GOVERNMENT
OrganizationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
MAXWELL
|
Legal representative |
15
Very Strong
|
29 | |
|
organization
Defense
|
Legal representative |
13
Very Strong
|
21 | |
|
person
defendant
|
Legal representative |
13
Very Strong
|
62 | |
|
person
Defense counsel
|
Legal representative |
12
Very Strong
|
14 | |
|
person
GHISLAINE MAXWELL
|
Legal representative |
12
Very Strong
|
14 | |
|
person
Ms. Maxwell
|
Legal representative |
11
Very Strong
|
55 | |
|
person
Recipient
|
Legal representative |
11
Very Strong
|
5 | |
|
organization
Defense
|
Adversarial |
11
Very Strong
|
10 | |
|
person
MAXWELL
|
Adversarial |
10
Very Strong
|
14 | |
|
person
the defendant
|
Legal representative |
10
Very Strong
|
6 | |
|
person
THOMAS
|
Legal representative |
10
Very Strong
|
9 | |
|
person
Defense counsel
|
Professional |
10
Very Strong
|
6 | |
|
person
Ms. Maxwell
|
Adversarial |
10
Very Strong
|
21 | |
|
person
the defendant
|
Adversarial |
10
Very Strong
|
7 | |
|
person
defendant
|
Adversarial |
10
Very Strong
|
24 | |
|
location
court
|
Legal representative |
10
Very Strong
|
5 | |
|
person
Ms. Comey
|
Professional |
9
Strong
|
4 | |
|
person
MR. ROHRBACH
|
Professional |
8
Strong
|
4 | |
|
organization
Defense
|
Professional |
8
Strong
|
3 | |
|
person
MR. EPSTEIN
|
Legal representative |
7
|
2 | |
|
person
Thomas
|
Legal representative |
7
|
3 | |
|
person
Dr. Rocchio
|
Professional |
7
|
2 | |
|
person
Minor Victims
|
Protective |
7
|
2 | |
|
person
Epstein's counsel
|
Professional |
7
|
2 | |
|
person
Ms. Moe
|
Professional |
7
|
3 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Maxwell's motion to compel discovery from the Government, including Jencks Act, Brady, Giglio mat... | Court proceedings | View |
| N/A | N/A | Court's ruling on Maxwell's discovery requests, concluding she is not entitled to expedited disco... | Court proceedings | View |
| N/A | N/A | Court accepts Government's representations that it has disclosed all Brady and Giglio Material. | Court proceedings | View |
| N/A | N/A | Accusation by the government that Epstein paid Maxwell millions for recruiting young, underage wo... | N/A | View |
| N/A | N/A | Government's intention to produce 'Materials' to the defendant (Maxwell) under a protective order... | N/A | View |
| N/A | N/A | Argument that defendants should be able to rely on government promises in written agreements and ... | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss Mann Act counts for lack of specificity or to compel Government to s... | N/A | View |
| N/A | N/A | Broader investigation into Epstein's sexual abuse of minors, covering periods beyond the Indictment. | N/A | View |
| N/A | N/A | Government's review of 'Materials' (documents and photographs) related to Epstein's sexual abuse ... | N/A | View |
| N/A | N/A | Maxwell's attempt to dismiss indictment due to alleged actual prejudice from Government's delay i... | N/A | View |
| N/A | N/A | Ex parte proceeding where government allegedly misled Chief Judge McMahon to obtain a subpoena. | Court | View |
| N/A | N/A | Client's arrest and detention despite voluntary surrender. | N/A | View |
| N/A | N/A | Discussion of discovery timeline, with the government requesting until November. | Court | View |
| N/A | N/A | Government initiated a massive OPR investigation into the execution of the NPA. | N/A | View |
| N/A | N/A | Court agrees that some of Maxwell's concerns are overstated but acknowledges defamation action re... | N/A | View |
| N/A | N/A | NPA (Non-Prosecution Agreement) not disclosed to victims | N/A | View |
| N/A | N/A | Search warrants executed at properties of Jeffrey Epstein. | New York and Virgin Islands | View |
| N/A | N/A | Lefkowitz argued that the government was not required to notify victims under the § 2255 provisio... | N/A | View |
| N/A | N/A | Depositions taken as a result of government-supported civil suits against the speaker. | N/A | View |
| N/A | N/A | Indictment of Thomas | S.D.N.Y. | View |
| N/A | N/A | Opening of Grand Jury Investigation | Unknown | View |
| N/A | N/A | Sentencing hearing regarding fines, restitution, and guideline calculations. | Courtroom | View |
| N/A | N/A | Planned resolution of pending redaction issues | N/A | View |
| N/A | N/A | Victims' lawsuit against the government | Court | View |
| N/A | N/A | Ex parte modification of the protective order by Judge McMahon. | Court | View |
DOJ-OGR-00008756.jpg
This document is a page from the jury instructions in the trial of United States v. Ghislaine Maxwell, filed on December 19, 2021. It outlines 'Instruction No. 36' regarding the 'overt act' requirement for conspiracy charges. The text explicitly lists alleged overt acts involving Maxwell and Epstein, including group sexual encounters with a minor ('Jane'), enticing a minor to travel for sexual abuse, and an unsolicited massage given by Maxwell to 'Annie' in New Mexico.
