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-00008487.jpg
This document is page 31 of 82 from a court filing (Document 562) in Case 1:20-cr-00330-PAE, filed on December 17, 2021. It contains Jury Instruction No. 23 regarding Counts Two and Four, clarifying that for the charges of enticement and transportation, the Government need only prove the Defendant had the requisite intent, and it is immaterial whether the intended sexual activity actually occurred.
DOJ-OGR-00008470.jpg
This document is page 14 of a court filing (Document 562) from Case 1:20-cr-00330-PAE, filed on December 17, 2021. It contains 'Instruction No. 8: Reasonable Doubt,' providing legal definitions and instructions to the jury regarding the burden of proof required to convict or acquit the defendant, explicitly named as Ms. Maxwell (Ghislaine Maxwell). The text outlines the standard of 'reasonable doubt' versus 'possible doubt' and instructs jurors on their duty based on their abiding belief of her guilt.
DOJ-OGR-00008378.jpg
This document is a legal filing (page 5 of 9) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated December 15, 2021. It argues against the defense's attempt to call attorney Scarola to the stand to testify about his client Carolyn's cooperation with the government and the Epstein Victims' Compensation Program (EVCP), citing attorney-client privilege and Federal Rule of Evidence 403 (prejudice/confusion). The text asserts that Carolyn was unaware of when the EVCP began accepting claims when she decided to cooperate, negating the defense's theory of financial bias.
DOJ-OGR-00008376.jpg
This document is page 3 of a court filing (Document 545) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 15, 2021. The text argues against the defendant's motion to call three attorneys for victims (Jack Scarola, Brad Edwards, and Robert Glassman) as witnesses, stating such testimony would be irrelevant, duplicative, or improper impeachment. Specifically regarding Jack Scarola, the document notes he represented victim 'Carolyn' in a 2008 lawsuit and before the Epstein Victims Compensation Program, facts which Carolyn already admitted during cross-examination.
DOJ-OGR-00008375.jpg
This document is page 2 of a legal filing (Document 545) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 15, 2021. The text argues against a motion by the defendant to compel victims' attorneys to testify, citing Federal Rules of Evidence 402 and 403 and the sanctity of the attorney-client privilege. The argument emphasizes that forcing counsel to testify against their clients, particularly victims of sexual abuse, is legally disfavored and damaging to the attorney-client relationship.
DOJ-OGR-00008339.jpg
This document is a court transcript from December 10, 2021, detailing a discussion between an attorney, Mr. Rohrbach, and the judge. They are clarifying a point of law regarding the testimony of 'witness 3' about sexual conduct with Mr. Epstein. The core of the conversation is whether the defendant can be convicted 'solely' on this testimony or if it must be considered in combination with other evidence.
DOJ-OGR-00008241.jpg
This page from a court filing (Case 1:20-cr-00330-PAE, likely the Ghislaine Maxwell trial) argues that attorney-client privilege protects communications between a witness named 'Jane' and her attorney 'Glassman.' It asserts that Glassman could not waive this privilege as it belongs to Jane, and distinguishes the situation from the 'Bergonzi' case precedent regarding documents prepared for the Government.
DOJ-OGR-00001910.jpg
This document is page 33 of a court transcript from Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on December 10, 2020. The discussion between the Court and prosecutor Ms. Moe concerns the details of the defendant's arrest, specifically confirming that the defendant ignored law enforcement commands to open the door and retreated to a separate room. The Court also notes an allegation that the defendant attempted to block location monitoring by wrapping a cell phone in foil.
DOJ-OGR-00001888.jpg
This document is page 11 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. In this excerpt, the Defendant (Maxwell) waives the public reading of the indictment and formally enters a plea of 'Not guilty.' The Court then transitions to a scheduling conference and asks prosecutor Ms. Moe for a status update regarding the discovery process.
DOJ-OGR-00001820.jpg
This is page 3 of a legal filing (Case 1:20-cr-00330-AJN, likely US v. Ghislaine Maxwell) dated November 6, 2020. The Government argues against the immediate production of witness lists (Giglio/Jencks material), stating it is premature seven months before trial. The document details an upcoming 'sixth discovery production' due November 9, 2020, which includes thousands of images/videos from Jeffrey Epstein's electronic devices, portions of his iPads and iPhone, and FBI Florida files.
DOJ-OGR-00001815.jpg
This document is the final page of a Government filing (dated Oct 30, 2020) regarding the detention conditions and discovery process for the defendant (Ghislaine Maxwell) at the Metropolitan Detention Center (MDC). The Government argues against the need for a court order regarding MDC issues, citing that protocols are already in place for passing papers, COVID-19 safety (Plexiglas barriers), and laptop viewing. The filing asserts that the defendant has access to discovery materials for approximately 13 hours a day—more than any other inmate—and details technical efforts to resolve file viewing issues mentioned in a footnote.
DOJ-OGR-00001813.jpg
This document is Page 2 of a Government filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on October 30, 2020. It addresses delays in electronic discovery production due to vendor volume and refutes defense accusations regarding the definition of the 'Prosecution Team' and the withholding of exculpatory material. A significant footnote (Footnote 2) argues that the 'genesis' of Jeffrey Epstein's Non-Prosecution Agreement with the Southern District of Florida is irrelevant because the current defendant (Maxwell) was not a party to it, was not named in it, and the agreement covered a different time period.
