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-00002752.jpg
This legal document is a court filing arguing against a defendant's proposed bail package. The prosecution contends that the defendant's offer to renounce her foreign citizenships (French and British) does not sufficiently mitigate the risk of her fleeing the country. The document argues the renunciation's validity is unclear and could be challenged later, and it cites a previous case (United States v. Cohen) where similar offers were deemed insufficient to assure the court that the defendant was not a flight risk.
DOJ-OGR-00002745.jpg
This document is the second page of a legal letter filed on March 1, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). Attorney Christian R. Everdell of Cohen & Gresser LLP requests Judge Alison J. Nathan extend the deadline for the defendant's reply to March 15, 2021. The document also notes that the trial is scheduled to begin on July 12, 2021.
DOJ-OGR-00005253.jpg
This document is page 4 of a filing by the Government in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell). The Government argues against attorney-led jury selection, supporting Court-led 'voir dire' instead. Additionally, the Government argues that individual sequestered voir dire is not warranted for all questions, suggesting that sensitive topics like sexual abuse and pretrial publicity can be handled at the sidebar rather than in a fully sequestered setting.
DOJ-OGR-00005244.jpg
This legal document, filed by the Government, responds to a request from defense counsel for expedited delivery of legal mail to a defendant held at the MDC. The Government argues against the request, citing the burden on the MDC's legal department, and details a timeline of events where a hard drive delivery was delayed by one day due to an 'institutional emergency' at the facility on October 13, 2021.
DOJ-OGR-00002898.jpg
This document is Page 9 of a legal filing (Document 195) from April 5, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text argues that any records obtained via Rule 17(c) subpoenas must be marked confidential under a protective order and shared with the opposing party, citing that the rule does not allow for secretive evidence gathering. It references the reciprocal discovery obligations of Rule 16 and cites the precedent of United States v. St. Lawrence.
DOJ-OGR-00002780.jpg
This is the second page of a legal filing by the US Attorney's Office in Case 1:20-cr-00330 (United States v. Ghislaine Maxwell), dated March 22, 2021. The Government argues against, but ultimately agrees to comply with, defense requests to redact specific information related to Count Six of the Indictment on pages 129-134, noting the information is already public. The document is signed by US Attorney Audrey Strauss and Assistant US Attorneys Comey, Moe, Pomerantz, and Rohrbach.
DOJ-OGR-00002774.jpg
This legal document is a court's opinion denying a defendant's third motion for bail. The court determines that the defendant remains a significant flight risk, and her new proposals—renouncing her French and British citizenship and placing assets under a monitor—are insufficient to ensure her future appearance. The court highlights the uncertainty and conflicting legal opinions surrounding the practical effect of renouncing French citizenship for a wanted individual.
DOJ-OGR-00020145.jpg
This legal document is a court filing that analyzes a defendant's proposed bail package. The Court concludes that the package, including a partially secured bond and various release conditions like home confinement, does not sufficiently mitigate the risk of flight. The Court reasons that the defendant's vast unrestrained wealth would plausibly allow her to flee and compensate third parties who supported her bond, and her arguments about illiquid assets are unpersuasive.
DOJ-OGR-00020141.jpg
This legal document is a court's analysis regarding a defendant's ties to the United States, likely in the context of a bail hearing. The court acknowledges letters of support from the defendant's friends, family, and spouse, which aim to prove her strong connections to the country. However, the court remains unconvinced that she is not a flight risk, highlighting a key contradiction: the defendant now emphasizes her spousal relationship as a significant tie, yet at the time of her arrest, she claimed to be getting divorced from him.
DOJ-OGR-00020136.jpg
This legal document is a court's analysis regarding a defendant's renewed motion for bail. The defendant argues the government's case is weak, lacking documentary evidence and relying almost entirely on the testimony of three unidentified accusers. The court, however, disagrees with the defendant's assessment and reaffirms its previous decision to deny bail, finding no conditions can reasonably assure the defendant's appearance at future proceedings.
DOJ-OGR-00008780.jpg
This document is Page 74 of 83 from a court filing (Document 565) in Case 1:20-cr-00330-PAE, dated December 19, 2021. It contains Jury Instruction No. 54, titled 'Persons Not on Trial,' which explicitly instructs jurors not to speculate or draw inferences regarding why other individuals are not currently on trial alongside the defendant.
DOJ-OGR-00008778.jpg
This document is page 72 of 83 from a court filing (Document 565) dated December 19, 2021, associated with Case 1:20-cr-00330-PAE (the Ghislaine Maxwell trial). It contains Jury Instruction No. 52, titled 'Use of Evidence from Searches,' where the judge instructs the jury that evidence seized by law enforcement was properly admitted and lawful. The jury is directed to disregard any personal opinions regarding the search methods and to give the evidence full consideration in determining the Defendant's guilt.
DOJ-OGR-00008748.jpg
This legal document is a jury instruction (Instruction No. 32) from case 1:20-cr-00330-PAE, filed on December 19, 2021. It details the four elements the government must prove beyond a reasonable doubt to convict a defendant of conspiracy to violate federal law, as charged in Counts One, Three, and Five of an indictment.