DOJ-OGR-00008754.jpg
This document is a page from a court filing, likely jury instructions, from a criminal case against Ms. Maxwell. It outlines the legal standards for proving her involvement in a conspiracy, stating that the Government must establish her knowing participation but does not need to prove she knew all details, knew all other members, or was involved from the beginning. The text clarifies that even a limited role or a single act could be sufficient for a guilty verdict if she was aware of the conspiracy's criminal aims.
DOJ-OGR-00008753.jpg
This document is a jury instruction (No. 35) from a federal criminal case (1:20-cr-00330-PAE), filed on December 19, 2021. It explains the second element of a conspiracy charge, requiring the Government to prove beyond a reasonable doubt that the defendant, Ms. Maxwell, knowingly and willfully joined the conspiracy. The instruction defines these terms as deliberate and purposeful actions, distinguishing them from mistake, negligence, or carelessness, and notes that knowledge must be inferred from evidence.
DOJ-OGR-00008742.jpg
This document is page 36 of 83 from a court filing (Document 565) in the case against Ghislaine Maxwell, filed on December 19, 2021. It contains Jury Instruction No. 28 regarding Count Six: Sex Trafficking of an Individual Under the Age of 18. The text defines the 'Third Element' of the charge, specifying that consent is not a defense if the victim 'Carolyn' was underage, and defining what constitutes a 'commercial sex act.'
DOJ-OGR-00008741.jpg
This document is Instruction No. 27 from a legal case, filed on December 19, 2021, pertaining to Count Six: Sex Trafficking of an Individual Under the Age of 18. It specifies that the Government must prove Ms. Maxwell knew Carolyn was under eighteen years of age, and directs the application of a previously provided definition of 'knowingly' in this determination. The document is part of a larger court filing, page 35 of 83.
DOJ-OGR-00008736.jpg
This document is a jury instruction (No. 22) from a legal case (1:20-cr-00330-PAE), filed on December 19, 2021. It specifies the third element the Government must prove for Count Four of an indictment: that the defendant, Ms. Maxwell, knew the individual referred to as 'Jane' was under seventeen years old at the time of the alleged criminal acts.
DOJ-OGR-00008734.jpg
This legal document, filed on December 19, 2021, is a jury instruction for 'Count Four' in the criminal case against Ms. Maxwell. It outlines the first element the Government must prove: that Ms. Maxwell knowingly transported an individual named Jane across state lines for illegal sexual activity. The instruction clarifies that direct personal transportation is not required; arranging the travel, such as by purchasing tickets, is sufficient, and the defendant's intent is a key factor.
DOJ-OGR-00008728.jpg
This document is page 22 of 83 from a court filing (Document 565) dated December 19, 2021, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It contains Jury Instruction No. 15 regarding 'Count Two: Enticement to Engage in Illegal Sexual Activity,' specifically defining the 'First Element' and the legal definition of acting 'Knowingly.' It outlines the burden of proof on the government to establish that Maxwell persuaded or coerced individuals to travel in interstate commerce.
DOJ-OGR-00008727.jpg
This document is page 21 of a court filing (Document 565) from case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on December 19, 2021. It details Jury Instruction No. 14 regarding 'Count Two: Enticement to Engage in Illegal Sexual Activity,' outlining the three legal elements the Government must prove. It specifies that this count relates specifically to a victim identified as 'Jane' during the period of 1994 to 1997.
DOJ-OGR-00008700.jpg
This document is a page of concluding remarks from a judge to a jury, filed on December 18, 2021, in the criminal case against Ms. Maxwell. The judge instructs the jurors on their duty to deliberate based solely on the evidence and law, to determine if the Government has met its burden of proof beyond a reasonable doubt, and to avoid being swayed by sympathy. The instructions also guide the jurors on how to interact during deliberations, encouraging open discussion while also urging them to hold fast to their own conscientious beliefs.
DOJ-OGR-00008695.jpg
This document is a page from the jury instructions (Instruction No. 55) filed on December 18, 2021, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The instruction advises the jury that it is standard practice for witnesses to meet with lawyers (both Government and Defense) to prepare before testifying and that such preparation is not improper, though the jury may weigh it when assessing credibility. The document bears the Bates stamp DOJ-OGR-00008695.
DOJ-OGR-00008693.jpg
This document is a jury instruction, specifically Instruction No. 53, from a legal case (1:20-cr-00330-PAE) filed on December 18, 2021. It directs the jury on how to properly consider electronic communications seized by the Government as evidence. The instruction clarifies that the evidence was obtained legally and that jurors must not let personal opinions about the seizure influence their deliberations, but rather should determine the weight of this evidence just as they would any other piece of evidence presented in the case.
DOJ-OGR-00008691.jpg
This document is page 153 of a court filing (Document 563) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated December 18, 2021. It contains Jury Instruction No. 51, which instructs the jury that the Government is not legally required to use any specific investigative techniques to prove its case and that the jury must decide based on the evidence presented.