DOJ-OGR-00001786.jpg
This document is page 3 of a legal filing submitted on October 7, 2020, by the Acting US Attorney Audrey Strauss and Assistant US Attorneys (Comey, Moe, Pomerantz) in the Southern District of New York (Case 1:20-cr-00330-AJN). The Government argues against the premature disclosure of witness identities and sensitive materials to the defense, citing risks to the ongoing investigation and the potential to deter other victims from coming forward. They request the Court to approve a delay in disclosing these materials pursuant to Rule 16(d).
DOJ-OGR-00001749.jpg
This document is page 3 of a court order filed on September 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The Court denies the Defendant's request to modify a protective order to disclose documents to judicial officers in other civil cases, citing a lack of good cause and noting that the relevant facts are already public. The text reveals that the Government previously issued grand jury subpoenas to an entity referred to as 'Recipient' regarding an investigation into Jeffrey Epstein and his co-conspirators.
DOJ-OGR-00001722.jpg
This document is page 4 of a Government filing (Document 41) in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330), dated August 13, 2020. The Government argues against disclosing witness identities prematurely before the July 2021 trial to protect victim privacy. Additionally, the Government rejects the defendant's complaints regarding her confinement conditions at the MDC, asserting that monitoring protocols are appropriate for safety and security, and clarifying that attorney-client calls are visually observed but not audited.
DOJ-OGR-00001694.jpg
This document is Page 5 of a Protective Order filed on July 30, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It outlines strict protocols prohibiting the Defense team and potential witnesses from publicly disclosing the identities of victims or witnesses found in discovery materials, mandating that such references in court filings be made under seal.
DOJ-OGR-00001693.jpg
This document is page 4 of a court-filed Protective Order from case 1:20-cr-00330-AJN, dated July 30, 2020. It establishes strict rules for handling sensitive 'Discovery' materials, requiring Defense Counsel to encrypt information shared through non-email channels. The order explicitly prohibits all parties, including the Government, the Defendant, and their entire legal teams, from posting any Discovery information on the Internet or social media.
DOJ-OGR-00001684.jpg
This legal document, filed on July 28, 2020, is the second page of a declaration by Assistant U.S. Attorney Alex Rossmiller. It outlines a disagreement between the U.S. Government and the defense regarding proposed restrictions on the public identification of victims and witnesses in the case. The document specifies the conflicting paragraphs in the proposed orders from both sides and references an accompanying letter for the Government's full reasoning.
DOJ-OGR-00001675.jpg
This document is page 5 of a court order (Document 33-1) from case 1:20-cr-00330-AJN, filed on July 28, 2020. The order restricts the defense team and other authorized persons from publicly disclosing or filing the identities of victims and witnesses found in discovery materials. Such information must be filed under seal unless specific written authorization is granted by the Government or the Court.
DOJ-OGR-00001674.jpg
This document is page 4 of a court-filed Protective Order from July 28, 2020, in a criminal case. It outlines the rules for handling discovery materials, stating that all members of the defense team are bound by the order even without individual signatures. The order mandates that Defense Counsel must encrypt discovery shared through non-electronic means and strictly prohibits all parties from posting any discovery information on the internet or social media.
DOJ-OGR-00001656.jpg
This document is page 10 of a court filing in case 1:20-cr-00330-AJN, filed on July 27, 2020. It defines 'Highly Confidential Information' as potentially including nude or sexualized images and establishes strict rules for its use by the Defense Counsel, limiting it solely to the defense of the current criminal action. The document also provides a legal mechanism for the Defense Counsel to challenge the Government's 'Highly Confidential' designation of materials before the Court.
DOJ-OGR-00001651.jpg
This document is a page from a Protective Order in criminal case 1:20-cr-00330-AJN, filed on July 27, 2020. It establishes strict rules for handling 'Discovery' materials, limiting their use by both government and defense witnesses and counsel solely for preparation for the criminal trial. The order explicitly prohibits using the information for civil proceedings and forbids any party, including the Defendant and defense team, from posting the Discovery or its contents on the Internet.
DOJ-OGR-00001627.jpg
This document is page 17 of a court filing (Document 22) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 13, 2020. The text argues against granting bail, citing an 'extraordinary risk of flight' and rejecting the defendant's claim that detention at the MDC prevents adequate preparation for defense. The filing cites numerous precedents (Tolentino, Adamu, Brito, etc.) where bail was denied despite access-to-counsel restrictions, distinguishing the current case from *United States v. Stephens*.
DOJ-OGR-00001622.jpg
This legal document, filed on July 13, 2020, argues that a defendant is a flight risk due to significant undisclosed financial assets. It details her access to millions of dollars in foreign bank accounts in Switzerland and England, including a trust account with over $4 million, and highlights several large transactions. The document also notes her recent arrest at a New Hampshire property purchased for over $1 million in cash, suggesting she has not been forthcoming about her wealth and has the means to flee.
DOJ-OGR-00001621.jpg
This legal document is a filing by the Government arguing against granting bail to a defendant. The Government contends the defendant is a significant flight risk because she has access to millions of dollars, possesses a multi-million dollar property in the United Kingdom, and is a citizen of a country that does not extradite to the United States. The proposed bail package, secured by foreign property, is deemed meaningless as the U.S. Government cannot easily seize foreign assets.
| 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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