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-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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
| 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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