Comey refutes the defense's suggestion (attributed to Ms. Menninger) that the FBI manipulated witnesses or asked leading questions, citing the ethical testimony of Special Agent Young. She argues that the victims (Jane, Kate, Carolyn, and Annie) did not misremember the defendant's role in their abuse and that the defense's argument relies on the jury believing all witnesses are liars.
DOJ-OGR-00014566.jpg
This document is a page from the rebuttal argument by prosecutor Ms. Comey during the trial of Ghislaine Maxwell (implied by case number). Comey argues that the testimony of four key witnesses (Jane, Kate, Carolyn, and Annie) is sufficient for a guilty verdict and refutes defense attorney Ms. Menninger's claims regarding age limits at the Epstein Victim Compensation Fund. Comey also details witness testimony corroborating that the victim 'Annie' was 16, not 17, during a trip to Santa Fe.
DOJ-OGR-00005864.jpg
This page from a legal filing (Document 397 in Case 1:20-cr-00330-PAE, the Ghislaine Maxwell trial) outlines the Government's argument for admitting evidence of rape. The prosecution rebuts defense claims that such evidence is irrelevant or overly inflammatory (Rule 403), asserting that the victims' testimony is necessary to explain the complex, multi-year relationships between the defendant, Epstein, and the victims. The text clarifies that the Indictment charges conspiracies for 'sexual activity' and 'commercial sex acts,' not merely 'sexualized massages' as the defense suggested.
DOJ-OGR-00005860.jpg
This legal document is a court filing arguing against several defense motions. The prosecution contends that evidence of the defendant's lifestyle and close partnership with Jeffrey Epstein is relevant to the conspiracy charge and not prejudicial. The filing also argues that trial participants should not be precluded from using the terms "Victims" or "rape" when referring to the Minor Victims and acts committed by Epstein.
DOJ-OGR-00005854.jpg
This document is page 71 of a court filing (Document 397) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on October 29, 2021. It is a legal argument by the prosecution opposing a defense motion to suppress an identification made by Minor Victim-4. The text argues that the victim's identification is reliable because she had multiple personal interactions with the defendant between 2001 and 2004, and concludes by asking the court to deny the defense's motion.
DOJ-OGR-00005805.jpg
This document is page 22 of a legal filing (Case 1:20-cr-00330-PAE) dated October 29, 2021, likely from the prosecution in the Ghislaine Maxwell trial. It argues for the admissibility of expert testimony by Dr. Rocchio regarding 'coercion and attachment in abusive relationships' and 'grooming,' refuting defense arguments based on Rule 403 and the 'Burns' case precedent. The text asserts that such testimony aids the jury in understanding psychological factors without being prejudicial.
DOJ-OGR-00005800.jpg
This document is page 17 of a legal filing (Document 397) from October 29, 2021, in the case US v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The Government is arguing against the defendant's motion to exclude the testimony of expert witness Dr. Rocchio, a clinical psychologist. The text asserts that Dr. Rocchio's qualitative methodology is reliable based on her clinical experience, rather than statistical error rates, which the Government argues are inapplicable to this type of social science testimony under Daubert standards.
DOJ-OGR-00005793.jpg
This legal filing (Document 397 in Case 1:20-cr-00330-PAE) argues for the admissibility of expert testimony regarding sex trafficking, coercive control, and the psychological relationship between pimps and victims. It cites several precedents (Kelly, Torres, Randall, Dupigny) where such testimony was permitted. Specifically, it defends the qualifications of Dr. Rocchio, a Brown University professor with 25 years of clinical experience, noting that the defendant does not contest her expertise.
DOJ-OGR-00005788.jpg
This document is Page 5 of a legal filing (Document 397) from Case 1:20-cr-00330-PAE (USA v. Ghislaine Maxwell), filed on October 29, 2021. The text presents the Government's argument to admit the testimony of Dr. Lisa Rocchio, an expert in trauma psychology. It outlines her credentials and details her expected testimony regarding the grooming process, manipulation tactics used by abusers, and why victims often delay disclosure or fail to recognize abuse while it is occurring.
DOJ-OGR-00005787.jpg
This document is a Preliminary Statement from a Government memorandum filed on October 29, 2021, in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues against thirteen motions in limine filed by the defense, asserting the admissibility of expert testimony, evidence regarding Minor Victim-3 and Minor Victim-4, co-conspirator statements, and the use of the terms 'victim' and 'rape' during trial. The Government also notes it will not introduce evidence of the defendant's flight or false statements in its case-in-chief unless the defense opens the door.
| 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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