DOJ-OGR-00008689.jpg
This legal document is a jury instruction, numbered 49, from a court case filed on December 18, 2021. It explicitly informs the jury about the defendant's constitutional right not to testify. The instruction directs the jury that they must not draw any negative or adverse inference from Ms. Maxwell's decision not to take the witness stand, as the burden of proof rests solely with the Government.
DOJ-OGR-00008675.jpg
This document is a jury instruction (No. 39) from a legal case (1:20-cr-00330-PAE), filed on December 18, 2021. It explains the legal doctrine of "conscious avoidance" or "willful blindness," instructing the jury that a defendant's deliberate act of ignoring a high probability of criminal activity can be treated as the legal equivalent of knowledge. This allows the jury to find that the defendant acted "knowingly" even without direct proof of their awareness.
DOJ-OGR-00008671.jpg
This legal document, part of an indictment, outlines several overt acts allegedly committed by Ghislaine Maxwell and Jeffrey Epstein in furtherance of a conspiracy. The acts include the recruitment and sexual exploitation of a minor named Carolyn between 2001 and 2004, involving payments, encouragement to recruit others, and arranging appointments. The document also mentions a separate 1996 incident involving another victim, Annie, and clarifies the legal standard for proving an overt act in a conspiracy case.
DOJ-OGR-00008668.jpg
This legal document, likely a page of jury instructions from a court filing dated December 18, 2021, outlines the legal standards for finding Ms. Maxwell guilty of participating in a conspiracy. It clarifies that the government does not need to prove she knew all the details or participants of the conspiracy, nor that she was involved from its inception. The document states that she can be held responsible for all acts of the conspiracy during its existence if she knowingly joined at any point, and that even a single act or a limited role could be sufficient to establish her membership.
DOJ-OGR-00008667.jpg
This document is a jury instruction (No. 35) from a federal criminal case (1:20-cr-00330-PAE), filed on December 18, 2021. It explains the second element of a conspiracy charge: 'Membership in the Conspiracy.' The instruction defines the terms 'willfully' and 'knowingly' for the jury, clarifying that the government must prove beyond a reasonable doubt that the defendant, Ms. Maxwell, deliberately and consciously joined a conspiracy to further its unlawful goals, rather than through mistake or negligence.
DOJ-OGR-00008659.jpg
This is a page from a legal document, likely jury instructions, from case 1:20-cr-00330-PAE, filed on December 18, 2021. The text defines the legal standard for 'aiding and abetting,' explaining that for the defendant, Ms. Maxwell, to be found guilty, the Government must prove she knowingly and willfully participated in a crime to help it succeed, not merely that she was present or aware of it.
DOJ-OGR-00008658.jpg
This document is a jury instruction (Instruction No. 30) from a federal criminal case, filed on December 18, 2021. It explains the legal concept of "aiding and abetting" as it applies to Counts Two, Four, and Six against the defendant, Ms. Maxwell. The instruction clarifies that the jury can find her guilty if she knowingly assisted another person in committing the crimes, even if she did not physically commit the acts herself.
DOJ-OGR-00008655.jpg
This legal document is a jury instruction (Instruction No. 27) from case 1:20-cr-00330-PAE, filed on December 18, 2021. It specifies the second element of Count Six, 'Sex Trafficking of an Individual Under the Age of 18,' requiring the Government to prove that the defendant, Ms. Maxwell, knew the victim, Carolyn, was under eighteen years old.
DOJ-OGR-00005858.jpg
This legal document is a court filing from October 29, 2021, detailing the defense's motion to exclude evidence seized from Epstein's Palm Beach home in 2005. The defense argues the evidence is inauthentic and unreliable, partly because the original custodian, Detective Recarey, is deceased. The Government counters that it will use other live witnesses to establish the evidence's authenticity at trial.
DOJ-OGR-00005857.jpg
This legal document is the Government's response to a defense motion to exclude 'Government Exhibit 52,' a physical contact book. The Government clarifies that it will offer the physical book itself, not a scan from the 'Guiffre v. Maxwell' civil case, and argues that the book's controversial acquisition history affects its weight, not its admissibility. The Government also contends the book is not hearsay because it is being used to prove the defendant kept contact information for victims, not to prove the accuracy of that information.
DOJ-OGR-00005846.jpg
This legal document is a filing by the Government arguing against the defense's claims of prejudice due to the volume of discovery material. The Government asserts that the defense's complaints are exaggerated, that it has clearly identified the evidence it will use at trial, and that suppression of evidence is not the proper remedy. A footnote clarifies that many co-conspirator statements, such as instructions from Epstein, are admissible on grounds other than the co-conspirator exception to hearsay.
DOJ-OGR-00002702.jpg
This document is a page from a legal motion filed by Ghislaine Maxwell's defense team on February 4, 2021. The defense argues that the government has failed to provide a 'bill of particulars' specifying the dates and details of alleged interactions with 'Accuser-1' (Minor Victim 1), including travel from Florida to New York for sexual encounters with Jeffrey Epstein. Citing the legal precedent *Bortnovsky*, the defense claims Maxwell cannot adequately prepare for trial because the allegations span a four-year period without specific dates, despite the government claiming to possess corroborating flight and business records.
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