DOJ-OGR-00008733.jpg
This document is page 27 (numbered 26 internally) of jury instructions filed on December 19, 2021, in the case USA v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It outlines the three legal elements required to prove 'Count Four: Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity.' The instruction specifies that this count relates solely to a victim identified as 'Jane' during the time period of 1994 to 1997.
DOJ-OGR-00008694.jpg
This document is a jury instruction, designated as Instruction No. 54, from a legal case (1:20-cr-00330-PAE) filed on December 18, 2021. It explicitly directs the jury not to draw any inferences or speculate about why individuals other than the defendant are not also on trial. The instruction clarifies that such considerations are irrelevant to the jury's duty of deciding the case based on the evidence presented.
DOJ-OGR-00008665.jpg
This document represents page 127 (labeled 44 internally) of a court filing in the case against Ghislaine Maxwell. It outlines Instruction No. 34 regarding the objects of the conspiracy for Counts One, Three, and Five. Count One alleges conspiracy to entice minors (1994-2004), Count Three alleges conspiracy to transport minors (1994-2004), and Count Five begins to describe conspiracy to commit sex trafficking (2001-2004).
DOJ-OGR-00005841.jpg
This document is page 58 of a legal filing (Document 397) from the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on October 29, 2021. It details a legal dispute regarding discovery, specifically the defendant's repeated requests for the Government to identify uncharged co-conspirators and their statements. The text outlines a history of motions (Dkt. Nos. 293, 297, 317, 320, 331) where the defense sought this information and the Government's opposition to identifying specific co-conspirator statements within their production.
DOJ-OGR-00005832.jpg
This document is page 49 of a court filing (Case 1:20-cr-00330-PAE) filed on October 29, 2021. It argues for the admissibility of 'Minor Victim-3's' testimony, stating it is necessary to counter expected defenses that the defendant (Ghislaine Maxwell) played no role in procuring girls for Jeffrey Epstein. Footnote 11 provides extensive legal analysis distinguishing this case from precedents (Cummings, Townsend, Mahaffy, Nektalov) regarding 'other crimes' evidence and Rule 404(b), arguing that the abuse of Minor Victim-3 is direct proof of the conspiracy rather than a distinct, unrelated crime.
DOJ-OGR-00020354.jpg
This is page 2 of a court filing by the US Attorney's Office (SDNY) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The document addresses the Court's inquiries regarding the defendant's housing conditions at the MDC. It explains that she is housed alone due to safety concerns ('high-profile case', 'nature of charges') and her own expressed fears of the general population. It also states that the MDC cannot provide her with an eye mask because they are considered contraband, though she may use other non-contraband items to cover her eyes.
DOJ-OGR-00011710.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) recording a sidebar conference during the opening statements of the Ghislaine Maxwell trial. Prosecutor Ms. Comey objects that the defense is improperly arguing the government is targeting the defendant, violating a pretrial ruling. The Court rules that while the defense cannot attack the prosecution's motives, they are permitted to argue that witnesses are using the defendant as a scapegoat or stand-in.
DOJ-OGR-00011704.jpg
This document is a transcript of an opening statement by Ms. Pomerantz in a criminal case (1:20-cr-00330-PAE). The prosecution outlines its case against an unnamed defendant, alleging their involvement with Jeffrey Epstein in the abuse of underage victims. The statement details the evidence to be presented, including testimony from victims' relatives, Epstein's pilots and staff, and law enforcement who searched Epstein's Palm Beach and New York residences, to establish the defendant's role and efforts to create a 'culture of silence'.
DOJ-OGR-00011700.jpg
This document is a page from a prosecutor's (Ms. Pomerantz) opening statement in a criminal trial, filed on August 10, 2022. The prosecutor alleges that the defendant conspired with Jeffrey Epstein to recruit and facilitate the sexual abuse of multiple underage girls. Specific examples cited include the abuse of a girl named 'Jane' in New York and Florida, and the grooming and abuse of a 16-year-old girl at Epstein's ranch in New Mexico.
DOJ-OGR-00011699.jpg
This document is page 34 of a court transcript (Case 1:20-cr-00330-PAE) containing the opening statement by Ms. Pomerantz. It details the grooming and sexual abuse of a minor referred to as 'Jane' (aged 14-16) by Jeffrey Epstein and the defendant (Ghislaine Maxwell). The text describes how they befriended the child, provided financial incentives, and committed sexual acts at Epstein's Palm Beach home, often with the defendant present in the room to normalize the abuse.
DOJ-OGR-00011698.jpg
This document is a transcript of an opening statement by Ms. Pomerantz in a criminal case, filed on August 10, 2022. Pomerantz alleges that an unnamed female defendant knowingly assisted Epstein in luring young girls by providing a 'cover of respectability.' The statement introduces the case of 'Jane,' who was 14 when she met the pair in 1994 and was subsequently invited to Epstein's Palm Beach home under the false pretense of mentorship and scholarships.
DOJ-OGR-00011697.jpg
This document is a page from a court transcript of an opening statement by Ms. Pomerantz, filed on August 10, 2022. She outlines the prosecution's case, detailing a decade-long sexual abuse scheme where Epstein assaulted teenage girls, and alleges that an unnamed female defendant was an essential accomplice who recruited, groomed, and facilitated the abuse.
| 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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